PRIVACY POLICY

Release, November 10, 2020

Who are we?

The Buvigo offered by Application (the "Application") is Mest Yazılım ve Bilişim Teknolojileri (here in after referred to as "Buvigo", "we" or "our").

Buvigo, Law No. 6698 on the Protection of Personal Data and the protection of natural persons regarding the processing of Personal Data, and the applicable data protection, including the General Data Protection Regulation (EU) No. 2016/679 of 27 April 2016 on the free movement of such data, as well as other applicable law provisions. is determined to protect and ensure the security of your Personal Data in accordance with the legislation (hereinafter referred to as "Data Protection Legislation").

This Privacy Policy ("Policy") states how we collect, use and share information ("Personal Data") that makes your identity specific or identifiable ("you", "belonging to you or the user"). If you have a request or complaint regarding this Policy, please contact us via the Data Protection Officer whose contact details are provided in the "Contact Us" section below. You can also apply to your local data protection authority. For the interpretation of terms not defined in this Policy, the definitions in the Buvigo Terms of Use ("Terms of Use") will be considered. For more information about cookies, please also read our cookie policy.

By Which Methods Is Your Personal Data Collected?

Buvigo collects your Personal Data if you provide it directly to us of your own will or when you transmit information through the Application. This information includes information you provide when you register to use the Application, create an account and profile, fill out a form, contact us, purchase products through the Application, or participate in surveys or promotions.

In addition, the device you connect to the App, information about how you use the App or our service providers, etc. We collect Personal Data from you indirectly, as well as information you obtain from third parties.

You can find detailed information about which data is collected for which purposes in the sections below.

Which Personal Data Is Collected?

We explain the categories of Personal Data we collect in more detail below:

• Identity and Contact Information: Phone number, username (nickname), avatar, e-mail address and other similar data, membership information, for authentication and account access in the App (if applicable). data such as passwords used;
• Usage Information and Favorites: Various technical data collected from your device through technical equipment, the type of messages (text message, video, etc.) sent (without collecting any information about its content), your preferred language, the time of active use, the type of services used, Usage habits related to the application interface. Data regarding the results of satisfaction surveys or similar surveys conducted through the Application, including, but not limited to, the date of the last login to the Application, errors that occurred during the use of the Application;
• Location Information: Data regarding the (approximate) location of the users. These include location and navigation data from nearby base stations, active Wi-Fi hotspots and IP addresses, as well as GPS data, depending on the device settings controlled by you.
• Payment Information: Payment information including the relevant price, invoice, invoice number, tax amount and payment method in case you make any in-App purchases.
• Device Information: Data such as device model, device operating system, preferred phone language, information about which operator users are using, country information.
• Backup Information: Contact data can be backed up by Buvigo upon users' request.
• Nickname, Profile Photo, Status Information.

For What Purposes Is Your Personal Data Processed?

Your Personal Data is processed by Buvigo for the purposes described below:

• Identity Information: This information includes user registration, error / failure notifications, control, development and realization of operational activities, business development, customer portfolio management, service quality measurement, communication, internal evaluation, promotion, service analysis, complaint management, customer survey process management and application subscription to other devices.
• These Personal Data are used for business development, direct or indirect marketing (customer campaigns, advertisements, services and functions in the application, advertisements to customers), profiling (presentation of ads according to your preferences, customers' location, operator, duration of use, application duration and functions. classification), audit and control, risk management, improvement of after-sales processes, internal evaluation, portfolio management, measurement and improvement of service quality, communication, execution of complaint management processes, execution and development of operational activities (as detailed below) Microsoft and the provision of translation service provided by Google, error / failure notifications and improving service quality based on usage habits. This information is processed for purposes such as promotion, internal evaluation, analysis and communication through anonymous data (in a way that users cannot be determined) and also statistical evaluation.

• Location Information: These Personal Data are processed for the purposes such as enabling users to share their locations with each other, controlling and controlling location services associated with the "Buvigo ID" field, getting directions, and also developing products and strategies.
• Payment Information: These Personal Data, management of invoicing processes and payment information of users who purchase in-app services, management of payment information, accounting, improvement of after-sales processes, business development, internal evaluation, customer portfolio management, after-sales services, communication, marketing is processed for purposes such as inspection and control.

• This Personal Data is used to determine usage habits and to detect unauthorized and fraudulent use in order to improve business development, marketing, service quality. During the processing of personal data in this category, no data regarding the content of the communication is reached.
• This Personal Data is used for backing up communications at the request of the users. The messages that the user receives from another user or sends to another user will only be archived at the request of the other user.
• These personal data will be shared with other users with public or private options in line with the instructions provided to the user through the Application. The responsibility of sharing personal data here belongs to the person using the application and accepts these terms.

Buvigo can anonymize and consolidate each of the data collected (so that the users in question are not made specific or identifiable). Buvigo uses anonymized data to test its own information technology systems, research, data analysis, App improvement, development of new products, direct or indirect marketing, advertising, profiling, or purchases made through the App (e.g. most popular purchases or purchases based on a specific location) for purposes such as viewing information.

What is the Legal Basis for Processing Personal Data?

Buvigoobligedisto process Personal Data for the purposes stated above and in accordance with the applicable Data Protection Legislation. Personal Data may be required by Buvigo to record the usage of the Application, to open an account, to create a profile, to fill out a form regarding Buvigo, to purchase products through the Application, or to participate in surveys or promotions approved by the user.

In cases where the legal reason for the processing of Personal Data of the User is the explicit consent to the processing of the Personal Data, the user has the right to withdraw the consent given at any time.

Personal Data may be partially or completely used in line with the purposes stated in this Policy, based on the legal reasons stated in Articles 5 and 6 of the Personal Data Protection Law, this Policy and Article 6 of the EU General Data Protection Regulation (or any other applicable Data Protection Legislation). By automatic or non-automatic methods, through dealers, call centers, websites, Application, messages and all kinds of written, verbal and electronic media

• To the extent stipulated in the legal legislation to which Buvigo is subject,

• Directly related to the establishment or performance of such data processing, Provided that, the processing of personal data of the parties to the contract, in case the claimed products and services offered on or users to supply the requirements to fulfill the terms of the contracts signed,

• Buvigo in cases where the processing is necessary data to fulfill their legal obligations,

• If the Personal Data in question is already made public by the person concerned,

• In case data processing is mandatory for the establishment, exercise or protection of a right,

• Provided that the said data processing does not violate the fundamental rights and freedoms of the persons concerned, it can be collected, processed and transferred if it is necessary for the legitimate interests of Buvigo.

Limitation of Purpose

Personal Data can only be processed to the extent necessary for the purposes described above. Personal Data cannot be processed for purposes other than the purpose for which it was collected. When Personal Data needs to be processed for other purposes, Buvigo will examine whether the purposes of the planned data processing are suitable for the initial data processing purposes. Buvigo will inform the user of the other data processing purpose before processing the data other than for the purpose for which it was collected. Buvigo will not process Personal Data more than required for the purpose of processing and will keep the data processing activity limited and measured for the purpose of processing.

Where Is Personal Data Stored and Processed?

Buvigo Personal Data collected by may be transferred to and stored in countries outside the jurisdiction of users, including countries outside the European Union (EU) or European Economic Area (EEA). Some of these countries offer different levels of protection for Personal Data, and in some cases it may be less protective than the user's country of residence. Buvigo takes all reasonable measures to ensure that Personal Data is processed securely and in accordance with this Policy and Data Protection Legislation. The transfer of Personal Data is only carried out in accordance with the applicable Data Protection Legislation and if the parties take appropriate protection measures that ensure an adequate level of protection as required by the applicable law.

With Whom Are Personal Data Shared?

Buvigo will be able to share the Personal Data it obtains with the following parties:

• Users: Buvigo and the user may share Personal Data with other users (including Official Accounts) as part of the Application so that users can interact with other users in line with the functionality of the service and their own preferences and to the extent permitted by applicable law. In the event that a User shares Personal Data belonging to another contact person, that User assumes full responsibility for this sharing.
• Service providers, partners and consultants: Third parties who serve Buvigo or its partners in the field of marketing and other commercial activities, consult Buvigo or work with Buvigo in other commercial activities. Buvigo may transmit Personal Data to marketing and other business partners, as well as to other carefully selected third parties who wish to provide you with different products or services that Buvigo or third parties consider to be of interest to you, if it is in accordance with the law. The third parties in question are only allowed to use Personal Data in accordance with Buvigo's instructions or the marketing preferences of the users (if any), and they must keep this information safe in accordance with the data processing agreements signed with the said parties as far as applicable.
• Judicial authorities, regulatory agencies and other parties in line with legal obligations: Buvigo is obliged to provide Personal Data under a legal obligation and to protect both its own rights, property or safety, as well as the rights, property or safety of third parties, illegal activities or any third parties to whom it is obliged to disclose Personal Data in order to detect and investigate violations of a contract.

Buvigo may provide aggregated statistical data and analysis about users of the Application to third parties. Buvigo declares that the persons concerned cannot be made identifiable from the data shared in this way, unless disclosed by him. Buvigo is not responsible for such third party service providers.

Your Rights Regarding Your Personal Data

The users of the application will be able to use the following rights in accordance with Article 11 of the Personal Data Protection Law:

•  Learning whether Personal Data is processed,

• Requesting information if Personal Data has been processed,

• Learning the purpose of processing Personal Data and whether they are used appropriately for their purpose,

• Learning the third parties to whom Personal Data is transferred domestically or abroad

• To request correction of Personal Data if it is incomplete or incorrectly processed,

• Request the deletion or destruction of Personal Data within the framework of the provisions specified in Article 7 of the Personal Data Protection Law,

• Request notification of the processes regarding the correction, deletion or destruction of Personal Data to third parties to whom Personal Data has been transferred,

• To object to the processing of Personal Data exclusively through automated systems,

• To request the compensation of the damage in case of damage due to the processing of Personal Data illegally.

In addition to the rights mentioned above, users of the Application may also have the following rights depending on their location:

• Learning whether their Personal Data is processed,
• If Personal Data has been processed, requesting information and a sample thereof,
• Learning the purpose of processing Personal Data and whether they are processed in accordance with the purpose in question,
• Learning about third party buyers to whom Personal Data is transferred domestically or abroad,
• Request correction or limitation of Personal Data in case of incomplete or incorrect processing,
• To request the deletion or destruction of data in accordance with the conditions specified in the Data Protection Legislation,
• Requesting the restriction of data processing in cases where Personal Data is processed subject to the user's consent,
• To the extent possible, to request that the Personal Data submitted to Buvigo be transferred to another data controller or the data data subject himself in a structured, commonly used and machine-readable format,
• Object to the processing of Personal Data,
• Requesting the notification of third parties with whom Personal Data is shared about the procedures for correction, deletion or destruction of data
• To object to the occurrence of a result that creates legal effects against the person himself and significantly affects the person negatively by analyzing the processed Personal Data only through automatic means.

In order to exercise any of your rights mentioned above in relation to your Personal Data, or your right to data portability (if any), please contact us using the contact information provided in the "Contact Us" section below. Please provide as much detailed information as possible about the data you want to exercise your rights for so that we can help you determine for which data you want to use your rights mentioned above. The information provided will be free of charge, unless the request is obviously unfounded or disproportionate (in which case a reasonable fee may be charged or your request may be denied). Users also have the right to file a complaint with a local data protection authority.

Age Restriction

Users must be 16 years old or older to share their Personal Data in the Application, and it is not desired to request, collect or process Personal Data of Users under the age of 16. In some countries, a different age limit may be set for not less than 13 years old. In such a case, you must fill the age in question. If you believe that we have processed Personal Data of a User under the age of 16 in error, please contact us via the contact details provided. If we find that we have inadvertently processed Personal Data of any user under the age of 16, we reserve the right to delete them.

Retention Period of Personal Data

Buvigo will retain Personal Data for the period required for data collection and / or processing purposes - for a maximum of 2 (two) years - unless a longer retention period is specified by applicable law. This includes retention of Personal Data for the period specified in accordance with the relevant legislation in case of any conflict that may arise from the Terms of Use. The maximum retention period for messages sent while a user is offline is three weeks, after which these messages will be deleted. Buvigo securely deletes Personal Data when Personal Data is no longer required for processing purposes, and ensures that all Personal Data recipients comply with the same obligation, unless the Personal Data is required to be stored for a longer period of time as required by the obligations arising from the legislation.

Measures Regarding Data Security

Buvigo takes care of the security of your Personal Data and takes appropriate technical and administrative measures to prevent unauthorized access to Personal Data and their illegal processing. Your Personal Data is protected by our strong security functions, which we carefully implement and regularly update.

Buvigo does not transfer any Personal Data of Users to third parties in violation of this Policy and / or the applicable Data Protection Legislation. Buvigo may carry out secondary processing of Personal Data only if such processing is compatible with the purpose and lawful. In the event that the Personal Data of Users are shared with outsourcing service providers in accordance with the provisions of this Policy, Buvigo will take the necessary measures to ensure that such third party service providers can provide protection at Buvigo level for personal data.

However, Buvigo does not assume any responsibility for third party applications where a link is provided through the Application, provided that such applications are not under the control of Buvigo, for transactions with other users and / or third parties.

Automated Decision Making Personal Data is not processed to make decisions about users through automated systems.

Changes to This Policy

Buvigo will update and change the provisions of this Policy in case of any changes / updates to the Data Protection Legislation. In such a case, the updated Policy will be brought to your attention by being published through the Application. Updates and changes made to the Policy by Buvigo are valid from the date of publication in the Application.

Contact Us

Your questions, comments and requests regarding this Policy can be sent to Buvigo via e-mail at info@buvigo.com or in writing to the following e-mail or postal addresses:

Data Protection Officer

MEST YAZILIM ve BİLİŞİM TEKNOLOJİLERİ

info@buvigo.com

Cumhuriyet Mah. Ataturk Boulevard Ilyas Center KARADAG ISA 31/15 ALTINOVA / Yalova / TURKEY