PARİBU BİLETLEME TEKNOLOJİLERİ A.Ş. MEMBER PRIVACY NOTICE
Pursuant to Article 10, entitled "Disclosure Obligation of the Data Controller", of the Personal Data Protection Law No. 6698 ("Law"), published in the Official Gazette dated 7 April 2016 and numbered 29677, which aims at the protection of fundamental rights and freedoms of persons — in particular the privacy of private life — in the processing of personal data, and pursuant to the Communiqué on the Procedures and Principles to Be Complied with in the Fulfilment of the Disclosure Obligation, published in the Official Gazette dated 10 March 2018 and numbered 30356, we, as Paribu Biletleme Teknolojileri A.Ş. ("Paribu Biletleme" or the "Company"), process certain of your personal data within the scope of your becoming our customer by completing all required membership processes in compliance with legal regulations. This privacy notice has been prepared with the aim of providing information about how we, as the data controller, process the personal data set out below.
For detailed information on how we protect personal data and the rules with which we comply when processing personal data, you may also review the Personal Data Processing, Protection, Retention and Destruction Policy on our website at pass.paribu.com.
A-) What Personal Data Is Processed?
Within the scope of your relationship with Paribu Biletleme, the following personal data is processed:
Identity Information: Name and surname, Turkish ID number, gender.
Contact Information: Telephone number, email, province, district and full address of residence.
Customer Transaction Data: Information regarding the transactions you have carried out via the Paribu Biletleme website and application, including support centre records, receipt information, request/complaint information, and assessment information.
Visual and Audio Data: Photograph, voice recordings of conversations with the call centre.
Transaction Security Data: IP address, hardware model, device operating system and version, device type, device ID, customer transaction records, website access logs and log records.
Financial Data: Information on the payments you have made and the payment methods used, and information regarding the payment transaction such as expenditure amount, expenditure date and time, transaction number.
Legal Action Information: Correspondence with judicial authorities, information regarding case/enforcement files in the event of a dispute.
Other Personal Data: Location information (location data of where you are, depending on your preference); company name, company address, tax office and tax number, in the event that you request a corporate invoice.
B-) Purposes of Processing Personal Data
Your personal data is processed on the basis of the legal grounds of the processing of personal data of the parties to a contract being necessary, provided that it is directly related to the establishment or performance of the contract and the processing of data being mandatory for the establishment, exercise or protection of a right for the following purposes:
Completion of membership procedures,
Verification of contact information,
The provision by Paribu Biletleme, via the website pass.paribu.com and the "Paribu Pass" mobile application, of services for the sale and distribution of tickets for any kind of cultural, artistic and sporting organisation, including but not limited to performing arts, concerts, entertainment and show activities, educational events, competitions, races, performances, cinema, theatre, opera, workshops, exhibitions and show activities,
Carrying out by the customer of payments related to the sale and distribution services provided by Paribu Biletleme,
Providing you with support within the scope of your password creation, renewal or update request,
Conducting process tracking regarding the provision of necessary procedures in the event that you cannot access your membership account for any reason,
Contacting you in respect of your membership account, your requests/complaints and other similar matters,
Closure of the membership account where requested by our customers,
Keeping your identity and contact information up to date.
Your personal data is processed on the basis of the legal ground of the processing of data being mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject for the following purposes:
Prevention, detection and resolution of issues, errors and unauthorised/malicious access attempts on our website,
Receiving and finalising your questions, suggestions, requests and complaints,
Conducting financial and accounting operations relating to payments,
Reviewing and auditing your payment transactions,
Contacting our customers, where necessary, in respect of their membership accounts and the transactions they carry out,
Reviewing and auditing our business activities,
Conducting work to develop/improve our processes and your experience within the scope of your suggestions and assessments,
Measuring customer satisfaction and conducting survey activities,
Carrying out the necessary infrastructure work to enable the services and transactions provided by Paribu Biletleme to be carried out quickly and accurately,
Ensuring the security of the website for the purpose of preventing unauthorised and malicious activities,
Conducting information technology and information security activities,
Ensuring legal and commercial security.
Your personal data is processed on the basis of the legal ground of being expressly provided for by law for the following purposes:
The provision, under the Law No. 6502 on the Protection of the Consumer, the Distance Contracts Regulation and other relevant legislation, of services for the sale and distribution to our customers — via the website pass.paribu.com and the "Paribu Pass" mobile application — of tickets for any kind of cultural, artistic and sporting organisation, including but not limited to performing arts, concerts, entertainment and show activities, educational events, competitions, races, performances, cinema, theatre, opera, workshops, exhibitions and show activities,
Conducting all necessary activities within the scope of carrying out electronic commerce under the Law No. 6563 on the Regulation of Electronic Commerce, the Regulation on Electronic Commerce Intermediary Service Providers and Electronic Commerce Service Providers, and other relevant legislation,
Fulfilment of our obligations under the Turkish Commercial Code No. 6102, the Turkish Code of Obligations No. 6098, the tax legislation and other relevant legislation to which we are subject within the scope of the activities we carry out.
Your personal data is processed on the basis of the legal ground of being mandatory for the data controller to fulfil its legal obligation for the following purposes:
Fulfilment of information and document requests from authorised institutions and organisations, or, in cases where we are required to make notifications to such institutions and organisations, the notification processes within the framework of our legal obligations,
Maintenance and storage of case files, notices and the conduct of legal affairs, management of enforcement proceedings and contract processes,
Protection and exercise of our rights in the event of a possible legal dispute, and the conduct of legal processes.
Your personal data is processed on the basis of the legal ground of the existence of explicit consent for the following purposes:
Establishing communication for the purpose of sending commercial electronic messages to our customers,
Enabling participation in campaigns and events specially organised for Paribu Biletleme customers,
Benefitting from gifts and benefits prepared for Paribu Biletleme customers.
C-) Transfer of Processed Personal Data
Your personal data may be shared by Paribu Biletleme with authorised official institutions and organisations, service provider companies, our business partners, our suppliers and the group of companies of which Paribu Biletleme is a member, in order to achieve the purposes set out above, within the scope of the data processing conditions regulated in Article 5 of the Law and in compliance with the rules on the transfer of personal data set out in the Law.
D-) Methods of Collection of Personal Data and Legal Bases
Within the scope of your relationship with Paribu Biletleme, your personal data is collected, in line with the transactions you carry out via our website, mobile application and customer support line, verbally, in writing or electronically, by wholly or partly automated means or by non-automated means as part of any data filing system. Your personal data may, in accordance with the Law No. 6563 on the Regulation of Electronic Commerce, the Regulation on Electronic Commerce Intermediary Service Providers and Electronic Commerce Service Providers, the Law No. 6502 on the Protection of the Consumer, the Distance Contracts Regulation and other relevant legislation to which we are subject, also be obtained from outside Paribu Biletleme through various methods, including from the databases of authorised institutions and organisations where legally required, at the moment your legal relationship with our Company is established and/or during the continuation of this relationship, through all contracts/information forms and other documents arranged with your approval and/or signature in respect of the transactions.
Your personal data is processed on the basis of the legal grounds set out in Article 5 of the Law: "the establishment or performance of a contract", "the processing of data being mandatory for the legitimate interests of the data controller", "the establishment, exercise or protection of a right", "being expressly provided for by law", "the fulfilment of the legal obligations of the data controller", and "the existence of explicit consent".
E-) Your Rights Regarding Your Personal Data
Within the scope of Article 11 of the Law, "regulating the rights of the data subject", you have the following rights regarding your personal data:
To learn whether personal data is processed,
To request information regarding personal data if it has been processed,
To learn the purpose of processing of personal data and whether they are used in line with their purpose,
To know the third parties to whom personal data is transferred domestically or abroad,
To request the correction of personal data in the event that they have been processed incompletely or incorrectly,
To request the deletion or destruction of personal data,
To request that operations carried out within the scope of correction, deletion or destruction of personal data be notified to the third parties to whom the personal data has been transferred,
To object to the emergence of a result against the data subject as a result of the analysis of processed data exclusively through automated systems,
To request compensation for damages in the event of suffering damage due to personal data being processed contrary to the law.
To exercise your rights within the scope of this article, please choose one of the following methods, in accordance with the Communiqué on the Procedures and Principles for Application to the Data Controller, and send it to us;
By submitting a petition or by sending it via notary post to the address: Huzur Mahallesi Maslak Ayazağa Caddesi Uniq İstanbul Sitesi B Blok No: 4B Sarıyer/İstanbul,
By sending an email to [email protected] using your email address registered in our systems,
By sending it to [email protected] via Registered Electronic Mail (KEP),
You may also choose one of the methods set out in the Communiqué on the Procedures and Principles for Application to the Data Controller.
In-person applications to be made within this scope will be accepted following the identity verification to be carried out by us; your requests will be finalised as soon as possible and at the latest within 30 days, depending on their nature.
This Privacy Notice may be updated in order to adapt to changing conditions and legal regulations. Updates made by our Company will be notified to you, our customers.
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Paribu Kripto Varlık Alım Satım Platformu A.Ş. Member Information Notice
Pursuant to Article 10, entitled "Disclosure Obligation of the Data Controller", of the Personal Data Protection Law No. 6698 ("Law"), published in the Official Gazette dated 7 April 2016 and numbered 29677, which aims at the protection of fundamental rights and freedoms of persons — in particular the privacy of private life — in the processing of personal data, and pursuant to the Communiqué on the Procedures and Principles to Be Complied with in the Fulfilment of the Disclosure Obligation, published in the Official Gazette dated 10 March 2018 and numbered 30356, we, as Paribu Kripto Varlık Alım Satım Platformu A.Ş. ("Paribu" or the "Company"), process certain of your personal data within the scope of your becoming our customer by completing all required membership processes, including identity verification, in compliance with legal regulations. This privacy notice has been prepared with the aim of providing information about how we, as the data controller, process the personal data set out below.
For detailed information on how we protect personal data and the rules with which we comply when processing personal data, you may also review the Personal Data Processing, Protection, Retention and Destruction Policy on our website at www.paribu.com.
A-) What Personal Data Is Processed?
Within the scope of your relationship with Paribu, the following personal data is processed:
Identity Information: Name and surname, date of birth, place of birth, Turkish ID number or Foreign ID number, ID card number and ID card serial number (if you use the old-type identity card), copies of the front and back of the Turkish ID card or Foreign ID card, nationality information, mother's name, father's name, civil registry sample (where required).
Contact Information: Telephone number, email, province, district and full address of residence, residence certificate.
Customer Transaction Data: Information regarding the transactions you have carried out via the Paribu website and application, including support centre records, receipt information, request/complaint information, lost/stolen and notice reports, buy/sell orders/transactions, and assessment information.
Visual and Audio Data: Photograph, recording of the meeting held with the customer during a video call, voice recordings of conversations with the call centre.
Transaction Security Data: IP address, hardware model, device operating system and version, device type, device ID, customer transaction records, website access logs and log records.
Bank Account Data: Bank information, IBAN, bank customer number.
Legal Action Information: Correspondence with judicial authorities, information regarding case/enforcement files in the event of a dispute, signature.
Biometric Data: Facial recognition information (identification data used during the remote identification/video call process to verify that the customer is the same person as the biometric photograph on the Turkish ID card or Foreign ID card), biometric photograph on the Turkish ID card or Foreign ID card.
Other Personal Data: Occupation information, your average monthly income, your main source of income, location information (location data of where you are).
B-) Purposes of Processing Personal Data
The personal data obtained within the scope of your relationship with Paribu is processed for the following purposes:
Your personal data is processed on the basis of the legal grounds of the processing of personal data of the parties to a contract being necessary, provided that it is directly related to the establishment or performance of the contract and the processing of data being mandatory for the establishment, exercise or protection of a right for the following purposes:
Completion of membership procedures,
Verification of contact information,
Verification of your identity information for the purpose of completing customer account creation procedures,
Enabling your crypto asset buy/sell transactions to be carried out after customer account creation procedures have been completed,
Conducting processes for raising account limits and defining commission rates,
Receiving your buy/sell orders and fulfilling the orders you submit within this scope,
Carrying out transfer transactions to the Paribu wallet,
Transferring crypto assets, where requested by our customers, to wallet addresses outside the Paribu platform or to different Paribu customers within Paribu,
Providing you with support within the scope of your password creation, renewal or update request,
Conducting process tracking regarding the provision of necessary procedures in the event that you cannot access your account for any reason,
Contacting you in respect of your customer account, portfolio and other similar matters,
Closure of the customer account where requested by our customers,
Keeping your identity and contact information up to date.
Your personal data is processed on the basis of the legal ground of the processing of data being mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject for the following purposes:
Prevention, detection and resolution of issues, errors and unauthorised/malicious access attempts on our website,
Receiving and finalising your questions, suggestions, requests and complaints,
Conducting financial and accounting operations relating to payments,
Reviewing and auditing your payment transactions,
Contacting our customers in respect of their accounts and the transactions they carry out,
Reviewing and auditing our business activities,
Conducting work to develop/improve our processes and your experience within the scope of your suggestions and assessments,
Contacting our customers in respect of their accounts and the transactions they carry out,
Reviewing and auditing our in-house business activities,
Measuring customer satisfaction and conducting survey activities,
Carrying out the necessary infrastructure work to enable the services and transactions provided by Paribu to be carried out quickly and accurately,
Ensuring the security of the website for the purpose of preventing unauthorised and malicious activities,
Conducting information technology and information security activities,
Ensuring legal and commercial security.
Your personal data is processed on the basis of the legal ground of being expressly provided for by law for the following purposes:
Verification of your identity information for the purpose of completing customer account creation procedures,
Fulfilment of our obligations regarding the determination of customer identity information and suspicious transaction reporting under Law No. 5549 on the Prevention of Laundering of Proceeds of Crime and other relevant legislation,
Carrying out customer identity verification procedures by means of remote identification under Law No. 5549 on the Prevention of Laundering of Proceeds of Crime, the Regulation on Measures Regarding the Prevention of Laundering of Proceeds of Crime and the Financing of Terrorism, the Regulation on the Compliance Programme Regarding the Obligations Concerning the Prevention of Laundering of Proceeds of Crime and the Financing of Terrorism, and other relevant legislation to which we are subject,
Taking and applying the relevant measures for the purpose of preventing fraud and the laundering of proceeds derived from crime within the scope of crime prevention.
Your personal data is processed on the basis of the legal ground of being mandatory for the data controller to fulfil its legal obligation for the following purposes:
Fulfilment of information and document requests from authorised institutions and organisations, or, in cases where we are required to make notifications to such institutions and organisations, the notification processes within the framework of our legal obligations,
Maintenance and storage of case files, notices and the conduct of legal affairs, management of enforcement proceedings and contract processes,
Protection and exercise of our rights in the event of a possible legal dispute, and the conduct of legal processes.
Your personal data is processed on the basis of the legal ground of the existence of explicit consent for the following purposes:
Establishing communication for the purpose of sending commercial electronic messages to our customers,
Enabling participation in campaigns and events specially organised for Paribu customers,
Benefitting from gifts and benefits prepared for Paribu customers.
C-) Transfer of Processed Personal Data
Your personal data may be shared by Paribu with authorised official institutions and organisations, service provider companies, our business partners and our group companies, in order to achieve the purposes set out above, within the scope of the data processing conditions regulated in Article 5 of the Law and in compliance with the rules on the transfer of personal data set out in the Law.
D-) Methods of Collection of Personal Data and Legal Bases
Within the scope of your relationship with Paribu, your personal data is collected, in line with the transactions you carry out via our website, mobile application and customer support telephone line, verbally, in writing or electronically, by wholly or partly automated means or by non-automated means as part of any data filing system. Your personal data is, in accordance with the Capital Markets Law No. 6362, the Law No. 5549 on the Prevention of Laundering of Proceeds of Crime, the Regulation on Measures Regarding the Prevention of Laundering of Proceeds of Crime and the Financing of Terrorism, the Regulation on the Compliance Programme Regarding the Obligations Concerning the Prevention of Laundering of Proceeds of Crime and the Financing of Terrorism, and other relevant legislation to which we are subject, also obtained from outside Paribu through various methods, including from databases of authorised institutions and organisations (Identity Sharing System, the Directorate of Population and Citizenship Affairs, etc.), where legally required, at the moment your legal relationship with our Company is established and/or during the continuation of this relationship, through all contracts/information forms and other documents arranged with your approval and/or signature in respect of the transactions.
Your personal data is processed on the basis of the legal grounds set out in Article 5 of the Law: "the establishment or performance of a contract", "the processing of data being mandatory for the legitimate interests of the data controller", "the establishment, exercise or protection of a right", "being expressly provided for by law", "the fulfilment of the legal obligations of the data controller", and "the existence of explicit consent".
E-) Your Rights Regarding Your Personal Data
Within the scope of Article 11 of the Law, "regulating the rights of the data subject", you have the following rights regarding your personal data:
To learn whether personal data is processed,
To request information regarding personal data if it has been processed,
To learn the purpose of processing of personal data and whether they are used in line with their purpose,
To know the third parties to whom personal data is transferred domestically or abroad,
To request the correction of personal data in the event that they have been processed incompletely or incorrectly,
To request the deletion or destruction of personal data,
To request that operations carried out within the scope of correction, deletion or destruction of personal data be notified to the third parties to whom the personal data has been transferred,
To object to the emergence of a result against the data subject as a result of the analysis of processed data exclusively through automated systems,
To request compensation for damages in the event of suffering damage due to personal data being processed contrary to the law.
To exercise your rights within the scope of this article, please choose one of the following methods, fill in the Application Form Regarding Personal Data on our website at www.paribu.com, and, in accordance with the Communiqué on the Procedures and Principles for Application to the Data Controller, send it to us;
By submitting a petition or by sending it via notary post to the address: Huzur Mahallesi Maslak Ayazağa Caddesi Uniq İstanbul Sitesi B Blok No: 4B Sarıyer/İstanbul,
By sending an email to [email protected] using your email address registered in our systems,
By sending it to [email protected] via Registered Electronic Mail (KEP),
You may also choose one of the methods set out in the Communiqué on the Procedures and Principles for Application to the Data Controller.
In-person applications to be made within this scope will be accepted following the identity verification to be carried out by us; your requests will be finalised as soon as possible and at the latest within 30 days, depending on their nature.
This Privacy Notice may be updated in order to adapt to changing conditions and legal regulations. Updates made by our Company will be notified to you, our customers.
Author:
Paribu
