FOOTBOND PRIVACY POLICY

Pursuant to Article 10 of the Personal Data Protection Law no. 6698 (“Law“), with this FootBond Privacy Policy (“Privacy Policy“), we, Footbond Oyun ve Teknoloji Hizmetleri Anonim Şirketi (“We” or “FootBond“), process your personal data as a data controller within the scope of your (“User”) membership of the FootBond mobile application (“Platform“). We would like to inform you about our identity, the purposes of processing your personal data, to whom and for what purpose we transfer your personal data, our legal reasons, our processing methods and your rights regarding the processing of personal data.

Data Controller

Footbond Oyun ve Teknoloji Hizmetleri Anonim Şirketi with 1018451 registration number, established at Acıbadem Mah. Çeçen Sk. A Blok No: 25 A İç Kapı no: 150 Üsküdar/İstanbul Türkiye.

Your personal data is processed in compliance with the following principles laid out in Article 4 of the PDPL:

Lawfulness and fairness,
Being accurate and kept up to date where necessary,
Being processed for specified, explicit and legitimate purposes,
Being relevant, limited and proportionate to the purposes for which they are processed.

Detailed Information Regarding the Processing of Your Personal Data

Data Category	Data Type	Processing Purpose	Legal Reason for Processing	Collection Method	Storage Period	Transfer Purposes and Parties
Identity	Name Surname	Execution of Goods / Service Sales Processes, Execution of Communication Activities	It is necessary for us to process your personal data for the establishment and execution of the User Agreement	By filling out the membership form (Automatic)	10 Years	Execution of e-mail sending processes, Storage and archive activities (Supplier) Informing authorised persons, institutions and organisations (Authorised Person, Public, Institutions and Organisations)
Contact	E-Mail Address	Execution of Goods / Service Sales Processes, Execution of Communication Activities	It is necessary for us to process your personal data for the establishment and execution of the User Agreement	By filling out the membership form (Automatic)	10 Years	Execution of e-mail sending processes, Storage and archive activities (Supplier) Informing authorised persons, institutions and organisations (Authorised Person, Public, Institutions and Organisations)
Contact	Mobile Phone Number	Execution of Goods / Service Sales Processes, Execution of Communication Activities	It is necessary for us to process your personal data for the establishment and execution of the User Agreement	By filling out the membership form (Automatic)	10 Years	Storage and archive activities (Supplier) Informing authorised persons, institutions and organisations (Authorised Person, Public, Institutions and Organisations)
Member Transaction	Member Nickname	Execution of Goods / Service Sales Processes	It is necessary for us to process your personal data for the establishment and execution of the User Agreement	By filling out the membership form (Automatic)	10 Years	Storage and archive activities (Supplier) Informing authorised persons, institutions and organisations (Authorised Person, Public, Institutions and Organisations)
Member Transaction	Member Information Regarding Platform Usage	Execution of Goods / Service Sales Processes	It is necessary for us to process your personal data for the establishment and execution of the User Agreement	By using the Platform (Automatic)	10 Years	Storage and archive activities (Supplier) Informing authorised institutions and organisations (Authorised Person, Public, Institutions and Organisations)
Process Security	Access Records	Execution of Activities in Accordance with the Legislation	It is clearly foreseen pursuant to subparagraph (b) of paragraph 1 of Article 6 of Law No. 5651	By using the Platform (Automatic)	6 Months – 2 Years	Storage and archive activities (Supplier) Informing authorised institutions and organisations (Authorised Person, Public, Institutions and Organisations)

* To conduct Our Storage and Archiving Activities, all data types included in this Privacy Notice are transferred to Google Cloud Services and IBM Cloud services for server and infrastructure services located outside of Türkiye. This data transfer is due to the fact that the servers are located within the relevant company in order to meet the need to host the data types we process on a server, and does not require an active data transfer and is realized due to the nature of the hosting service.

Third Party Access

Only aggregated, anonymised data is periodically transmitted to external services to aid the Service Provider in improving the Application and their service. The Service Provider may share your information with third parties in the ways that are described in this privacy statement.

Please note that the Application utilises third-party services that have their own Privacy Policy about handling data. Below are the links to the Privacy Policy of the third-party service providers used by the Application:

The Service Provider may disclose User Provided and Automatically Collected Information:

as required by law, such as to comply with a subpoena, or similar legal process;
when they believe in good faith that disclosure is necessary to protect their rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
with their trusted services providers who work on their behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.

Your Rights Regarding Your Personal Data

Pursuant to Article 11 of the Law, you have the following rights regarding your personal data:

Your Personal Data:

– whether or not it was committed,

– whether it is used in accordance with the purpose and purpose of processing,

– on the transfer into or out of the country

– to be processed in accordance with its purpose,

– to be corrected if incorrect or incomplete and to inform third parties,

– destroyed and third parties notified if the relevant reasons no longer exist; and

– to compensate you for the damages you have suffered

– the results against you due to analyses made by automated systems

Information Request

Requesting

Objection

Your Rights and Choices Under the EU GDPR & UK GDPR

Footbond undertakes to respect the confidentiality of your Personal Data and to guarantee Users can exercise their rights.

Users have the right under this Privacy Policy, and by law if they are within the UK or EU, to:

– Right of Access: Users have the right to obtain confirmation from us as to whether or not Personal Data concerning Users are processed, and, where that is the case, Users have the right to request and get access to such Personal Data.

– Right to Rectification: Users have the right to request rectification by us of inaccurate Personal Data and Users have the right to provide additional Personal Data to complete any incomplete Personal Data.

– Right to Erasure (“Right to be Forgotten”): In certain cases, Users have the right to request from us the erasure of their Personal Data.

– Right to Restriction of Processing: Users have the right to request from us restriction of processing, for a certain period and/or for certain situations.

– Right to Data Portability: Users have the right to receive their Personal Data from us in a structured format and Users have the right to (let) transmit such Personal Data to another controller.

– Right to Object: In certain cases, Users have the right to object to the processing of their Personal Data, including with regards to profiling. Users have the right to object to the further processing of their Personal Data in so far as such data has been collected for direct marketing purposes.

– Right to be Not Subject to Automated Individual Decision-Making: Users have the right to not be subject to a decision based solely on automated processing.

– Right to Filing Complaint: Users have the right to file complaints with the applicable data protection authority on our processing of their Personal Data.

– Right to Compensation of Damages: In case we breach applicable legislation on the processing of Users’ Personal Data, Users have the right to claim damages from us for any damages such breach may cause to Users.

Exercising of Your UK & EU GDPR Data Protection Rights

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. If you are a resident of United Kingdom, you may complain to Information Commissioner’s Office (ICO) regarding your data protection rights. If you are a resident in the European Economic Area (EEA), please contact your local data protection authority in the EEA. However, we would be appreciated to deal with your concerns before you apply to a Data Protection Authority.

You may exercise your rights of access, rectification, cancellation, and opposition by simply contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You can send us the declaration regarding your use of the above-mentioned rights, documents identifying your identity and the subject of the request through the following channels:

info@footbond.net via e-mail with or without secure electronic signature,
Acıbadem Mah. Çeçen Sk. A Blok No: 25 A İç Kapı no: 150 Üsküdar/İstanbul Türkiye by hand delivery or by sending notary or registered mail with return receipt.

We undertake to respond to your request as soon as possible, but not more than 30 (thirty) days, and without charge, unless the transaction is costly.