PRIVACY POLICY

Clarification Text on the Processing of Personal Data (“Clarification Text”) has been prepared for natural persons and legal entities with whom Vodafone Telekomünikasyon AŞ (“Vodafone”) is in cooperation, under the Law on Protection of Personal Data No. 6698 (“Law”).

Your personal data that you provide while participating in Vodafone's Guvenli Depo service will be processed in accordance with the Law and relevant legislation and this Clarification Text.

Identity of Data Controller

The expression "Vodafone" in the Clarification Text refers to the company established in Turkey and operating under the brand "Vodafone Telekomünikasyon AŞ". In terms of data processing activities within the scope of storage services, the data controller is Vodafone Telekomünikasyon A.Ş., located at Büyükdere Caddesi No: 251 Maslak, 34398, Sarıyer / İstanbul.(“Vodafone”)

Method of Obtaining Your Personal Data

Güvenli Depo | 4.5G | Servisler | Bireysel: Vodafone Türkiye: Personal data obtained through the use of data you have voluntarily processed in line with the information you have entered within the scope of the storage service you will benefit from in the field at Vodafone Turkey link, for the purposes stated below, in accordance with the basic principles stipulated in the Law; are collected with the use of the application.

Which Personal Data is Processed at Vodafone?

By Vodafone during the use of the application;

• Identity Information: This data category refers to name, surname, date of birth.

• Contact Information: This data category refers to data types such as GSM number, social media accounts, e-mail address, address.

• Subscription Information: This data category, customer number, package information and your information about the use of products and services; refers to the types of data consisting of your information about invoices, debts and payments.

• Usage Information: Actively used times, the date of the last login to the Service, errors and error information that occurred during the use of the Service, your preferences, habits and other usage information regarding the use of the Service, your behavior information in the Service and cookies.

• Device Information: Technical data collected from your device through technical equipment, information about the device, network, application, location data obtained through the Service

• Information in Sales Channels: This data category is the information you convey in sales processes; data obtained when communicating via electronic or physical means; your voice call recordings kept in accordance with call center standards; your voice recording to be used as a means of identity confirmation upon your request; refers to data types such as your demand and transaction information in sales channels.

•Audio and Audio Recordings: This category of data (i) photos and objects within photos, (ii) photos and videos on your device on users' phones or computers can be automatically uploaded to Guvenli Depo. Photos and videos uploaded to Guvenli Depo are only stored, not used or transferred to third parties.

• Contact List Information: This data category refers to data types such as name, surname, phone number belonging to third parties registered in the users' phone book. Your contact list information in your directory is uploaded to Guvenli Depo only for storage, it is not transferred to third parties and is not used within the service. The Guvenli Depo loads the contact list information only to create a backup copy of the contacts that can be restored later.

When you turn on contact backup and give Guvenli Depo access to your contact list, Guvenli Depo provides access to your phone book to read and write your contacts. In this case, the contact list information on your device will be uploaded to the Guvenli Depo server to be stored and allow you to restore the contacts list to your device.

Note: Your contact list information is uploaded to Guvenli Depo for safekeeping only. Guvenli Depo does not transfer, publish, or use your contact list information to third parties.

Guvenli Depo can also request access to your contact list when you select people to share a public link with. In this case, your contact list information will not be uploaded to the Guvenli Depo server, it will only be read and displayed on the screen.

For What Purposes and Under Which Data Processing Conditions Is Your Personal Data Processed?

Your personal data processing with these purposes:

a) It is expressly provided for by the laws.

b) It is necessary for the protection of life or physical integrity of the person himself/herself or of any other person, who is unable to explain his/her consent due to the physical disability or whose consent is not deemed legally valid.

c) Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract.

ç) It is necessary for compliance with a legal obligation to which the data controller is subject.

d) Personal data have been made public by the data subject himself/herself.

e) Data processing is necessary for the establishment, exercise or protection of any right.

f) Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.

g) Confirming your identity.

To Whom Can Your Personal Data Be Transferred?

Your personal data processed by our company,

• With the aim of ensuring the realization of the data transfer and processing conditions specified in Article 8 of the Law and the purposes listed above.

Provided that adequate and effective measures are taken, in accordance with the security and confidentiality principles set forth in the legislation,

• Authorized public institutions and organizations,

• Your authorized representatives (for example, your expressly authorized attorney, guardians for the disabled, etc.),

• Third parties we consult, including lawyers, tax consultants and auditors,

• Regulatory and supervisory institutions, authorized official authorities

can be transferred.

What Rights Do You Have Regarding Your Personal Data?

Regarding your personal data processed by Vodafone, in accordance with Article 11 of the Law;

a) to learn whether his/her personal data are processed or not,

b) to demand for information as to if his/her personal data have been processed,

c) to learn the purpose of the processing of his/her personal data and whether these personal

data are used in compliance with the purpose,

d) to know the third parties to whom his personal data are transferred in country or abroad,

e) to request the rectification of the incomplete or inaccurate data, if any,

f) to request the erasure or destruction of his/her personal data under the conditions referred to in Article 7,

g) to request reporting of the operations carried out pursuant to sub-paragraphs (d) and (e) to third parties to whom his/her personal data have been transferred,

h) to object to the occurrence of a result against the person himself/herself by analyzing the data processed solely through automated systems, 

i) to claim compensation for the damage arising from the unlawful processing of his/her personal data. 

Within the scope of these rights, your application to Vodafone is a document that you have prepared in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller;

1. Maslak Mah. Buyukdere Cad. No: 251 Maslak, 34398, Sarıyer / Istanbul (notary channel, registered mail, etc.) or

2. By sending it to Vodafone@hs03.kep.tr kep address with electronic signature or

3. You can do this by sending it to your e-mail address, kisiselverilerinkorunmasi@vodafone.com, provided that Vodafone has been previously notified and confirmed and registered in the relevant company systems.