PRIVACY POLICY AND INFORMATION NOTICE UNDER THE PERSONAL DATA PROTECTION LAW

This Privacy Policy and Information Notice explain the conditions and terms regarding the processing of personal data shared by or generated by users (“Data Subject”) while using the Sefona Mobile Application (“Mobile Application”) and the Sefona Website (“Website”), which are operated by Sefona Teknoloji A.Ş. (“Sefona”) located at Gülpınar Mahallesi Atapark Karşısı Sokak. No:1 Köyceğiz/Muğla, in compliance with the Personal Data Protection Law No. 6698 (“Law”) and relevant legislation.

All necessary security measures are taken to ensure the secure storage of user data and to protect it against unauthorized access.

This Privacy Policy and Information Notice explain the scope in which your personal data is processed while providing services through the Mobile Application and Website.

1. Data Controller

Your personal data is processed by Sefona as the data controller in compliance with applicable legislation and the methods specified below.

2. Methods of Collecting Personal Data and Legal Grounds for Processing

2.1. All information collected within the scope of the commercial activities carried out by Sefona is processed to conduct Sefona’s operations lawfully. Personal and sensitive personal data obtained within the scope of these activities are collected orally, in writing, and electronically. Your personal data is collected by Sefona either automatically or manually as part of a data recording system through the Mobile Application and Website based on contract formation or execution, legitimate interest, legal obligations, establishment, exercise, or protection of a right, and activities requiring explicit consent.

2.2. Unless explicitly stated otherwise, the term “personal data” in this Privacy Policy includes the following information:

  • Identity and Contact Information: Name, surname, phone number, email address
  • User Information, User Transaction Information: Membership details, membership ID, service usage dates and times, communication details with the Mobile Application, Website, or Support Line, Member Business Preferences, transactions made at Member Businesses, participation in campaigns, points earned and spent, errors occurring during use
  • Transaction Security Information: Login credentials, password information, user activities
  • Location Data (if explicit consent is given): Location data collected for security during transactions at Member Businesses
  • Marketing Information: Reports and analyses showing preferences, targeting information, cookie records, etc.
  • Request/Complaint Management Information: Requests and complaints made through the Mobile Application, Website, and support channels
  • Risk Management Information: IP address, device information

2.3. Data that has been anonymized under Articles 3 and 7 of the Law will not be considered personal data and may be processed without being subject to this Privacy Policy.

2.4. Personal data processing conditions specified in Articles 5 and 6 of the Law are detailed below regarding the purposes of processing personal data.

3. Transfer of Your Personal Data to Third Parties

Your personal data shared with Sefona is accessed only by our employees with limited authorization to fulfill their duties.

Additionally, your personal data may be transferred to third parties within Turkey and abroad under Articles 8 and 9 of the Law, subject to explicit consent where required. These third parties include:

  • Existing and future Member Businesses of the Mobile Application, domestic service providers (e.g., call centers, IT infrastructure providers), consultants, legal advisors, group companies, subcontractors, program-service partners, public authorities, and exceptional private entities
  • Potential buyers, sellers, and other transaction parties in case of a company merger, acquisition, joint venture, or other structural changes
  • Legally authorized institutions and private entities to fulfill legal obligations

4. Ensuring Data Security

Your membership information and other personal data cannot be shared with third parties unlawfully, and both you and Sefona are responsible for ensuring their security under applicable law. Sefona undertakes to:

  • Prevent unlawful processing of personal data,
  • Prevent unauthorized access to personal data, and
  • Ensure the secure storage of personal data by taking necessary technical and administrative measures.

5. Changes to the Privacy Policy

This Privacy Policy may be updated from time to time to comply with changing conditions and legislation.

6. Retention Period of Your Personal Data

Sefona retains the personal data provided during the use of the Mobile Application for up to 5 years after membership termination. Personal data storage periods are determined based on the continuity of the services provided. Once the retention period expires, your personal data will be deleted, destroyed, or anonymized upon request.

7. Your Rights Under the PDPL

As a personal data owner, you have the following rights under Article 11 of the Law:

  • To learn whether your personal data is processed,
  • To request information regarding the processing of your personal data,
  • To learn the purpose of processing and whether data is used for its intended purpose,
  • To know the third parties to whom your personal data is transferred domestically or abroad,
  • To request correction of incomplete or incorrect data and notification to third parties if applicable,
  • To request deletion or destruction of personal data when the purpose of processing no longer exists and notification to third parties if applicable,
  • To object to decisions made solely through automated systems,
  • To claim compensation for damages arising from unlawful processing.

8. Cookie Policy

During the use of the Sefona Mobile Application, cookies may be used to improve services and ensure quality without harming your fundamental rights and freedoms. For more information, you can review Sefona’s cookie policy at https://sefona.com.tr/cerez-politikasi. By accepting the Individual User Agreement and this Privacy Policy, you acknowledge and accept the use of cookies on the Sefona Mobile Application.