GENERAL MOBILE PRIVACY POLICY

As General Mobile, we know how important privacy is to our customers. In this Privacy Policy, it is explained how General Mobile collects, utilizes and shares your personal data. You can reach this information in up-to-date form from this adress: https://www.generalmobile.com/tr/gizlilik-politikasi

In this Privacy Policy, it is explained how General Mobile or companies affiliated to General Mobile (Telpa Telecommunication Trade Inc., Telpa Technology Services Inc., Telpa Communication Distribution and Sales Inc., “General Mobile” as a whole) processes personal data when you contact us directly through our website, or through General Mobile apps (GM Assistant, GM Music, GM Documents and GM Watch) or by visiting our retail stores. General Mobile may also have third party connections or may put third party applications for use on Google Play to be downloaded. The forms of use or recognition of personal data by third parties is not liable to the Privacy Policy of General Mobile. We suggest you to read the privacy policies and learn about your privacy rights before interacting with third parties.

ON YOUR PERSONAL DATA

We accept all data about persons whose identities are or may be determined, or all data that is or may be related to the subject persons as “personal data”.

We are using the personal data that is provided by you to offer you service, to understand your way of using our services and to therefore enhance and personalize your experiences and develop the best applications, technologies and content for our customers. We also use the personal data to offer you personalized ads that are specialized according to your interests.

PERSONAL DATA THAT IS GATHERED FROM YOU BY GENERAL MOBILE

General Mobile gathers your personal information that are listed below in various ways.

• Certain information such as your name and date of birth when you create an account or a profile, and/or information such as your email adress, adress, phone number,
• Your invoice adress and data about your paying method such as your bank information, credit card, bank card and another payment card information,
• Your name, adress, contact information, information about delivery and payment for putting your order in process if you order a product or a paid service,
• Information to validate your identity and the product you are asking about to provide answer when you contact Customer Service,
• In the condition that you share your contact persons, your contacts’ phone numbers and other communication information, in order to facilitate document sharing and messaging (You can stop or limit this feature from the Settings section of your device.)
• Your hardware model, your device hardware information, your IMEI number and other unique device definers, phone number, serial number, sale code, access record, current software release, MCC (Mobile Country Code), MNC (Mobile Network Code), MAC adress, IP adress, GAID, cookies, pixels, subscription information, operating system versions and settings of the devices that you use to access Services,
• Session information, information of recognition, technique, error and use such as your time and duration of using the services, inquiry terms about a spesific General Mobile service that you have entered to your device, and any information contained in the cookies that we have placed into your devices,
• Information about your device’s GPS signal or nearby Wi-Fi access points and cell towers, which may be transmitted to us when you use certain services and/or activate your location function,
• Voice recordings when you activate voice function to command a service and use voice commands,
• Details like the content of your contacts with General Mobile, including interactions with customers service team and contacts through social media channels,
• The words you type when you activate Word Prediction (This feature may be provided linked with your General Mobile account in order to equalize the data to be used in your other General Mobile devices. You can delete the data by going to your word prediction settings.),
• Links, channels, websites that are visited and programs that are viewed on your devices and time that is spent on viewing them, information of how you interact with the content that is provided by websites that you visit and by a service,
• Data which are used to help detect and prevent fraud,
• Data about your activity on our offers, including activity history, search history, product interaction, crash data, performance and other identification data and data about your usage such as starting application within our services,
• Data concerning health condition including data about physical condition. The data which may be used to draw inference about a person’s health or to determine his or her health condition is among personal health data.
• Details about fitness and exercise, on the condition of your allowance,

General Mobile, by itself and/or by its associates, provides Dynamic Pre-Load application, Smart folder, widgets, wizard application and services that have updates about them. These provided services are in End-User Licence Agreement that has URL.

When we work with a third party service provider that provides the services, mind that this provider may collect and keep certain data, in accordance with the agreement between us and our private third party service provider.

Personal data that are irreversibly rendered anonymous will not be accepted as personal data in accordance with the aforementioned law and processing activities concerning these data will take place notwithstanding this Privacy Policy.

It is not necessary that you provide the personal data that is aforementioned and/or we demand. You may choose not to give these information to us. If you choose not to share these data, we may not be able to provide you our products or services and/or fulfill your demands in most cases.

PERSONAL DATA THAT GENERAL MOBILE RECEIVES FROM OTHER SOURCES

General Mobile may take personal data about you from other persons, from businesses that are directed by you or from third parties, from our business partners that we work together to provide our products and our services and that also help us for security and prevention of fraud, and from legal sources.

• Persons: General Mobile may gather data about you from other persons (for example if the aforementioned person has sent you a product or gift card, if that person has invited you to join a service or forum of General Mobile, or has shared a content with you).
• Those Who Are Directed By You: You may direct other persons or third parties to share data with General Mobile. For example you may direct your mobile operator to share data about your operator account with General Mobile for account activation, or your loyalty program to share your participation information for you to win a prize on your purchase activities.
• Business Partners of General Mobile: We may verify the data that is provided by you via a third party in order to prevent fraud and for security reasons.

Also, if you give approval, we may collect other informations about you, your device and your use of Services.

Through certain Services, we may collect personal information about your online activity on websites and linked devices in time and from third party internet sites, devices, applications and other online features and services. We may use third party analytic services such as Google Analytics. The service providers that offer these analytic services help us analyse your use of Services and improve Services. The information we receive may be revealed by other relevant third parties or get collected directly by them to, for example, evaluate how Services were used, help the management of Services and detect errors. For detailed information about Google Analytics, please visit http://www.google.com/analytics/learn/privacy.html and https://www.google.com/policies/privacy/partners adresses.

GENERAL MOBILE’S INTENDED USE OF PERSONAL DATA

As General Mobile, we use personal data to; offer our services, process your operations, communicate with you, prevent fraud, provide security and obey the law. We may also use personal data for different purposes in accordance with your permission.

As General Mobile, we use your personal data only when we have a valid legal foundation. Depending on the situation, General Mobile may either take action toward your permission or toward the justification that it is necessary to process your personal data to fulfill a contract that you are a party to, protect the criticially important benefit of you or others or obey the law. Considering your interests, rights and expectations, we may also process your personal data in cases that we believe it is to our or others’ legitimate interest. If you have any questions concerning legal foundation, you can contact Data Protection Attendant via General Mobile.com/tr/privacy/contact.

Intended use of data is listed below:

• To help register you and your device to our services, to offer specialized and personalized services based on your previous actions related to our services, to review or do data analysis for personalizing or enhancing our proposals,
• To gather data such as your purchasing information and payment information to process operations,
• To present specialized ads, promotions and proposals that are interesting to you on our websites, third party websites and online platforms such as social media sites,
• To present promotions and proposals with direct marketing communications only in circumstances that you separately give us permission,
• To analyse our products and services to better understand our customers,
• To ask for your opinions on our products and services and make customer surveys with your separate permission if necessary,
• To update softwares for your devices, offer care services and support,
• Obey the laws and legal processes,
• To protect the security, property and rights of General Mobile or our affiliate companies, business partners or customers,
• To protect persons, employees and General Mobile; to prevent losses; to prevent fraud including scanning and examination to detect whether there are any illegal content, including sexual abuse materials toward children,

GENERAL MOBILE’S SHARING OF PERSONAL DATA

General Mobile may share personal data with third parties with your instruction and permission, just as when we share information about your operator to activate your account. We may also share information about you in case of finding information disclosure necessary or appropriate for national security, execution of law and other important matters. We will declassify your information within our business only in the measure that is necessary to provide our services and only to those who need it to offer services and help with your demands, and to institutions that are listed below:

As General Mobile, we may share personal data with other General Mobile Group companies that we manage or possess, service providers that operate on behalf of us, our business partners, providers and publishers or third persons that you direct to. General Mobile service providers are obligated to process personal data with consistency to this Privacy Policy and within your instructions. They can not use the personal data we share for their own purposes and are obligated to delete or return personal data after complying with our request.

Partners that work with us to provide you the Services which you follow or purchase. We may work with a bank, for example, so that you can use one of our Services to make faster and more productive payments. These business partners control and manage your personal data.

Companies that are selected carefully to provide services for us or on behalf of us; companies that help us for, as examples, renovation, customer communication centers, customer care activities, advertising (including specialized advertisements on our websites, third party websites or online platforms), performing customer satisfaction surveys or companies that help us for invoicing or sending emails on behalf of us. These providers are also committed to protect your information.

We may reveal your information to a third party in case of a unision or transition, takeover or disposition.

When you purchase a third party subscription on Play Store, a special Subscriber Identity is created for you and the developer or publisher. Subscriber Identity may be used to provide reports that include information about the subscription you purchase and the country that you reside in.

PROTECTION OF PERSONAL DATA AT GENERAL MOBILE

We take data protection process seriously. We take physical and technical precautions in order to ensure the security of information that we gather linked to Services. However, despite our reasonable steps to protect your information, please do not forget that no website, internet transmission, computer system or wireless connection is ever completely safe.

INTERNATIONAL TRANSMISSION OF PERSONAL DATA

General Mobile products and offers give us opportunity to connect with the entire world. To make this possible, your personal data, associated with your use of our products and services, may be transmitted to institutions around the world including companies that are connected to General Mobile to execute the processing operations that were explained in this Privacy Policy. In order to help the protection of your personal data regardless of location, General Mobile obeys the laws regarding international transmission of personal data.

STORAGE PERIOD OF PERSONAL DATA

As General Mobile, your personal data will be stored during the necessary period within the information that is used to offer/provide you a service, when it is regarded as necessary within Law and Contract and during the reasonable period for these purposes or for your legal liabilities and only for gathering, in longer periods in case it is necessary within any contract or necessary for governing law or statistic purposes. While evaluating the storage periods, we primarily analyse whether storing personal data is necessary or not and try to store the data that is necessary within the shortest extent permitted by the law.

General Mobile does not use algorithms or profiling technologies to make any decision that would affect you in an important mesure without the opportunity of it being reviewed by a real person.

THIRD PARTY SERVICES

Some of the content, advertisement and features of our Services are provided by third parties. These third parties may use cookies, signs, tracking pixels and other tools in order to gather information about your use of these Services. These third parties are not administered directly by General Mobile; for this reason we suggest you to read their privacy policies to understand how they are going to make use of your data.

For some applications and services including social networks, we collect and store your login information that you have allowed us to collect when you connect to these applications and services.

COOKIES AND OTHER TECHNOLOGIES

Us and some third parties that offer content, advertisement or other features in our services may use cookies, signs, pixels and other technologies in some sections of our services. Including purposes of preventing fraud and security, these technologies also help us better understand customer behavior; they give us information about which sections of our websites are visited; also facilitate the activities of advertisements and web searches. Besides helping us determine errors, cookies are used to enable network traffic that pass by General Mobile’s systems.

Strictly Necessary Cookies are set in a necessary way for a feature or service that you reach or demand to be provided. For example, for us to display our websites in appropriate style and language, to verify and approve our operations and to secure your Basket while you are shopping online on www.generalmobile.com/tr website.

Other Cookies are used to understand how customers interact with our website and our online services (including helping us understand the activity of advertisements and web research). General Mobile also uses aforementioned cookies to remember the choices you made during your web activity; this way we can provide you a specialized experience.

While you are using a web browser to reach Services, you may set your browser to accept or reject all cookies or to inform you when a cookie is sent to you. Every browser is different; for this reason, take a look at your browser’s help menu to learn how to change your cookie preferences. The operating system of your device may include additional checks for cookies. Please do not forget that some Services may be designed to function by using cookies and that turning off cookies may affect your chance of using these services or their certain parts.

With some third parties, we may use other technologies such as Local Shared Objects (also named as Flash cookies) and HTML5 local stroge connected to our services. These technologies are similar to the one that were mentioned above. They are stored in your device and may be used to store some information about your activities and preferences. But these technologies may use different parts of your device than regular cookies do, and for this reason it may not be possible for you to oversee these by using standart browser tools and settings. Please visit this adress for information on disabling or deleting information that take place in Local Sharing Objects: https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html

We may, with some third parties, use technologies that are called signs or pixels, that transfer information from your device to the server. Signs; they can be placed into online content, video and emails and enable a server to read certain kind of information from your device, know when you view a certain content or a certain email and detect the IP adress of your device, along with the date and time of when you viewed the sign. We and some third parties use signs, along with the analysis of the use of our services and with cookies, for various purposes such as providing content and advertisement that is more related to you.

Also, with the open consent that you provide; we may share parts of your personally identifiable information (PII) that are rendered random and complex with our strategic partners of Social Media Platform in order to increase customer satisfaction in all social media panels, to provide a better service related to your interests and to offer a better service to our consumers who have common interests with you.

YOUR PRIVACY QUESTIONS

Your personal information belongs to you. You may ask us to give details about the ones we collect and to delete or fix any inconsistency. You may also ask us to limit and or restraint the processing, sharing and transfering of your personal data and ask us to provide you your personal data so that you can use it for your own purposes. However, asking your personal information to be deleted may also result in loss of access to services we provide.

There may be occasions when we may not fulfill your requests (for example if you request your operation data, that General Mobile is liable by law to keep a record of, to be deleted). We may also refuse to fulfill requests that may prevent us to use data to prevent fraud and ensure security (for example deleting an account that is under an ongoing investigation for security concerns). Your privacy requests that may danger other peoples’ lives, that are unreasonable, ill intentioned or unfavorable to fulfill may be refused.

Contact us to make a request about your rights and to ask questions. Please check https://www.generalmobile.com/tr/hakkimizda/iletisim section and/or in order to learn about your rights related to General Data Protection Regulation numbered 6698 and to make an application, check “Person Application Form Regarding Personal Data Protection Law” at this adress: https://assets.generalmobile.com/download/General_Mobile_Basvuru_Formu.pdf

As General Mobile, in order to ensure the security of your personal data we inform our employees about our rules of privacy and security and we strictly apply security measures within the company.