1. KEY DETAILS AND WHO WE ARE
1.1. Our Purpose
The personal information subject to processing may differ from one action to another such accessing to Website, assigning-up for an account, using the Application, using services provided with Disconti card (“Disconti Card”) or contacting us; and Disconti using the Policy herein informs you about how we handle your personal information in different cases.
If you are a resident of State of California, please see §7.1 titled “Additional Information for Users/Visitors from California” and; if you are a European citizen, see §7.2 titled “Additional Information for Users/Visitors from European ”.
1.2. Data Controller
Disconti Bilgi Teknolojileri A.Ş. having its address at Atatürk Mahallesi Ertuğrul Gazi Sokak Metropol İstanbul Sitesi C2 Blok Apt. No:2A/14 Ataşehir/İstanbul with trade registry number 231647-5 is a data controller (“Controller”) for any and all data processing that occurs through accessing the Application and purchasing Disconti Card.
1.3. Contact Details
Contact details of Disconti are as follows:
Name of the company: Disconti Bilgi Teknolojileri A.Ş.
Postal address of the company: Atatürk Mahallesi Ertuğrul Gazi Sokak Metropol İstanbul Sitesi C2 Blok Apt. No:2A/14 Ataşehir/İstanbul
E-mail address [email protected]
Trade registry number 231647-5
For the Policy the definitions provided herein shall be understood as follows:
CCPA The California Consumer Privacy Act of 2018, signed into law on June 28, 2018 by the State of California
Data Controller A natural or legal person who determines the means of and purposes for processing personal data
Data Subject A natural person who can be identified or rendered identifiable through the personal data related to
GDPR The General Data Protection Regulation, signed into law on May 25, 2018 by the European
Personal Data Information that makes it possible for any other person to identify an individual to whom the data relates to
Personal Data Breach A breach of security whether accidental or on purpose, resulting in accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data
Sensitive Personal Data Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade membership and; genetic and biometric information, information concerning data subject’s sex life or sexual orientation
Third Party Any other natural or legal person that is not part of Disconti
3. YOUR PERSONAL DATA
3.1. Personal Data You Provide Us
The Personal Data listed hereunder may be collected when you;
3.2. Categories and Types of Personal Data
3.3. Personal Data Collected by Us
The Personal Data listed hereunder may be collected through automatic means including without limitation cookies, server logs and other technologies of equivalent nature. In cases where a Third Party uses our cookies, we may also receive Personal Data therefrom.
3.3.1. Categories and Types of Personal Data
3.4. How Your Personal Data is Processed
Your Personal Data given to or collected by us shall only be processed when necessary and as it is given in the table below:
188.8.131.52. First Name and Last Name
184.108.40.206.1. Processing Reason: Creating an account
220.127.116.11.1.1. Legal Basis: Entering into a contract
18.104.22.168.2. Processing Reason: Identifying the contracting party
22.214.171.124.2.1. Legal Basis: Entering into a contract
126.96.36.199.3. Processing Reason: Issuing an e-archive invoice
188.8.131.52.3.1. Legal Basis: Complying with a legal obligation
184.108.40.206.4. Processing Reason: Sending a reply to whom contacted us through Website
220.127.116.11.4.1. Legal Basis: Legitimate interest
18.104.22.168. Email Address
22.214.171.124.1. Processing Reason: Creating an account
126.96.36.199.1.1. Legal Basis: Entering into a contract
188.8.131.52.2. Processing Reason: Guiding for password renewal
184.108.40.206.2.1. Legal Basis: Performance of a contract
220.127.116.11.3. Processing Reason: Notifying about distant sales agreement
18.104.22.168.3.1. Legal Basis: Performance of a contract
22.214.171.124.4. Processing Reason: Sending an e-archive invoice
126.96.36.199.4.1. Legal Basis: Complying with a legal obligation
188.8.131.52.5. Processing Reason: Sending a reply to whom contacted us through Website
184.108.40.206.5.1. Legal Basis: Legitimate interest
220.127.116.11.6. Processing Reason: Sending commercial messages
18.104.22.168.6.1. Legal Basis: Clarified explicit consent
22.214.171.124. Phone Number
126.96.36.199.1. Processing Reason: Allocating an account to a phone number
188.8.131.52.1.1. Legal Basis: Performance of a contract
184.108.40.206.2. Processing Reason: Notifying about distant sales agreement
220.127.116.11.2.1. Legal Basis: Performance of a contract
18.104.22.168.3. Processing Reason: Sending a reply to whom contacted us through Website
22.214.171.124.3.1. Legal Basis: Legitimate interest
3.4.3. Marketing Information
126.96.36.199. Order History
188.8.131.52.1. Processing Reason: Issuing an e-archive invoice
184.108.40.206.1.1. Legal Basis: Complying with a legal obligation
3.4.4. User Feedback
220.127.116.11.1. Processing Reason: Improving the Application
18.104.22.168.1.1. Legal Basis: Legitimate interest
3.4.5. Profile Information
22.214.171.124.1. Processing Reason: Creating an account
126.96.36.199.1.1. Legal Basis: Entering into a contract
3.4.6. Usage Information
188.8.131.52. Use of the Application
184.108.40.206.1. Processing Reason: Improving the Application
220.127.116.11.1.1. Legal Basis: Legitimate interest
3.4.7. Location Information
18.104.22.168.1. Processing Reason: Suggesting nearby places
22.214.171.124.1.1. Legal Basis: Clarified explicit consent
126.96.36.199.1. Processing Reason: Offering personalized campaigns and discount options to Users
188.8.131.52.1.1. Legal Basis: Legitimate interest
3.4.9. Technical Information
184.108.40.206. IP Address
220.127.116.11.1. Processing Reason: Accessing the Application
18.104.22.168.1.1. Legal Basis: Complying with a legal obligation
22.214.171.124. Cookie Information
126.96.36.199.1. Processing Reason: Improving the Application
188.8.131.52.1.1. Legal Basis: Legitimate interest
3.5. Changes to Above-Mentioned Information About Processing
In the event of any changes to those listed in §3.3, this Policy shall be updated accordingly.
4. Data Transfer
Your Personal Data may only be transferred when your explicit and informed consent is acquired to do so with exceptions mentioned below.
4.1. Competent Authorities such as Law Enforcement and Judiciary Authorities
Your Name-Surname data may be transferred to competent authorities in case of dispute.
4.2. Presidency of Revenue Administration
Your Name-Surname, E-mail Address and Order History data may be transferred to Presidency of Revenue Administration within the scope of e-archive services in accordance with the legislation.
4.3. Eren Holding & Group Companies
Your Name-Surname, E-mail Address, Phone Number, Order History, Location Data and Gender data may be transferred to Eren Holding and group companies in order to collaborate in commercial activities.
4.4. İleti Yönetim Sistemi Anonim Şirketi
Your E-mail Address data may be transferred to İleti Yönetim Sistemi Anonim Şirketi within the scope of conducting permission and complaint operations through Message Management System in order to fulfill our obligations arising from the legislation.
4.5. E-Mail Sending Service Provider
Your E-Mail Address data may be transferred to the company providing e-mail sending service in order for us to send commercial e-mails.
4.6. Mobile Application Server and Infrastructure Services Provider
Your Name-Surname, E-mail Address, Phone Number, Order History, Location Data and Gender data may be transferred to the company providing server and infrastructure services for Mobile Application.
5. Information Security
We have enacted appropriate security measures to ensure the safety, protection and the encryption of your Personal Data such that we may prevent accidental or unauthorized destruction, loss, theft or; unauthorized use, alteration and disclosure.
To do so, we limit the accessibility of your Personal Data to our employees, agents, contractors, affiliates, directors and other relevant Third Parties on a need-to-know basis. Any legal or natural person processing your Personal Data shall be under the duty of confidentiality and shall act accordingly.
In addition, any case of Personal Data Breach or reasonable suspicion of shall be handled according to our internal documents detailing how to act under such circumstances.
6. Children’s Privacy
Our Application is not intended for those under the age of 13 and between 13 and 18 without his/her parent’s or legal guardian’s allowance (a “Minor”) as stipulated in our Terms of Service, as a result of this Disconti does not knowingly collect Personal Data belonging to a Minor.
If we learn that any Personal Data processed by us, belongs to a Minor Disconti shall take the appropriate measures to delete such Personal Data.
7. Additional Information Regarding Different Legislation
7.1. Additional Information for Users/Visitors in California
7.1.1. California Residents’ Privacy Rights
Our Users and Application/Website Visitors residing in the State of the California have the right to contact us to be informed about their Personal Data, if any processed by us or shared by us with Third Parties.
7.1.2. 7.1.2. California and Delaware “Do Not Track” Disclosures
As per California and Delaware State Laws, Disconti honors the “Do Not Track” settings in the privacy settings that turn-off targeted advertising.
7.2. Additional Information for Users/Visitors in European
Your Personal Data listed under §3.3 shall be processed,
7.2.2. Legal Bases
Legal Bases for processing Personal Data listed thereunder §3.3 shall be understood as listed under GDPR Article 6 as;
8. Your Rights
We undertake to respond your request as soon as possible but not more than 30 (thirty) days, and without any charge, as long as there is no transaction cost.