PRIVACY POLICY

We value your privacy. SIKAYETVAR BILISIM A.S. ("SIKAYETVAR" or "Site" or Xolvie in the other articles of this policy ) has created this Privacy Policy to explain how your information is protected, collected, and used. This Privacy Policy may be updated from time to time, and you can always review the most current version here.

By using the website, you acknowledge that you have accepted the terms and conditions of this Privacy Policy and that you are aware that our policies are subject to change in the future. In the event of a conflict between our Terms of Service, which govern your use of the website, and this Privacy Statement, the Terms of Service shall govern.

On SIKAYETVAR we strongly believe in transparency and trust. The more we trust each other openly and honestly, the more we can benefit from our shared experiences. We hope that this is reflected in our Privacy Policy below. Furthermore, we believe that our users have the right to exercise control over their Personal Data (as defined below). In Article 14, you can review all of our rights and obligations, as well as issues concerning your rights.

We collect and process personal data about you when you create a membership on "SIKAYETVAR" or use our website in any other way (when you visit). This document will help you understand what personal data we collect about you, how we collect it, what we use it for, and what rights you have in relation to your personal data.

We mean SIKAYETVAR BILIM A.S (sikayetvar.com website, its derivative sites, Xolvie, Xolvie by SIKAYETVAR, Sikayetvar Social Media Accounts, and other platforms under our management) and our affiliates when we say "SIKAYETVAR" or "we." Additionally, we use the term "Policy" to refer to this Privacy Policy and the term "Site" to refer to all of SIKAYETVAR's websites.

"SIKAYETVAR" is the legal entity in charge of processing your personal data. Please read the information below about what we collect and how we use it under the following conditions.

 

1. Personal Data

In accordance with the purpose of this Privacy Policy, "Personal Data" refers to any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

1.1. Main Data?

We will automatically create a personal account ("Account") for you on XOLVIE when you create a profile on the website or when you create your first membership and collect the following personal data ("Main Data") about you:

  • Your Identity Information: your first name, last name
  • Your Contact Information: your mobile phone number (for writing complaints), your email address
  • Your Transaction Security Information: IP address information, password information, cookie information
  • Your Location Information: information about where you wrote the complaint and where you purchased the product
  • Other information provided by the chosen login method

These pieces of information are mandatory, so it will not be possible to initiate a Membership on the website without them.

You can choose to add more personal data to your profile, some of which can help us resolve your complaints with different businesses and deliver your refunds to you faster. This additional information (profile picture, contact information, etc.) will be part of your general profile and the Main Data.

 

1.2. Account and Content Data

We collect the information you provide for your Membership Account ("Account") when you create one on our website. This includes the following:

  • Which company/companies you are associated with
  • Your complaints about the purchase or service or the types of problems you experienced
  • The title and content of your complaint
  • Your rating of the company's resolution of the complaint (1-5 stars)
  • Your responses to survey questions
  • The date and resolution of your complaint
  • A reference number or Complaint ID (if provided by you or the company)
  • Voice Data: Call center call recordings
  • Uploaded images, audio files, and other materials
  • Legal Process Information: Information in correspondence with authorized individuals, institutions, and organizations, information in legal case and execution files, and information in legal information requests.
  • Messages you send and receive
  • Metadata about these contents and messages
  • This metadata includes information about the content itself (e.g., the location where a photo was taken or the creation date of a file)
  • Information about the message itself (e.g., message type or send date and time)
  • Types of content you view or interact with and how you interact with them
  • Information about the message itself (e.g., message type or send date and time)
  • Types of content you view or interact with and how you interact with them
  • Actions you perform on our applications and features
  • For example, we may record: which applications, posts, videos, advertisements, brands, and other content you view or interact with on our products or when you use the auto-fill feature
  • Time, frequency, and duration of your activities on our platform
  • Specially protected data
  • Information such as your religious beliefs, sexual orientation, political opinions, health, race or ethnic origin, philosophical beliefs, or union membership that you choose to provide may be subject to special protections under the laws of your jurisdiction.

If we ask you to provide information or documents that verify your Service Experience and you send us such documents, we will collect and process the documents for the purposes specified in the request.

We may find it necessary to supplement the information collected to improve your experience, resolution time, or other aspects of Site operations. Please refrain from sharing unnecessary sensitive personal documents or information about yourself or others with us.

1.3. Data on How Useful Your Views, Likes, and Content Are to Others

When you initiate a Complaint process on our website, people can indicate that they found your Content's progress or solution helpful, and we collect this information. We also gather information about how many people are following your Content. We do not track the identities of non-registered users or those who do not view the Content, but we do collect data on the number of consumers and companies following your Content. If you follow another user’s content, we will also collect this information.

1.4. Notifications

If you believe that a User has violated our Guidelines, please report the offending Content to us. We collect the information you provide within your notification when you send it to us. This may include information regarding the Content you are reporting, the reason for your report, the date of your report, and so on.

1.5. Data Obtained from Other Services, Including Social Networks

You can link your XOLVIE profile to your social media profiles, especially your Facebook and/or Google account, to facilitate quick communication with us regarding your complaint. When you use this option, we automatically gather the information selected about you from your social media accounts. The information we collect depends on the privacy settings and the information you choose to share on these social media platforms. Based on your settings and preferences, we will gather the necessary information to resolve your complaint as quickly and completely as possible.

When you request to link your XOLVIE profile to a social media profile, we will make every effort to inform you about the information we will collect from that particular social media platform. However, we cannot guarantee that this will always be the case since it depends on the features provided by the social media platform, and we may not always be able to provide you with this information. You can choose to disconnect your social media profile from your XOLVIE profile through your Social Media Account.

At this point, XOLVIE will remove your unique social media identifier and disconnect/cancel the connection between your XOLVIE profile and social media account. Your profile picture from the social media profile will remain in your XOLVIE profile.

 

1.6. Application, browser, and device data

  • We collect and receive data on your various devices and how you use them.
  • The device information we collect and receive includes:
  • The specific devices and software you're using and other device characteristics.
  • Activities you carry out on your device include whether our application is in the foreground or your mouse is moving (which can help distinguish humans from bots).
  • Identifiers that distinguish your device from others, including Family Device Codes.
  • Data you share with us via your device settings (such as camera access, photos, and so on).

 

1.7. Cookies

Like many websites, XOLVIE also uses a standard technology called "cookies." A cookie is a small text file that is stored on your computer's hard drive and can be accessed by a specific website to make your experience faster and more user-friendly. Cookies allow our users to log in to XOLVIE without entering their identities and passwords. They also assist us in better understanding how our users interact with the site, allowing us to improve the service. We do not use cookies to retrieve information from your computer that we do not provide, such as user codes.

 

1.8. Your IP Address, Browser Settings, and Location

We log your IP address and browser settings when you visit the website. The IP address is the numerical address of the computer from which the website is accessed. Browser settings may include the browser type, browser language, and time zone. We collect this information to track the computer used in the event of misuse or illegal activities related to website visits or website usage. We also use your IP address to estimate your city-level location so that we know which set of Terms of Service applies to your use of the website.

 

1.9. News Bulletins and Summary Emails

We collect the information you provide us when you receive our news bulletins, summary emails, notifications regarding updates on your complaints, or similar communications (including your name, email address, and newsletter preferences). If you no longer wish to receive our news bulletins, summary emails, or similar communications, you can cancel your subscription by logging into your account and changing your settings.

 

1.10. Why do we collect and use your personal information?

We will use the information you provide us for the following purposes:

  • To resolve your complaint and provide you with our services, including providing you with access to your profile and our website.
  • To identify you as a registered user when you log in and revisit the site.
  • To verify the details of your complaint.
  • To improve our website and services.
  • To invite you to create more content.
  • To respond to your questions and provide relevant customer support.
  • To assist the brand related to your complaint in contacting you.
  • To contact you and, if necessary, request documentation to verify your experience if we receive questions about your complaint from other users or companies.
  • To send you our newsletters.
  • To evaluate your requests, complaints, and suggestions related to our services.
  • To notify you when other users follow the status of your complaint or provide feedback in any other way.
  • To facilitate the social sharing function, including connecting you with members of your network who are both users of XOLVIE and one or more social media platforms.
  • To enhance trust in our process and provide a better user experience on our website by displaying which members of your social networks are users of XOLVIE.
  • To be used for a variety of internal business purposes, including data analysis, audits, fraud monitoring and prevention, developing new products and services, improving or modifying the website or our services, identifying usage trends, determining the effectiveness of our promotional campaigns, and conducting and expanding our commercial activities.
  • To comply with legal requirements, legal processes, requests from public and official authorities, relevant industry standards, and our internal policies.
  • To ensure information and transaction security and prevent misuse.
  • To enforce the Terms of Use.
  • To protect our activities or the activities of any of our affiliates.
  • To protect our rights, privacy, security, property, and/or the rights of our affiliates, you, or others.
  • To enable us to follow existing resolution paths or limit the damages we may suffer.
  • We will also use the information in other ways for which we have provided specific notice at the time of collection.

 

2. Sharing Personal Data

2.1. Sharing Personal Data on the Website

We are an open platform, and we publish your Complaints and other Content on our website for others to read about your specific experience with a particular company. When you create a Complaint, we display your Complaint, your real name (only the first name provided by you), your profile picture from the Social Network you used for login, and other information you choose to connect with your general profile. Please note that the information disclosed about your Complaint may partially or completely reveal your identity, as part of our credibility relies on real solutions for real Complaints from real people. We recommend that you use caution when deciding which information to display on the site and that you understand that depending on the level of information provided, you may or may not remain anonymous.

Main Data and other information: When you publish a Complaint on our website and create an Account, your name, Complaints/Content, photo, location, and the number of Complaints you've created may be displayed on the site. Additionally, the companies/brands mentioned in your Complaints will receive information regarding the complaint.

Geographical location: When you create a Complaint on the site, we use your computer's IP address to estimate your location to the nearest city (refer to section 1.8 of this Policy above). This information may be made available to other users of the site.

Other users of our site can see that you found this content helpful, as well as your likes, comments, approvals, flags, and any other indicators of your opinions when you see other important content.

Social Networks: If you connect to a Social Network, information such as your profile picture, your name, your year of birth, and your approximate location will be collected from your Social Network profile and used to identify you on the site. Depending on your privacy settings and the level of information obtainable from the Social Network, site users may use this information to determine which Complaints you have created. If your contacts or friends on the Social Network (referred to as "Connections") have also connected with our platform, how you are connected to these Connections through the Social Network may be visible on the site. This information is only visible to you. Other users on XOLVIE cannot see your Connections on Social Networks.

 

2.2. Information Disclosure to Other Services That You Can Link Your Profile With

If you choose to link your XOLVIE profile with a social media profile, the information and data related to the complaints you initiate or your usage of the service (such as the number of complaints you initiate) will be shared, displayed, and subject to the privacy policy of the social media platform on the website.

 

2.3. Information Disclosure with Other Services, Websites, and Companies

One of the main goals of XOLVIE is to increase the impact of complaints on its website. Therefore, we allow other services to publish your complaints on their platforms. This service enhances the potential impact of the complaints. The categories of third-party services and companies that are allowed to view your complaints on your public user profiles are as follows:

  • All search engines such as Google, Bing, etc.
  • Brands that have accounts on XOLVIE
  • Consumer portals and business portals
  • Application partners and platforms
  • Other platforms, media, and social media channels that XOLVIE deems relevant for its users to search for complaints
  • After you submit your complaint, it will be published on the website. This means that the following information may be shared:
  • Your complaint (see section 1.2 above)
  • Your name (in the format you provided) and additional documents, photos, videos, etc. that you want to add to your profile, profile description, and profile picture (XOLVIE may occasionally update this information as well.)

If we need to verify your complaint, we will contact you and request documents proving your service experience with the company to which you have applied.

 

2.4. Other

In addition to the foregoing, we transfer your personal data to the individuals/legal entities and content listed below:

Our company ensures that your personal data is processed in accordance with the principles of "need to know" and "need to use," ensuring data minimization and implementing necessary technical and administrative security measures. We are required to transfer the personal data we process to third parties for specific purposes due to the critical continuous data flow with different stakeholders to conduct or supervise business operations, maintain business continuity, and operate digital infrastructure. Furthermore, it is critical for us to have accurate and up-to-date personal data in order to properly and appropriately fulfill our contractual and legal obligations. As a result, we must work with a variety of business partners and service providers.

Personal data, managing complaint processes, managing assistance and support requests related to your processes, conducting activities to enhance the experience and satisfaction of our members/visitors, providing information about developments and innovations within our company, conducting activities for the development and improvement of the products and services offered by our company, conducting activities to provide users with a better service experience and increase their satisfaction, ensuring business continuity, ensuring information security, fulfilling legal obligations, and within the limited scope of the purposes specified in the second article of this disclosure text, as necessary:

Based on the legal grounds of our company's obligations to be explicitly stipulated in the applicable legislation and to fulfill its legal obligations, being necessary for the establishment or performance of a contract;

  • XOLVIE shares the GSM number entered by users for verification code only with the authorized personnel of the company they are complaining about in order to find a solution to their complaint.
  • If XOLVIE engages in activities such as merging with another company, acquiring a company, or selling assets, we will continue to ensure the confidentiality of personal information and notify the affected users before the transfer of personal information or before being subject to a different privacy policy.
  • With business partners and service providers who provide services in the field of quality control, complaint management, and risk analysis,
  • With our business partners and service providers who provide, operate, or deliver our information technology infrastructure,
  • With our business partners who provide risk management and financial reporting process services,

Based on the legal basis of obtaining your explicit consent;

  • For the purpose of displaying advertisements based on website usage preferences, browsing history, segmentation, and user preferences, we may share your data with relevant service providers and partners,
  • We may share your data with partners and service providers in this field for profiling, analysis, customization of services offered, marketing, and advertising purposes,
  • We may share your data with our relevant partners to manage marketing processes,

We may share your personal data with the following third parties and business partners based on legal grounds, including the necessity of data processing for the establishment, exercise, or defense of a legal right explicitly provided for in the legislation applicable to our company and the mandatory nature of fulfilling our legal obligations;

  • Lawyers, auditors, forensic experts, cybersecurity consultants, tax advisors, and other consultants and service providers we work with to meet our legal obligations,
  • Authorities in charge of regulation and supervision, as well as authorized public institutions and organizations such as courts and enforcement offices,
  • Other public institutions or organizations are authorized to request your personal data.

Your legal transaction information is automatically collected and processed in an electronic format directly from you via the internet website for the following purposes. The majority of our services allow you to share data with other users. Please keep in mind that when you share information publicly, including on platforms like XOLVIE, it may be indexed by search engines.

Your complaints are particularly notable examples of publicly shared information.

In conclusion, XOLVIE may disclose or use the information you have provided or obtained from you for the following purposes;

  • To allow third-party providers, consultants, and other service providers to provide services on our behalf
  • To XOLVIE affiliates and other companies within the XOLVIE corporate group
  • To comply with laws or respond to public and government authorities' requests, and court proceedings (including subpoenas and court orders) and to protect our rights, privacy, safety, or property
  • To cooperate with regulatory and government agencies
  • For the enforcement of our Terms of Service and other relevant documents to third parties
  • To third parties in order to protect our business or the business of our affiliated companies
  • To third parties for displaying advertisements based on user preferences
  • To third parties for profiling, analyzing, and adapting our services, marketing, and advertising
  • To third parties for managing marketing processes
  • To third parties for obtaining possible solutions or limiting the damages we have suffered
  • To third parties for investigating, preventing, or taking action against suspected or actual cases of prohibited activities on our website, including fraud and misuse
  • To third parties in the event of a restructuring, merger, acquisition, sale, joint venture, assignment, transfer, or other transactions involving the transfer of all or part of our business or assets (including in connection with bankruptcy or similar proceedings).

 

2.5. Data Sharing Restrictions

We may store, process, and transfer the personal data we collect from you across the countries in which we operate. The legal provisions in your jurisdiction may have determined that some of the countries in which we operate do not have a Personal Data Protection Law that provides adequate protection. Derogations are granted based on specific situations defined in Article 14 of the XOLVIE legislation. We will strive to implement reasonable security measures wherever we transfer, process, or store your personal data. We will use the information we collect from you in accordance with the practices described in our privacy statement. By using our platform, you agree to the personal data transfers described in this section.

Within the framework of your legal rights in your region, you can request that the sale or sharing of your personal data with third parties be disabled. XOLVIE will never sell your data for profit. Still, we do give you the option to opt out of situations where we share your data with our business partners for purposes such as showing you personalized ads or improving our services to comply with local laws. You should be aware that we only conduct such data transfers when we believe it will benefit you by providing a better experience, higher service quality, or content that may be of interest to you.

Please contact us at [email protected] to manage your privacy preferences and disable the sale or sharing of your personal data.

 

3. Data Controller

3.1. Data Under Our Responsibility

XOLVIE is the entity in charge of the Main Data you enter to create and update your profile (including, but not limited to, your name, password, email address, and recorded IP address). In addition, XOLVIE is in charge of information sent to other services (see 2.3).

 

3.2. Data Under Your Responsibility

You are responsible for the personal data revealed when you connect the content we share on our website and platforms and your social media profiles to your XOLVIE profile.

 

4. Links to Websites

Our website and platforms may contain external links. This does not imply that we endorse or support the linked websites. We have no control over the content of third-party websites, nor are we liable for their policies and procedures. Therefore, we advise you to review the privacy policies of these third-party websites, as their methods for collecting, processing, and using personal information may differ from ours.

 

5. Video Attachments

Videos submitted to " XOLVIE " may be published on YouTube using API services provided by YouTube. You agree to YouTube's terms of service by creating and submitting videos. In addition, we advise reading the Google Privacy Statement to learn how Google processes and protects your personal information.

 

6. Third-Party Advertisements

The advertisements you see on XOLVIE may sometimes be directly provided or "served" to you by third-party providers. During this process, they automatically collect your IP address. These third-party providers may also download cookies or other technologies such as JavaScript and "Web Beacons," also known as "1x1 Gifs," to personalize ad content and measure the effectiveness of their ads on your computer. These activities enable advertisers to recognize your computer when they send each ad to you, measure the effectiveness of their ads, and personalize ad content. In this way, they can determine where people using your computer or browser have seen ads and which ads they have clicked on. XOLVIE does not provide access or control over the cookies that third-party advertisers may place. Unless you have provided your contact information to them, third-party advertisers cannot access the contact information stored on XOLVIE. This Privacy Policy applies to the cookies used by XOLVIE and does not apply to the use of cookies or other tracking technologies by an advertiser. XOLVIE collects data about Google advertising cookies and anonymous identifiers, including data collected through Google Analytics, Google Analytics Demographics and Interest Reporting, Google Analytics Remarketing, Google Display Network Impression Reporting, DoubleClick Platform integrations, and Google Ads. By visiting the following links, you can opt out of certain advertisers' practices: Network Advertising Initiative, Omniture, Digital Advertising Alliance, Google Analytics, and Privacy Choice. Please keep in mind that opting out will not keep you from seeing advertisements.

 

7. Data Storage

We keep your personal data, including Main Data and Complaints/Contents you provide, for as long as you have an Account or as long as it is necessary to provide our services to you. Please keep in mind that if you choose to delete your Account, all of your Complaints may also be deleted, or the information about the person who made the Complaint may be deleted, or that person may be anonymized. We will delete this information upon your request, but in accordance with applicable laws (Article 14), we will retain a record containing the following information for the periods specified below:

  • Call Center voice recordings: 3 years
  • Membership records: 10 years
  • All records related to accounting and financial transactions: 10 years
  • Cookies: 2 years
  • Commercial electronic message consent records: 1 year from the date of withdrawal of consent
  • Traffic information for online visitors: 2 years

At the end of these time periods, all relevant data will be deleted, destroyed, or anonymized in accordance with the applicable legislation. If you only use our website to look for companies that have Complaints about them, we will keep your information and your Account open until you decide to close it. Even if you close your account, we sometimes prefer to store certain information (for example, visits to our website) in an anonymized or aggregated form. (Note: Deleting your information from our website does not mean that search engines no longer index it. Please keep in mind that you must follow the specific protocols of the relevant website in order to have your records removed from search engines.)

 

8. Security Measures

The personal data shared with XOLVIE is under the supervision and control of XOLVIE. As the data controller, XOLVIE assumes responsibility for establishing and implementing the necessary organization and technical measures to protect the confidentiality and integrity of the information in accordance with the applicable legislation. Being aware of our obligations in this regard;

  • We conduct periodic penetration tests in accordance with international and national technical standards regarding data privacy.
  • Your personal data transmitted to XOLVIE through the website and mobile site are protected using Secure Sockets Layer (SSL) technology.
  • Regular risk analyses are conducted regarding personal data processing activities, and actions are taken to mitigate the risks.
  • Access and authorization controls are implemented to prevent unauthorized access to personal data.
  • Accordingly, we constantly update our data processing policies.

However, since the internet is not a completely secure environment, we cannot guarantee the security of the information you transmit to us. Emails sent via the website are not encrypted, therefore, we advise against including sensitive information in the emails you send to us. For more information about our current data protection policies and practices, please contact us at [email protected]. We are continuously working to improve our security practices and plan to update them as we progress.

 

9. How can you access and review your personal data?

To access and review your personal data, you can send an email to [email protected] requesting information about your personal data. After receiving your request, we will inform you about the personal data we have, how we collected the data, the purposes for which we process your personal data, and with whom we share your personal data.

 

10. How can you manage or delete your personal data?

We give you access to your data and allow you to correct, transfer, and delete it.

We keep the data for as long as it is required for us to provide our services and products to you or until your account is deleted (whichever comes first). This determination is made on a case-by-case basis, taking into account factors such as the nature of the data, the purpose of collection and processing, and any applicable legal or administrative retention requirements. For example, if you search for something on XOLVIE, you can delete your search history from your account at any time. However, the record of your search will be deleted after 6 months. If you submit a copy of your government-issued identification for account verification, we will delete it after 30 days, unless otherwise specified.

We will delete the content you have shared, such as your photos and complaints if you delete your account. This information will not be recoverable later. If you want to delete your account, go to the "Edit Profile" section and click the "Delete My Account" button.

XOLVIE stores the personal data processed via its website and mobile site for the time periods mandated by applicable laws (Article 14) and/or the necessary processing purposes. In accordance with the provisions of the Regulation on Deletion, Destruction, or Anonymization of Personal Data, it will delete, destroy, or anonymize the personal data upon the expiration of these periods.

The deletion of personal data by XOLVIE entails rendering the personal data inaccessible and unusable for the applicable users. XOLVIE creates and implements an access authorization and control matrix at the user level and takes the necessary steps for the database deletion process.

The deletion and destruction of personal data by XOLVIE refer to making personal data inaccessible, irretrievable, and unusable by anyone.

The anonymization of personal data by XOLVIE refers to making the personal data unidentifiable or unrelatable to any identified or identifiable natural person, even when matched with other data.

XOLVIE provides detailed explanations of the methods and technical and administrative measures for deletion, destruction, and anonymization within the scope of its Personal Data Storage and Destruction Policy prepared in accordance with the Regulation on Deletion, Destruction, or Anonymization of Personal Data. In this Policy, the time interval for the periodic destruction prescribed by the Regulation is determined as six months.

We strive to manage our services in such a way that they are not destroyed accidentally or maliciously. As a result, after you delete your information from our services, we may not delete the remaining copies from our active servers or remove this information from our backup systems right away.

We review compliance with our Privacy Policy on a regular basis. After receiving formal written complaints, we contact the complainant to follow up on the matter. We work with appropriate supervisory authorities, including local data protection authorities, to resolve any complaints about the transfer of personal data that we cannot resolve directly with our users.

 

I want to delete my membership and all my data

10.1. How long does it take to erase your data?

Request that your account or content be deleted. It may take up to 90 days for us to delete your information after we initiate the account deletion process or receive a content deletion request. After the data is deleted, it may take up to 90 days to remove it from backups and emergency recovery systems. Within 30 days, the deletion process will begin automatically. Other users will no longer be able to see the content you delete.

 

10.2. How can you modify your preferences for receiving commercial electronic messages?

You can modify or update your positive or negative preferences for receiving commercial electronic messages at any time by accessing the "My Account" section of the XOLVIE website, either during membership registration or at a later date.

Your membership cancellation does not result in the revocation of your consent to receive commercial electronic messages. Therefore, make sure that you carry out all the necessary steps for revoking your consent separately.

You can follow the steps outlined in our Cookie Policy regarding cookie management.

 

11. Other Rights

You have the following rights in addition to the rights mentioned above regarding your personal data:

  • You have the right to object to processing your personal data and to have that processing restricted.
  • You have an unrestricted right to object to processing your personal data for direct marketing purposes, in particular.
  • If your personal data is being processed with your consent, you have the right to withdraw your consent at any time. The withdrawal has no effect on the legality of the data processing that occurred prior to the withdrawal. You can withdraw your consent at any time by contacting [email protected].

If you wish to withdraw your consent for XOLVIE to process your data, it will not affect any processing that has already taken place at that time.

 

12. Data on Children

12.1. Children under the age of 13

XOLVIE does not knowingly collect or solicit personal data from children under the age of 13, and it does not allow them to register. Please do not attempt to register on XOLVIE or provide any personal information about yourself, including your name, address, telephone number, or email address, if you are under the age of 13. No one under the age of 13 is permitted to submit personal data to XOLVIE. If we discover that we collected personal data from a child under the age of 13 without parental consent, we will delete that data as soon as possible. If you believe we have information about a child under the age of 13, or if you are a parent and want to exercise any of your child's privacy rights, please contact us at [email protected].

 

12.2. Children between the ages of 13 and 18

We recommend that children over the age of 13 obtain parental consent before disclosing personal information online.

 

13. Privacy Consultant

We have a Privacy Consultant (PC) on hand. If you have any questions about our data processing activities, please contact our privacy consultant via email at [email protected].

 

14. The Legal Grounds for Our Rights and Obligations Regarding Data Collection and Storage

The legal responsibilities of both you and " XOLVIE " are presented below according to region. These regions were chosen based on the languages in which " XOLVIE " provides services. You may also use our services from a location other than those listed. By continuing to use our platform in such cases, you are deemed to have accepted the country's legal regulations where " XOLVIE " is established as the legal framework.

Despite the fact that these legal regulations may differ, they address similar issues with a parallel understanding. Please note, however, that your rights and obligations may vary depending on your location. Therefore, we advise you to carefully review the local laws in your area. If you have any questions or concerns about these matters, please email our Privacy Advisor at [email protected].

 

Legal Basis for Authority and Responsibility

Türkiye

 Law on Protection of Personal Data (PPD Law).

USA

California Consumer Privacy Act (CCPA)

 

EU

The General Data Protection Regulation (GDPR)

Russia

Federal Law 152-FZ

What personal data is collected?Article 6

Section 1798.140 (b)

 

Article 4, Article 13, Article 30Article 3
Why do we collect personal data?Article 4 and Article 6

Article 1798.140 (c)

Article 1798.105 (d)

Article 1798.135. (a)(6)

 

Article 6Articles 5 and 6
How is personal data used?Article 5

Article 1798.140 (c)

Article 1798.105 (d)

Article 1798.110 (a)

 

Article 4 and Article 6Articles 5 and 6
Data ResponsibilityArticle 3 and Article 11Section 1798.100Article 32 and Article 35Article 22.1
Whether or not personal data will be transferred abroad, and if so, under what conditions?Article 9Section 1798.145(a)

Article 6 and Article 44

 

Article 12
To whom and for what purposes can personal data be shared?Article 8

Section 1798.140(d)

Section 1798.135

Section 1798.115(a), (b), (c)

Article 6 and Article 44Article 9
Personal data storage period and how this period is determinedArticle 7

Section 1798.120(a)

Section 1798.105(d)

Section 1798.115

Article 5Article 5
Security measuresArticle 12 and Article 16

Section 1798.81.5

Section 1798.105(d)

 

 

Article 32Article 19
The Rights of data subjectsArticle 11

Section 1798.100 to

1798.199

 

Articles 12-23Articles 14, 15, 16, 17
Obtaining consent for the processing of personal data and revocation of consent, as well as changesArticle 5 ve Article 7

Section 1798.105

Section 1798.140

Section 798.130

Article 7Article 9

 

Due to the fact that we provide services in a variety of regions, the derogations listed here are based on the XOLVIE-defined legal requirements for particular circumstances. In the event of a conflict between laws, the provisions of the Personal Data Protection Law of the Republic of Turkey prevail. By using our platform, you are deemed to have accepted the stated legal regulations.

 

15. Changes

XOLVIE reserves the right to update the Explanation text on Personal Data Protection in accordance with possible changes in the applicable legislation.

Our Privacy Policy is subject to change at any time. We will not limit your rights under this Privacy Policy without your explicit consent. Any changes to the Privacy Policy will be published on this page. If the changes are significant, we will provide a more prominent notification (for example, an email notification regarding Privacy Policy changes for specific services). We will also keep previous versions of this Privacy Policy for your review. If you do not agree with the changes, you may terminate your account. Using our website after we have published or communicated a change notification means that you accept and approve the updated policy.

 

16. Contact Information Required for the Exercise of Your Rights and Requests

In order to exercise your rights over your personal data, you can access your account through the "My Account" section on the XOLVIE website and perform necessary changes, updates, and/or deletions. Additionally, every email sent to [email protected] is considered as a request and will be addressed and responded to accordingly. You can submit all your rights, including the right to request the deletion of your personal data, either through the platform or via email.

Application Method - Address for Application

In-person Written Application - Söğütözü, Yaşam Cd. No:7, 06560 Çankaya/Ankara

Notary - Söğütözü, Yaşam Cd. No:7, 06560 Çankaya/Ankara

Registered Electronic Mail (KEP) Signed with Secure Electronic Signature or Mobile Signature - [email protected]

From the electronic mail address previously notified to our company and registered in the system - [email protected]