Privacy Policy

DATA PRIVACY POLICY

1. Purposes and Scope of Data Processing

This privacy policy is prepared to explain the company’s data protection policy and to ensure that the data of users (“User”) who are members of the Tivizon application owned by Tivizon Dijital Platform Isletmeciligi Anonim Sirketi (“Company” or “Tivizon”) during their visits to these applications are processed in accordance with the relevant legislation, including the Constitution of the Republic of Türkiye, the European Union General Data Protection Regulation (“EU GDPR”), the Law on the Protection of Personal Data No. 6698 (“LPPD”), and the decisions of the Personal Data Protection Board.

2. Tivizon Privacy Policy

We process your data in accordance with the applicable legal provisions for the protection of personal data, in particular EU GDPR and LPPD. With the help of this privacy policy, we will inform you how Tivizon processes your personal data and the rights you have.

Personal data includes any information that relates to an identified or identifiable natural person, such as name, date of birth, address, phone number, e-mail address and also IP address.

This policy doesn’t apply to anonymous data which does not relate to an identified or identifiable natural person or to personal data rendered anonymous in such a manner that the data subject is not or no longer identifiable.

3. Data Processed in Our Application and Our Purposes of Use

When you open our application, the information sent by your provider is automatically saved by our servers. This data includes the type and version of your provider, your language preferences, the pages you accessed and the time you spent in our application, the information you searched for in our application, the date and time you accessed our application. These data are statistical data and do not contain your personal data and are collected in order to improve the use of our application and user preferences.

3.1 Personal Data Processed in Our Application

All personal data shared with us will be processed in accordance with the principles set forth in Article 4 of the LPPD, in a lawful, proportionate, and relevant manner, in connection with our activities and service objectives.

The personal data collected during the operation of our application may vary depending on which options you use in our application while using the application.

When you visit our video platform we collect and process the following data:

When you visit our video platform, your device transmits the following types of data, which we then save:
the browser type and language,
the IP address of the computer used to access the site,
the server requests (e.g. accessed pages) including time stamps and
the referral URL (i.e. the address of the previous website that you visited, if you came to our site by following a hyperlink from there).

These first three data types are technically required to be able to properly display the webpage you accessed. Moreover, this data may be used, if necessary, to maintain secure operation of this website (e.g. to protection against hacking). Besides the IP address and browser language, the referral URL is anonymized and used to compile statistics.

We also collect information about how you use Tivizon, such as the types of use or engage with; the features you use; the actions you take; frequency and duration of your activities. For example, we log when you’re using and have last used Tivizon.

For reasons of technical security and in particular to prevent attempts to attack our web server, this type of data are also stored for a certain period of time in accordance with Art. 6 Paragraph 1, Sentence 1(f) EU GDPR.

When you contact us with an enquiry, we collect and process the following data:

For example, our app offers you different ways to contact us for information about specific products. You can use the online chat function, request a call back or send an e-mail message.

A contact form is used to collect the required details for communication (e.g. name, phone number or e-mail address) as well as to send your message. The collected data are used for customer relations management (contact history) and for responding to/fulfilling your request.

When you place an order, we process the following data:

As a customer, you can order digital services and products in our website www.tivizon.com.
To process your orders, your contact details, invoice/delivery address and payment method (bank, credit cards, etc.) are required.

In some cases, a credit check may be performed when placing an order. Details will be provided during the ordering process. The credit check is carried out pursuant to Art. 6 Para. 1 S. 1(f) EU GDPR within the scope of our legitimate interest in the customer’s ability to pay.

When you apply online, we collect and process the following data:
– Basic data (e.g. name, additional names, date of birth, and academic titles, if applicable),
– Contact details (postal address, phone number, email address)

In addition, we may collect and process various other (voluntary) data. You may also choose to provide information regarding your personal accounts on social networks that may be relevant for the service.

We have implemented security measures to ensure that your data remain safe and confidential at all times. All account information submitted via the web site are encrypted. Provisions to protect your information always correspond to the latest technological standards.

Your data provided in the context of the buying process are stored subject to applicable law. We will retain your data beyond this point only if we are entitled to or have an obligation to do so, e.g. if you have given your express consent for us to retain your data for an extended and specified period of time, or to exercise our rights under applicable law.

For instance, we are obliged to retain certain data under the Turkish Consumer, Tax and Commercial Codes. All statutory periods of limitation are observed. You can find further information in the Privacy Policy.

When you subscribe to a newsletter, we collect and process the following data:

  • Title,
  • Last name, first name,
  • E-mail address.

Please be aware that we conduct anonymous link tracking for statistical purposes.

Contact forms / contact via e-mail, chat or phone.

A contact form is available on our website which can be used to contact us electronically. If you write to us using the contact form, we will process the information you provide to contact you and answer your questions and requests. (Art. 6 Para. 1 S. 1 (a, b) EU GDPR).

If you contact us by e-mail, we will process the personal data provided solely for the purpose of processing your enquiry.

If you request a call back, we collect your name and telephone number. When requesting a call back, you can attach a message if you wish.

You can also contact us via live chat. When using the chat feature, we collect and process your first and last names as well as your e-mail address. The chat history is saved on our internal servers for 90 days for reasons of follow-up and is then deleted.

All data required to complete the form is subject to the principles of data reduction and data economy, meaning you only have to provide the data that is absolutely necessary for processing inquiries and making contact.

For reasons of technical security and in particular to prevent attempts to attack our web server, we will also process your IP address.

Newsletters

You can subscribe to our free newsletter via our website. The e-mail address and name provided during the registration process are used to send a personalized newsletter in accordance with Art. 6 Para. 1 S. 1(a) EU GDPR.

The principle of data economy and data reduction is observed, as only the e-mail address, name and title are marked as mandatory fields to enable personalization. Due to technical and legal reasons, we will also process your IP address.

You can cancel your subscription at any time via the unsubscribe option provided in the newsletter and therefore revoke your consent. You also have the option to unsubscribe directly via our website.

Online Shop

Unless you agree to the additional terms use, we only process the data you provide on an order form for the performance or processing of the contractual relationship. Art. 6 Para. 1(b) EU GDPR.

All data are subject to the principles of data reduction and data economy, meaning you only have to provide the data that is absolutely needed for the performance of the contract or for the fulfilment of our contractual obligations (i.e. your name, address, e-mail address and the payment data required for the chosen payment method) or to which we are legally obliged to collect.

Due to technical and legal reasons, we will also process your IP address. Without this data we will unfortunately have to reject the contract, as we will then not be able to perform our obligations. We may also have to terminate an existing contract. You can of course provide us with more data if you wish.

3.2 Cookies

The cookies used in our application automatically collect your data through your devices that you access our application. Cookies are used to facilitate the use of our application, to improve your user experience, to enhance application efficiency and functionality, to have information about the use of the application, to make updates on the application, to develop and personalize application features according to User preferences, to ensure the legal and commercial safety of visitors and the Company, and to ensure easy and quality use of the application. Cookies can be deleted by the user at any time or the use of cookies can be blocked.

4. Purposes of Processing Your Personal Data

Your personal data is processed for the purposes of;

  • Fulfillment of the Company’s legal obligations,
  • Resolution of legal disputes that may arise in the future,
  • Protection and use of the rights of the data subject recognized by the law,

in accordance with the personal data processing conditions and principles specified in Articles 4 and 5 of the LPPD. Your personal data will not be processed for any purpose other than these specific purposes.

5. Transfer of Your Personal Data

Your personal data may be transferred to;

  • Authorized official authorities and organizations and legally authorized individuals in order to fulfill the legal obligation or to establish, exercise or protect the rights of the Company,
  • Judicial authorities for the purpose of conducting or tracking judicial proceedings

within the framework of the procedures and principles stipulated in the relevant legislation, in accordance with the conditions and purposes of transferring personal data specified in Article 8 of the LPPD.
Within our Company, we only receive your data from those who need it to fulfill their contractual and legal obligations.

Through our website, agreements are made with Tivizon Dijital Platform Isletmeciligi A.S.

It is possible that other affiliated and/or sister companies may also be involved during the agreements and requests. For example, a request for on-site support may be processed by an Tivizon affiliate in your region.

In some cases, service providers support our specialized departments in fulfilling their tasks. An example of this is sending newsletters.

Necessary data protection agreements have been concluded with all service providers.

Data is transferred to third countries (countries outside Türkiye, the European Union or the European Economic Area) in accordance with the law, if you have given your consent or if this is necessary for the fulfillment of a commitment. Currently, this happens when you use a service to make an inquiry because a service provider outside of Türkiye and the European Economic Area, who provides us with this functionality, has access to your personal data. In this case, we take all possible and necessary measures to establish the level of data protection in the third country in accordance with Article 9 of the LPPD and Article 44 et seq. of the EU GDPR.

6. Method and Legal Grounds for Collecting Your Data

When you open our application, our servers automatically store non-personal information sent by your provider, such as your device’s provider type and version, operating system type and version, and language preferences. This data is deleted when you close your provider.

6.1 Method and Legal Grounds for Collecting Your Personal Data

When you open our application, the IP address and Mac information of your device are obtained by our servers by automatic methods. The IP information and MAC addresses of the users who visit our application are collected based on the legal grounds explicitly stipulated in the law as specified in subparagraph a of paragraph 2 of Article 5 of the LPPD pursuant to the Law No. 5651 on the Regulation of Publications on the Internet and Counteracting Crimes Committed Through These Publications.

Your personal data can only be processed if at least one of the personal data processing conditions stipulated in the LPPD is present. Your personal data is obtained by automatic methods by recording your IP information and Mac addresses during your visit to the application.

7. Retention and Destruction of Your Personal Data

Personal data processed within the framework of the activities of our application are stored for the period stipulated in the relevant legislation or in accordance with our processing purposes.

Your personal data will be destroyed when;

  • The all purposes requiring the processing of personal data and the reasons requiring its retention are disappeared, the provisions of the relevant legislation are amended or revoked,
  • You request the disposal of your personal data by exercising your rights specified in Article 11 of the LPPD and the application made is approved by us,
  • The application made by the data owner with the request for the deletion, disposal or anonymization of your personal data is rejected by us or if no response is given within the period stipulated in the LPPD; if the data owner files a request to the Personal Data Protection Board and this request is approved by the Personal Data Protection Board,
  • The maximum period required for the retention of personal data has expired and there is no circumstance justifying the retention of personal data for a longer period of time

Your data will be preserved only for as long as it is necessary for the purposes described in this Privacy Policy.

8. Data Security

Your personal data processed in our application is preserved securely and appropriate measures are taken to protect your data against unauthorized or unlawful processing, accidental loss, disposal or destruction.

Appropriate technical and organizational security measures have been taken to protect data from accidental or intentional manipulation, loss, damage or unauthorized access. For this purpose, the level of security is constantly tested and adjusted in accordance with new security standards in collaboration with security experts.

Incoming data to our website and data transferred between our website are always encrypted. We use HTTPS as the communication protocol for our website and use up-to-date encryption protocols in all cases.

We also offer our users content encryption for contact forms and applications. Only we can decrypt this data. It is also possible to use alternative communication channels (e.g. by post).

Various personal data are necessary for the establishment, execution and termination of the commitment and the fulfillment of contractual and legal duties related thereto. The same applies to the use of our website and the various functions it provides.

We have summarized the details for you above. In some cases, data must be collected or provided based on legal regulations. Please note that without the provision of this data it is not possible to process your request or fulfill the underlying obligation.

9. Rights of the Data Subject

Pursuant to Article 11 of the LPPD;

  • You can have information whether your personal data is processed by us or not.
  • You can request information from us if your personal data is processed by us.
  • You can find out for which purposes we process your personal data and whether your personal data is used in accordance with these purposes.
  • If we process your personal data for the purposes of direct marketing, you have the right to object at any time without giving any reason. This right applies insofar as it is directly linked to advertising-related profiling.
  • If you object to the processing of your personal data for direct marketing purposes, no further processing will be carried out for these purposes.
  • You can learn about third parties to whom we transfer your personal data domestically or internationally.
  • If we have processed your personal data incompletely or inaccurately, you can demand their correction and request that these corrections be transmitted to the third parties to whom we have transferred your personal data.
  • Although we have processed your personal data in accordance with the law and other relevant national and international legislation provisions, you may request the deletion or disposal of your personal data in the event that the reasons requiring the processing of your personal data no longer apply, and you may request that the corrections made within this scope be communicated to third parties to whom we have transmitted your personal data.
  • In the case that a consequence occurs against you by analyzing the data we process exclusively through automated systems, you may object to this result.
  • In any case you incur any damage due to the processing of your personal data in violation of the law, you may request the compensation of the damage caused by unlawful data processing.

Your personal data may further be processed if it is explicitly stipulated by law, the processing of personal data belonging to the parties of a contract is necessary provided that it is directly related to the execution or fulfillment of a contract, it is mandatory for the data responsible to fulfill its legal obligation, it has been made public by the data subject himself/herself, it is mandatory to process data for the exercise or protection of a right, it is mandatory to process data for the legitimate interests of the data responsible, provided that it does not harm the fundamental rights and freedoms of the data subject.

In order for you to have an easy access to exercise your rights listed above and to submit the related requests to us easily, you can contact us via our contact information below. We will respond to you as soon as possible and within thirty days at the latest, depending on the qualification of your application. In principle, data owners’ applications are answered free of charge; however, we reserve the right to charge you a fee according to the tariff to be determined by the Personal Data Protection Board in case of additional costs.

In order to exercise your rights set out in Article 11 of the LPPD, you can apply to our Company by sending an e-mail to our e-mail address below or by sending mail to our address:
Tivizon Dijital Platform Isletmeciligi Anonim Sirketi, Cumhuriyet Mah. Tavukcu Fethi Sok., No: 4 Ic Kapi No. 2 Şişli

İstanbul 34380 Türkiye

Contact Information: support@tivizon.com

Data Protection Officer: privacy@tivizon.com

10. Updating the Privacy Policy

If this policy is updated, users will be notified by publishing the current policy in our application via this link.

11. Payment Systems and Credit Checks

You can pay with a credit card or via PayPal in our online shop. The respective payment-relevant data are collected in order to be able to carry out and complete your order and payment. Art. 6 Para. 1 S. 1(a, b) EU GDPR. Due to technical and legal reasons, we will also process your IP address.

All data are subject to the principles of data reduction and data economy, meaning you only have to provide the data that is absolutely needed to complete your payment and therefore execute the contract or for the collection of which we are legally obliged.

Without this data we will unfortunately have to reject the contract, as we will then not be able to perform our obligations.

The payment system we use employs SSL encryption to ensure the secure transfer of your data.

12. Responsible Executive and Data Protection Officer

Tivizon Dijital Platform Isletmeciligi Anonim Sirketi, Cumhuriyet Mah. Tavukcu Fethi Sok., No: 4 Ic Kapi No. 2 Şişli İstanbul 34380 Türkiye

Contact Information: support@tivizon.com

Data Protection Officer: privacy@tivizon.com

13. Your Rights as a Data Subject

We would like to inform you about your rights as a data subject. 15 – 22 EU GDPR. These include:

  • Right of access (Article 15 EU GDPR),
  • Right to erasure (Article 17 EU GDPR),
  • Right to rectification (Article 16 EU GDPR),
  • Right to data portability (Article 20 EU GDPR),
  • Right to restriction of processing (Article 18 EU GDPR),
  • Right to object (Article 21 EU GDPR),

    To exercise these rights, please contact: privacy@tivizon.com. In the case of questions about data processing at Tivizon, the same is also applicable. You also have the right to appeal to the supervisory authority for personal data protection.