1.  Objective

Codeway Dijital Hizmetler Anonim Şirketi (“Codeway” or “Company”), aims to process the personal data of users in accordance with general principles of privacy and the provisions of the Law on Personal Data Protection No. 6698 (“PDP Law”) and other applicable legislation.        

Your personal data, which you provided/will provide to our Company and/or obtained by our Company by any external means, may be processed by our Company as “Data Controller”;

• In the context of the objective of processing your personal data and in connection with this purpose, in a limited and measured manner,
• By maintaining the accuracy and up-to-date version of the personal data as reported or notified to our Company,
• May be recorded, stored, preserved, reorganized and be transferred to the institutions authorized to request such personal data by law and shall be transferred, classified and shared with third parties within the country or abroad under the conditions stipulated by legislation, and  they may be processed  by other means  listed under the legislation and be subject to other procedures set forth in the legislation.

This Privacy Policy is adopted for the continuance and improvement of the activities carried out by Codeway in line with the principles set forth in the PDP Law.

This Privacy Policy describes which data we collect, how we intend to use, store, protect and share the data we collect, how you can withdraw your consent for the processing of these data and how you can correct and revise the data.

2.  Collection of Personal Data and Method

Codeway may process your personal data for the purposes specified in this Privacy Policy.

The personal data of users collected and used by Codeway in particular, are as follows:

• your name and surname, e-mail address, phone number which we will receive once you contact Codeway, and
• identifier for advertisers designated in your mobile device used in accessing our services (The Identifier for Advertisers-IDFA), identifier for vendors/developers designated your mobile device (The Identifier for Vendors-IDVF) and Internet Protocol Address-IP Address).

We may collect your abovementioned data directly from you through electronic or physical mediums, your mobile device, third party applications or third party sources which you can access our application through these mediums such as Apple App Store, Google Play App Store, Amazon App Store (similar platforms together with “App Stores”), for the purposes of compliance with legal obligations, enhancing  our services, administering  your use of our services, as well as enabling  you to enjoy and easily navigate our services.

We may collect your Log Data generated while you are using our services/applications (through our products or third party products). This Log Data may include information such as your device’s Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our service/application, the time/date of your use of the service/application, and other statistics.

Cookies:

Cookies are little text files that are stored on the browser or hard drive of your computer or mobile device when you visit a webpage or application.  Cookies allow a website to run more efficiently in addition to ensuring the presentation of personalized web pages in order to make you live a faster visit experience which is more fit for your specific personal needs and demands. Containing only data on your website visit history via the internet, cookies do not collect any information, including your personal data/files stored on your computer or mobile device. We may use cookies when it is necessary for operating our services, to enhance our service performance and functionality, and to deliver content, including ads relevant to your interests, on our sites, or third-party sites. You can delete cookies which are already present on your computer and prevent the recording/location of cookies on your internet explorer.

Internet browsers are predefined to automatically accept the cookies as default. As the management of cookies varies from browser to browser, you may look at the help menu of the browser or application to get detailed information.

Links to Other Websites

In case you are directed to the related website by clicking the link of third party web sites that are found in our Services; we would like to inform you that Codeway has no obligation and control over these web sites. For this reason, we recommend you to review the privacy information of the related site you are directed to.

3.  Purposes of Processing Personal Data and Legal Reasons

Your personal data will be processed via automatic or non-automatic means for the purposes stated below, in accordance with the applicable legislation and articles 5 and 6 of the PDP Law where it is expressly permitted by the laws, the establishment of a contract or direct relation to  the execution or performance of the contract and for the legitimate interests of Codeway provided that your  fundamental rights and freedoms are protected.

The purposes of processing personal data may be updated in line with our obligations arising from our company policies and legislation; in particular,

• Creating user accounts for the service recipients/application users,
• Customizing our Services, understanding our users and their preferences to enhance user experience and enjoyment using our Services and improve our users’ experience,
• Informing about new products, services and applications and delivering you information regarding advertisements and promotions,
• Carrying out a digital subscription and In-app purchase processes of service recipients,
• Carrying out the auto-renewable subscriptions for giving users access to content, services, or premium features in our service,
• Carrying out the processes of information security,
• Conducting activities in accordance with legislation,
• Fulfilling the demands of competent authorities,
• Conducting the processes of finance and accounting transactions,
• Conducting communication activities,
• Conducting the processes of contracts,
• Carrying out strategic planning activities,
• Following up requests and complaints,

Push Notifications:

Codeway may occasionally send you push notifications via its mobile applications regarding application upgrades or notifications about our services. You can always edit such communication and notifications through the settings on your device and stop receiving such communications and notifications.

Your data will be stored for the duration specified in the applicable legislation or for a reasonable time until the purpose of processing cease to exist, or during legal periods of limitation.

Codeway may continue to store your personal data, even after the expiry of the purpose of its use provided that it is required by other laws or a separate granted by you in this regard.  

In cases that you allow Codeway to store your personal data for additional time by giving your consent, such data shall be immediately deleted, destructed or anonymized upon the expiry of such additional time or once the purpose of processing no longer exists.

4.  Transferring Personal Data to Third Parties

The procedures and principles to be applied for transferring of personal data are regulated in articles 8 and 9 of the PDP Law, and the personal and special categories of data of the supplier may be transferred to third parties within the country or abroad.

Your personal data may be transferred for the following reasons:

• Facilitating the delivery of our service,
• Using servers and cloud systems located abroad,
• Provision of this the service by Codeway,
• Performing service-related processes,
• Fulfilling the demands of competent authorities,
• Analyze on how our services are used

to services providers of our Company, third parties such as Facebook SDK, Adjust and Firebase Analytics which are embedded into our service, servers and cloud systems located abroad and competent authorities.

5.  Your Rights

Pursuant to Article 11 of the PDP Law, you request the following regarding your personal data by applying to Codeway:

• Learn whether or not your personal data have been processed;
• Whether or not your data have been processed;
• Learn the purpose of the processing of personal data and whether data are used in accordance with their purpose;
• Know the third parties in the country or abroad to whom your personal data have been transferred;
• In case the personal data is processed incompletely or inaccurately; requesting notification of the transactions made under this scope to third parties to whom personal data have been transferred;
• Request deletion, destruction or anonymization of personal data if the reasons for the processing have disappeared and request notification of the transactions made under this scope to third parties to whom personal data have been transferred;
• Object to occurrence of any result that is to your detriment by means of the analysis of personal data exclusively through automated systems;
• Request compensation for the damages in case the you incur damages due to unlawful processing of your personal data.

Our Company will enable you to file such requests through the “Data Subject Application Form” at support@codeway.co. In accordance with Article 13 of the PDP Law, our Company will finalize your requests, free of charge, within 30 (thirty) days at the latest depending on the nature of the request. In case the request is rejected, the reason or reasons for the rejection will be notified in writing or electronically along with its justification.

This Privacy Policy may be revised by our Company when deemed necessary. You can access the most up-to-date version of this Privacy Policy at https://codeway.co/

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