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Privacy

Privacy

We summarize how we collect and use your personal data in a transparent way.

 

PERSONAL DATA 

PROCESSING AND PROTECTION 

POLICY

  1. INTRODUCTION
    1. PURPOSE AND SCOPE

As J Labs Teknoloji Anonim Şirketi (“Company”) we attach the utmost importance to the protection of the personal data of all natural persons we come into contact with during our activities, including our customers, employees, visitors, and business partners, which constitutes a constitutional right. To this end, in accordance with the Personal Data Protection Law No. 6698 of Republic of Türkiye (“PDPL”) and, to the extent applicable, the EU General Data Protection Regulation (“GDPR”) and all other applicable legislation, we take all necessary technical and administrative measures to ensure full compliance, to prevent the unlawful processing of and access to personal data, and to ensure data security.

As the Company, through this Personal Data Processing and Protection Policy (“Policy”) we aim to inform you about the processing, transfer, and protection of personal data, our retention and disposal systems, and our fundamental principles. 

This Policy provides transparency with respect to the Company’s data processing activities but does not on its own cover all possible scenarios. In processes specific to a product or service, detailed information is provided through disclosure texts presented before or at the time of data collection; where necessary, your explicit consent is separately obtained. Accordingly, more comprehensive information regarding the processing of your personal data may be accessed through the relevant disclosure texts.

This Policy covers all physical and electronic data recording systems and environments used for the processing of personal data and special categories of personal data by automated means or by non-automated means provided they form part of a data recording system. The website operated by the Company (“Website”) and all related online/digital platforms are also within the scope of this Policy. Third-party websites, platforms, or mobile applications not managed by the Company are outside the scope of this Policy. Processing activities relating to your personal data on such third-party platforms are subject to the policies and terms of use of the relevant service provider.

  1. DEFINITIONS

Explicit Consent:

Consent that is given on a specific subject, based on information, and expressed with free will.

Constitution: 

The Constitution of the Republic of Türkiye numbered 2709.

Data Subject: 

The natural person whose personal data is processed.

Disposal: 

The deletion or destruction of personal data.

J Labs: 

J Labs Teknoloji Anonim Şirketi.

Personal Data:

Any information relating to an identified or identifiable natural person.

Personal Data Processing Inventory:

The inventory that data controllers prepare by associating their personal data processing activities carried out in connection with their business processes with the purposes of processing personal data, the data category, the recipient group to which data is transferred, and the group of persons subject to data, and in which they detail the maximum period required for the purposes for which personal data is processed, the personal data envisaged to be transferred to foreign countries, and the measures taken in relation to data security.

Anonymization of Personal Data:

The anonymization of personal data means rendering personal data incapable of being associated in any way with an identified or identifiable natural person, even when matched with other data.

Disposal of Personal Data:

The process of deleting, anonymizing, or destroying personal data.

Deletion of Personal Data:

The process of making personal data inaccessible and unusable in any way for the relevant users.

Destruction of Personal Data:

The destruction of personal data means making personal data inaccessible, irrecoverable, and unusable in any way by anyone.

DPA Board:

The Personal Data Protection Board.

PDPL: 

The Personal Data Protection Law No. 6698.

Special Categories of Personal Data:

Data relating to a person’s race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, membership of an association, foundation or trade union, health, sexual life, criminal conviction and security measures, as well as biometric and genetic data.

Periodic Disposal: 

The process of deletion, destruction, or anonymization carried out ex officio at recurring intervals specified in the retention and disposal policy, in the event that all conditions for the processing of personal data set forth in the PDPL cease to exist.

Policy: 

The Personal Data Processing and Protection Policy.

Data Processor: 

A natural or legal person that processes personal data on behalf of the data controller based on the authority granted by the data controller.

Data Recording System:

A recording system in which personal data is structured and processed according to specific criteria.

Data Controller: 

A natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.

 
  1. GENERAL PRINCIPLES REGARDING THE PROCESSING OF PERSONAL DATA 

In accordance with Article 20 of the Constitution and Article 4 of the PDPL, the Company processes personal data in compliance with the law and principles of good faith; accurately and, where necessary, up to date; for specific, explicit, and legitimate purposes; and in a manner that is connected with, limited to, and proportionate to the purpose. In this context, pursuant to Article 5 of the PDPL, the Company processes personal data based on one or more of the conditions set forth in Article 5 of the PDPL, and retains personal data for as long as stipulated by law and/or required by the purpose of processing. Furthermore, the Company acts in compliance with the provisions stipulated under Article 6 of the PDPL regarding the processing of special categories of personal data; acts in accordance with Articles 8 and 9 of the PDPL regarding the transfer of personal data, complying with the regulations stipulated in the law and set out by the DPA Board; and, in accordance with Article 10 of the PDPL, informs the Data Subject and provides the necessary information upon request by the Data Subject.

Your personal data is processed by the Company in accordance with the personal data processing principles set forth in Article 4 of the PDPL. Compliance with these principles is mandatory for each personal data processing activity.

Processing of personal data in compliance with the law and principles of good faith: In the processing of your personal data, we act in accordance with laws, secondary regulations, and general principles of law; and we attach importance to ensuring that personal data is processed only to the extent necessary for the purpose of processing.

Accuracy and currency of personal data: Attention is paid to whether your processed personal data is up to date and to carrying out the relevant checks. In this context, the Data Subject is granted the right to request the correction or deletion of inaccurate or outdated data.

Processing of personal data for specific, explicit, and legitimate purposes: Prior to each personal data processing activity, the purposes of data processing are determined and compliance with the lawfulness of these purposes is observed.

Personal data being connected with, limited to, and proportionate to the purpose for which it is processed: Personal data required to fulfill the collection purpose is limited, and the necessary technical and administrative measures are taken to prevent the processing of personal data not related to this purpose.

Retention of personal data for as long as required by legislation or the purposes of processing: After the purpose of personal data processing ceases or following the expiration of the period stipulated in the legislation, personal data is deleted, destroyed, or anonymized.

  1. CONDITIONS FOR THE PROCESSING OF PERSONAL DATA

Your personal data is processed by the Company where at least one of the personal data processing conditions set forth in Article 5 of the PDPL exists. These conditions are as follows:

Existence of Explicit Consent of the Data Subject: The personal data of the Data Subject may be processed where the Data Subject gives consent with free will, having sufficient knowledge about the personal data processing activity, in a clear and unambiguous manner, and limited solely to that specific processing.

Being expressly stipulated by law: Personal data may be processed without the explicit consent of the Data Subject, within the framework of the relevant legal regulation, where it is expressly stipulated by law.

Inability to obtain the explicit consent of the Data Subject due to actual impossibility and the processing being mandatory: Personal data belonging to a Data Subject who is unable to give consent or whose consent cannot be considered valid may be processed without seeking explicit consent, where the processing is mandatory to protect the life or physical integrity of the Data Subject or a third party.

The personal data processing activity being directly related to the establishment or performance of a contract: If the processing of personal data belonging to the parties to a contract established or already concluded between the Data Subject and the Company is necessary, the personal data processing activity may be carried out without seeking explicit consent.

The personal data processing activity being mandatory for the Data Controller to fulfill its legal obligation: Personal data may be processed without seeking explicit consent for the purpose of fulfilling legal obligations stipulated under applicable legislation.

The Data Subject having made their personal data public: Personal data that has been disclosed to the public by the Data Subject in any way and has become accessible to the general public as a result of such disclosure may be processed without seeking the explicit consent of the Data Subject, limited solely to the purpose of such disclosure.

Processing of personal data being mandatory for the establishment, exercise, or protection of a right: Where the processing of data is mandatory for the establishment, exercise, or protection of a right, it may be processed without seeking the explicit consent of the Data Subject.

Processing 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: Personal data may be processed provided that the balance of interests of the Data Subject is observed. In this context, when processing data based on legitimate interests, the legitimate interest the Company will obtain as a result of the processing activity is first determined. The potential impact of the processing of personal data on the rights and freedoms of the Data Subject is evaluated, and where it is concluded that the balance is not disrupted, the processing activity may be carried out without seeking explicit consent.

  1. CONDITIONS FOR THE PROCESSING OF SPECIAL CATEGORIES OF PERSONAL DATA

Special categories of personal data under Article 6 of the PDPL are listed on a closed-list basis. These are data relating to a person’s race, ethnic origin, political opinion, philosophical belief, religion, sect, or other beliefs, appearance and dress, membership of an association, foundation, or trade union, health, sexual life, criminal conviction and security measures, as well as biometric and genetic data.

The Company makes maximum effort to limit its contact with special categories of personal data, taking into account the sensitivity of company activities and personal data. 

The Company may process special categories of personal data by ensuring the additional measures determined by the DPA Board are taken, in the following circumstances:

Existence of Explicit Consent of the Data Subject: The special categories of personal data of the Data Subject may be processed where the Data Subject gives consent with free will, having sufficient knowledge about the special categories of personal data processing activity, in a clear and unambiguous manner, and limited solely to that specific processing.

Being expressly stipulated by law: Special categories of personal data may be processed without the explicit consent of the Data Subject, within the framework of the relevant legal regulation, where it is expressly stipulated by law.

Inability to obtain the explicit consent of the Data Subject due to actual impossibility and the processing being mandatory: Special categories of personal data belonging to a Data Subject who is unable to give consent or whose consent cannot be considered valid may be processed without seeking explicit consent, where the processing of special categories of personal data is mandatory to protect the life or physical integrity of the Data Subject or a third party.

Being related to personal data made public by the data subject and consistent with the intent of such disclosure: Special categories of personal data that have been disclosed to the public by the Data Subject in any way and have become accessible to the general public as a result of such disclosure may only be processed without seeking the explicit consent of the Data Subject, limited solely to the purpose of such disclosure.

Being mandatory for the establishment, exercise, or protection of a right: Where the processing of special categories of personal data is mandatory for the establishment, exercise, or protection of a right, it may be processed without seeking the explicit consent of the Data Subject.

Being necessary for the purposes of protecting public health, preventive medicine, medical diagnosis, the provision of treatment and care services, and the planning, management, and financing of health services: Special categories of personal data may be processed without seeking explicit consent only by persons bound by confidentiality obligations or by authorized institutions and organizations, where it is necessary for the purposes of protecting public health, preventive medicine, medical diagnosis, the provision of treatment and care services, and the planning, management, and financing of health services.

Being mandatory for fulfilling legal obligations in the fields of employment, occupational health and safety, social security, social services, and social assistance: Special categories of personal data may be processed without explicit consent where it is mandatory for fulfilling legal obligations in the fields of employment, occupational health and safety, social security, social services, and social assistance.

Processing of special categories of personal data relating to current or former members and affiliates of foundations, associations, and other non-profit organizations or entities established for political, philosophical, religious, or trade union purposes, or persons who are regularly in contact with such organizations and entities: Special categories of personal data relating to current or former members and affiliates of foundations, associations, or other non-profit organizations or entities established for political, philosophical, religious, or trade union purposes, or persons regularly in contact with such organizations and entities, may be processed without seeking explicit consent, provided that it is in compliance with the legislation and purposes to which they are subject, limited to their fields of activity, and not disclosed to third parties.

  1. OUR PURPOSES FOR PROCESSING YOUR PERSONAL DATA AND OUR COLLECTION METHOD

As the Company, we collect certain personal data during our interactions with our users, within the scope of the products and services offered through the Website. In this context, your data may be collected automatically when you visit our Website, create an account, make a payment, or submit a support request.

In addition, certain technical data is also obtained through cookies and similar technologies via the device, browser, or applications you use. Detailed information about cookies can be found in the Cookie Policy. 

The personal data we collect may include, depending on how you interact with the Company, information such as your full name, Turkish ID number, address, e-mail address, phone number, payment information, IP address, and device information. Depending on which of our products and services you request or use, or depending on your relationship with the Company, the personal data we collect may vary and some of this data may not be applicable to you. Additionally, the contents of questions, feedback, or information shared within the scope of customer service support directed to us, as well as the contents of messages you send to our Company, may also be recorded in our systems.

At the stage of creating your membership, you are given the opportunity to share with the Company your profile photo, full name, educational status, date of birth, occupation, Turkish ID number, city and country of residence, mobile operator, phone number, and address. The sharing of these specified pieces of information is entirely up to your choice and discretion. Preferring not to share such personal data will not constitute any obstacle to your access to the Company’s games. This information is used to create user database records, to manage the control of payment-related disputes, and to manage customer relations.

We request your personal data for the following purposes, without being limited thereto:

  • To carry out account creation and membership login processes,
  • To carry out purchase transactions and ensure the performance of the sales contract,
  • To optimize games and resolve technical issues,
  • To process payments, ensure collection security, and maintain the necessary financial records,
  • To create accounting records and fulfill our obligations arising from tax legislation,
  • To respond to your customer service and support requests, 
  • To measure the quality of our services through our website and digital channels, improve user experience, and ensure system security,
  • To perform statistical analyses regarding the use of our services through cookie data, measure performance, and resolve potential technical errors,
  • To provide you with information about personalized campaigns, discounts, promotions, and advertising activities, subject to your consent,
  • To conduct customer satisfaction surveys and evaluate your feedback in order to improve our service quality,
  • To fulfill information requests from official authorities, discharge our legal obligations, and protect our rights in potential dispute processes.

In cases where we process your personal data for purposes other than those specified above, we carry out these activities solely within the legal framework and in accordance with the relevant disclosure texts.

  1. CATEGORIES OF PERSONAL DATA PROCESSED BY THE COMPANY

In accordance with the PDPL and other relevant legislative provisions, the Company may process the Data Subject’s personal data in the categories of Identity, Contact, Finance, Legal Transaction, Personnel, Visual and Audio Records, Professional Experience, and Customer Transaction, within the framework of the purposes and conditions set forth in this Policy. You may find detailed information about the personal data processed about you in the disclosure text provided to you.

  1. TRANSFER OF PERSONAL DATA 

The Company may transfer the personal data and special categories of personal data of the Data Subject to third parties by taking the necessary security measures in line with lawful personal data processing purposes. In this regard, the Company acts in compliance with the regulations set forth in Articles 8 and 9 of the PDPL.

  1. Transfer of Personal Data

Even without the explicit consent of the Data Subject, personal data may be transferred to third parties by the Company with due care and all necessary security measures, where one or more of the following conditions exist:

  • The relevant activities relating to the transfer of personal data being expressly stipulated by law,
  • Being mandatory to protect the life or physical integrity of the person who is unable to give consent due to actual impossibility or whose consent is not legally valid, or of another person,
  • The transfer of personal data being directly related to the establishment or performance of a contract,
  • The transfer of personal data being mandatory for the fulfillment of a legal obligation,
  • The personal data having been made public by the Data Subject, provided that it is transferred in a manner limited to the purpose of such disclosure,
  • The transfer of personal data being mandatory for the establishment, exercise, or protection of the rights of the Company, the Data Subject, or third parties,
  • The personal data transfer activity being mandatory for the legitimate interests of the Company, provided that it does not harm the fundamental rights and freedoms of the Data Subject.

In addition to the above, personal data may only be transferred abroad where the following conditions exist:

  • To foreign countries declared by the DPA Board to have adequate protection, where any of the above conditions exists,
  • Where there is no adequacy decision, where any of the above conditions exists and the Data Subject has the ability to exercise their rights and apply to effective legal remedies in the country to which the transfer will be made, where one of the appropriate safeguards specified in the PDPL is provided by the parties,
  • Where there is no adequacy decision and none of the appropriate safeguards provided for in the PDPL can be ensured, exceptionally and only where one of the cases specified in Article 9(6) of the PDPL exists.
  1. Transfer of Special Categories of Personal Data

The Company makes maximum effort to limit its contact with special categories of personal data, taking into account the sensitivity of company activities and personal data. In the event of special categories of personal data processing, such data may be transferred by the Company in accordance with the principles set forth in this Policy and by taking all necessary technical and administrative measures, where the following conditions exist.

  • The explicit consent of the data subject exists,
  • The relevant activities relating to the transfer of special categories of personal data are expressly stipulated by law,
  • The transfer of special categories of personal data being mandatory to protect the life or physical integrity of the person who is unable to give consent due to actual impossibility or whose consent is not legally valid, or of another person,
  • The special categories of personal data having been made public by the Data Subject, provided that they are transferred in a manner limited to the purpose of such disclosure,
  • The transfer of special categories of personal data being mandatory for the establishment, exercise, or protection of the rights of the Company, the Data Subject, or third parties,
  • The transfer of special categories of personal data being necessary by persons bound by confidentiality obligations or by authorized institutions and organizations, for the purposes of protecting public health, preventive medicine, medical diagnosis, the provision of treatment and care services, and the planning, management, and financing of health services,
  • The transfer of special categories of personal data being mandatory for fulfilling legal obligations in the fields of employment, occupational health and safety, social security, social services, and social assistance,
  • Special categories of personal data relating to current or former members and affiliates of foundations, associations, and other non-profit organizations or entities established for political, philosophical, religious, or trade union purposes, or persons regularly in contact with such organizations and entities, being transferred in compliance with the legislation and purposes to which they are subject, limited to their fields of activity, and not disclosed to third parties,

In addition to the above, special categories of personal data may only be transferred abroad where the following conditions exist:

  • To foreign countries declared by the DPA Board to have adequate protection, where any of the above conditions exists,
  • Where there is no adequacy decision, where any of the above conditions exists and the Data Subject has the ability to exercise their rights and apply to effective legal remedies in the country to which the transfer will be made, where one of the appropriate safeguards specified in the PDPL is provided by the parties,
  • Where there is no adequacy decision and none of the appropriate safeguards provided for in the PDPL can be ensured, exceptionally and only where one of the cases specified in Article 9(6) of the PDPL exists.
  1. Sharing of Your Personal Data

During the provision of the products and services offered through our Website, certain processes are carried out by our authorized business partners or service providers. In such cases, your personal data may be shared with the following parties, solely to the extent required by the service:

  • Banks and/or Payment Service Providers: May be shared for the purposes of collecting payment in purchase transactions, carrying out collection processes, managing return and refund processes, preventing fraud, and ensuring payment security.
  • Service Providers and Advisors: May be shared with third-party business partners from whom services are received, such as audit firms, law firms, financial advisors, and suppliers providing technical support, for the purposes of conducting our Company activities in compliance with regulations, tracking legal processes, and ensuring operational efficiency.
  • Analytics and Database Providers: For the purposes of improving user experience and enhancing service quality, your search behaviors and in-site interactions may be processed statistically through analytics tools such as Google Analytics via cookies and similar analytics software.
  • Accounting, Financial Advisory, and Integration Systems: May be shared with authorized financial advisors, accounting software, or integration providers in the processes of invoicing, accounting records, tax returns, and fulfilling legal obligations.
  • Official Authorities and Judicial Bodies: Your personal data may be shared where duly requested by authorized public institutions, courts, or regulatory authorities, where required by law or for the purpose of fulfilling our legal obligations.
  • Mobile Applications: When you download, use, or make in-game purchases in the mobile games published by the Company, all of your purchase transactions or transactions related to downloading and use are carried out through the Apple App Store and Google Play app stores.
    • Even where explicit consent has been given for personalized advertisements, the Company and its suppliers process the actions you take within the application and your reactions to the advertisements shown to you anonymously.
    • The Company works with third-party suppliers for analytics, analysis, hosting, advertising, marketing, and similar services on its behalf. You can access the list of our third-party service providers and business partners and their respective privacy policies from the table below:

Amplitude

Privacy Policy

Applovin Max

Privacy Policy

AppsFlyer

Privacy Policy

Facebook

Privacy Policy

Firebase

Privacy Policy

Unity

Privacy Policy

 
  • The Company may only send notifications to the device through which you connect to the games, subject to your explicit consent. You may change the notification settings from your device at any time.

These parties process your personal data as data processors on behalf of our Company or as data controllers within the scope of their own legal obligations. All sharing is carried out within the framework of contractual security measures and technical-administrative measures.

The Company takes the necessary security measures in accordance with international standards to protect the confidentiality, integrity, and accessibility of personal data, and applies all necessary technical and administrative measures to prevent unauthorized access to, disclosure of, or loss of data.

The persons and organizations listed above represent some of the parties with whom data may be shared, and this list is not exhaustive. Depending on the nature of the transaction or service you carry out with the Company, you may always access detailed information about with whom and to what extent your personal data is shared, through the disclosure texts provided to you specific to the relevant process.

  1. MATTERS REGARDING THE PROTECTION OF PERSONAL DATA

In accordance with Article 12 of the PDPL, the Company takes the necessary technical and administrative measures to provide the appropriate level of security to prevent the unlawful processing of and access to the personal data it processes and to ensure the safeguarding of data, and within this scope carries out or has carried out the necessary audits.

In this context, the fundamental data protection principles adopted by the Company are set forth below. 

  • Only personal data that is mandatory for the provision of products and services or necessary to the extent required by the relevant transaction is collected and stored from our users.
  • Clear information is provided regarding who uses personal data and how. 
  • For the security of your personal data, up-to-date encryption technologies, access control mechanisms, and firewalls are used in our information systems; data is protected against the risks of unauthorized access, disclosure, or misuse.
  • Except for cases stipulated by legislation, your personal data is not shared with any natural or legal person without your explicit consent. However, when data sharing is required pursuant to court decisions, requests from authorized public institutions, or legal obligations, sharing is done solely within the scope of what is requested and in compliance with the relevant legislation.
  • Business partners and service providers from whom support services are received for the purpose of executing services are obligated to act in compliance with the Company’s policies and data security requirements.
  • The necessary technical security measures are taken on our information systems to prevent unauthorized access to personal data; the confidentiality and integrity of data is protected.
  • Access of Company employees to personal data is regulated in a manner limited to their duties and responsibilities.
  • All of our employees are informed about confidentiality obligations.
  • Agreements signed contain data security provisions.
  • The Company regularly reviews and continuously improves its information security processes in line with evolving technologies, legislative changes, and current risks.

The Company carries out the necessary work to regularly review and continuously improve its security systems regarding the protection of personal data in line with evolving technology and current risks. However, being aware that no security measure provides absolute protection, we adopt a preventive (proactive) security approach aimed at identifying, preventing, and minimizing potential risks in advance.

  1. RETENTION AND DESTRUCTION OF PERSONAL DATA

The Company retains personal data for the period necessary for the purpose for which it was processed and in compliance with the minimum periods stipulated by the legislation to which the relevant activities are subject. In this context, it is first determined whether a period is stipulated in the relevant legislation for the retention of personal data, and if a period is determined, it is acted in accordance with such period. If no period exists in the legislation, personal data is retained for as long as necessary for the purpose for which it was processed. When determining the retention period for data, the nature of the relevant data category, legal obligations, potential dispute risks, and service requirements are taken into account.

The general retention principles applied by the Company in this context are as follows:

  • Pursuant to tax legislation and relevant regulations, financial records, invoices, and payment information are retained for the period stipulated or permitted by the legislation,
  • Data relating to the user account is retained for as long as the user account is active; in the event that the account is deleted by the user or the membership expires, personal data is retained for the period stipulated or permitted by the legislation from the relevant date,
  • Data relating to marketing and communication consent given by the user is retained for as long as such consent is valid; when the user withdraws their consent, the personal data processed within this scope is deleted or anonymized, with the exception of cases arising from legal obligations.

Personal data is disposed of at the end of the determined retention periods in accordance with periodic disposal periods or the application of the Data Subject, and by the determined disposal methods (deletion and/or destruction and/or anonymization).

In cases where a longer period is legally required or permitted (such as a dispute or legal proceedings), your personal data may be retained only for the limited period until the conclusion of the relevant process. In such cases, your personal data is disposed of when the purpose of data retention ceases.

Data subjects have the right to request the deletion or destruction of their personal data within the scope of Article 11 of the PDPL. However, in some cases, this request may not be fulfilled immediately. For example, based on legal grounds such as the retention of data being necessary for the fulfillment of an obligation arising from legislation or being mandatory for the establishment, exercise, or protection of a legal right, the relevant data may continue to be retained for the legal retention period. In such cases, you will be informed as to why your data deletion request cannot be fulfilled and the reasons will be clearly shared.

  1. INFORMING AND NOTIFYING THE DATA SUBJECT 

The Company informs the Data Subject in accordance with Article 10 of the PDPL. In this context, if personal data is obtained from the Data Subject themselves, at the time of obtaining; if not obtained from the Data Subject, within a reasonable period after the personal data is obtained; but in any case, regardless of the Data Subject’s request, the Data Subject shall be informed about:

  • The identity of the Company,
  • The purposes for which personal data will be processed,
  • To whom and for what purposes it may be transferred,
  • The method of collecting personal data,
  • The legal basis on which personal data collection is based,
  • The other rights of the Data Subject enumerated in Article 11 of the PDPL,

shall be disclosed.

  1. RIGHTS OF THE DATA SUBJECT AND EXERCISE OF THESE RIGHTS 

The legal rights that the Data Subject may exercise pursuant to Article 11 of the PDPL regarding personal data are enumerated below:

  • To learn whether your personal data has been processed, 
  • If your personal data has been processed, to request information about it, 
  • To learn the purpose of processing your personal data and whether it is being used in accordance with that purpose, 
  • To know the third parties to whom your personal data has been transferred domestically or abroad, 
  • To request correction of your personal data if it has been processed incompletely or inaccurately,
  • To request the deletion or destruction of your personal data within the conditions stipulated in Article 7 of the PDPL, 
  • To request that correction, deletion, or destruction operations be notified to third parties to whom your personal data has been transferred,
  • To object to a result arising against you through the analysis of your processed data exclusively by automated systems, 
  • To request compensation for damages in the event that you suffer harm due to the unlawful processing of your personal data. 

The Data Subject may submit their requests regarding the rights enumerated in this article in Turkish, in accordance with the Communiqué on the Procedures and Principles for Applications to the Data Controller, to the Company located at “Pınarbaşı Mah. Hürriyet Cad. Antalya Teknokent Uluğbey Ar-Ge 2 Binası No: 3A İç Kapı No: B25 Konyaaltı / Antalya” in writing, or via [email protected] Registered Electronic Mail (REM), Secure Electronic Signature, Mobile Signature, or the e-mail address previously provided and registered in our system, or in accordance with other application methods determined by the DPA Board.

  1. THE COMPANY’S RESPONSE TO APPLICATIONS

The Company takes all necessary technical and administrative measures to conclude the applications to be made by the Data Subject effectively and in compliance with the law and the principles of good faith.

The Data Subject’s applications may be accepted or rejected with stated reasons. The response to the Data Subject’s application may be communicated to the Data Subject in writing or electronically.

If the Data Subject submits their request regarding the rights set forth under heading XI of the Policy titled “Rights of the Data Subject and Exercise of These Rights” to the Company through the aforementioned methods, the relevant request will be concluded free of charge in the shortest possible time and within at most 30 (thirty) days, depending on the nature of the request. However, if the transaction requires an additional cost and the conditions determined by the DPA Board are met, the fee set out in the tariff may be charged.

  1. ENTRY INTO FORCE AND UPDATE OF THE POLICY

The Company reserves the right to amend, update, or revise this Policy at any time in line with legal changes, internal process updates, or innovations in the scope of services. Changes made to the Policy enter into force at the moment they are published in their most current form on the website.

It is recommended that our users visit our website at regular intervals in order to always have access to the most up-to-date information regarding the conditions for the processing of their personal data. 

  1. CONTACT INFORMATION

For any questions, requests, suggestions, or complaints regarding the implementation of this Policy, the processing of your personal data, or the exercise of your rights under the PDPL, you may contact the Company through the following communication channels:

Title: J Labs Teknoloji Anonim Şirketi

Address: Pınarbaşı Mah. Hürriyet Cad. Antalya Teknokent Uluğbey Ar-Ge 2 Binası No: 3A İç Kapı No: B25 Konyaaltı / Antalya

E-mail: [email protected]

REM Address: [email protected]

Requests submitted to us will be concluded in the shortest possible time and within at most 30 (thirty) days, pursuant to Article 13 of the Personal Data Protection Law No. 6698. The Company reserves the right to request additional information or documentation in cases requiring identity verification, in order to confirm that the application belongs to the data owner.