PRIVACY POLICY

This Privacy Policy contains the terms and conditions of use of personal data shared with Paksam Fotoğraf ve Bilişim Teknolojileri Ticaret Anonim Şirketi(“Company”) by users/members/visitors (“Data Owners”) of the web site www.photier.com (“Site”)/Mobile applications or the personal data collected by the Company during the operation of the Site/Mobile applications during the Data Owner’s use of the Site.

Which Data are Processed?

Your personal data processed by The Company is categorized according to (i) the Law for Protection of Personal Data (“Law”); and (ii) General Data Protection Regulation(“GDPR”) as provided for in the following. Unless expressly stated otherwise, the terms "personal data" under the terms and conditions of this Privacy Policy shall cover the following information.

• Identity and Contact Information: name, surname, phone, birthdate, gender, address, workplace information, e-mail address
• Information About the User, User Transaction Data and Financial Information: membership data, membership ID number, data on the date and time of using The Company services, reasons for communication with The Company, terms you use when searching at the Site and filtering preferences, scores and remarks, preferences, pages you have visited, errors during use, invoice and payment information, balance information (such as bills sent to the user and vouchers showing payments received from users, such as invoice number, invoice amount, invoice date, etc.).
• Location Information: Specific or approximate location information about your location, such as GPS data, that we have received while using the services of The Company.
• Transaction Security Information: log in credential information, password information
• Marketing Information: reports and evaluations showing your habits and likes, notifications, targeting information, and information on cookie records, etc.
• Complaint Management Information: Complaints you make through the Site
• Risk Management Information: IP address
• Face Scan Information:hair, face posture, gender, age, facial hair, makeup, facial expressions, emotional reflection, accessory, eye-mouth-nose alignment, Identifying marks / stains

• User generated Information: createdevents, event information (name, location, date), shared photos

Data anonymized under Articles 3 and 7 of the Law will not be considered as personal data in accordance with the provisions of the said law and the processing of such data will be conducted without being bound with the provisions of this Privacy Policy.

Please apply to the Company whether your data is being processed.

What is the Purpose of Use of Your Data?

Personal data you share with The Company may be processed for making your membership registration on the Site, updating the membership registration, conducting commercial activities including improvement of the services offered by The Company and providing new services through the Site, and providing you with information on these activities, determining and implementing commercial and business strategies, ensuring legal and commercial security of the persons who are in business relationship with The Company and providing necessary information to you and fulfilling responsibilities arising from the nature of these activities to allow you to utilize the services provided through the Site or via the Mobile Application.

Such personal information may be used to communicate with you or to improve your experience on the Site or on the mobile application (such as managing the communication management process, conducting research on customer satisfaction, etc.), and also to perform internal reporting and business development, and to make various statistical evaluations without disclosing your identity, to create database and perform market research. This information can be processed, stored and transmitted to third parties by The Company for the purposes of direct marketing, digital marketing, remarketing, targeting, profiling and analysis, and you may be contacted for promotion, maintenance and support activities on various applications, products via the aforementioned information.

The Company will also be able to process and share your personal data with third parties, pursuant to Articles 5 and 8 of the Law, and/or in the presence of exceptions under the applicable law, without obtaining your consent as Data Owner. Such conditions mainly include:

• If clearly prescribed in the law,
• If necessary to protect the life or physical integrity of a person or third parties, where the person is unable to explain his consent or the consent of such person is not legally accepted,
• If the processing of personal data is required for performance or execution of an agreement between the Data Owner and The Company,
• If it is compulsory for The Company to fulfill its legal obligations,
• If it has been revealed to the public by the Data Owner,
• If its compulsory for the establishment, use or protection of a right,
• Data must be processed for the legitimate interests of The Company, provided that it does not jeopardize fundamental rights and freedoms of the Data Owner.

As mentioned above, The Company will be able to use cookies and transmit data to third parties for processing purposes only to the extent required by such third party to generate analysis services based on the data in question. The technical communication files mentioned above are the small text files that the Site sends to the browser of the Data Owner for storage in the main memory. The technical communication file makes the use of the Site more convenient by storing status and preference settings for the website. The technical communication file is designed and used for helping to generate statistical information on the number of people who use internet sites in what proportion of the time, the number of times a person visits a website, the number of times they have visited a particular website, the amount of time they have stayed at the site; and to dynamically generate advertisements and content from user pages specially designed for users. The technical communication file is not designed to receive any other personal data from the main memory. Most browsers are configured to accept the technical communication file by default; however, users can always change the browser settings so that the technical communication file is blocked or a notification is made upon receiving a technical communication file.

Who Can Access to Your Data?

The Company may transfer your personal data and any new data obtained using such personal data to third party suppliers, business partners and clients for the purpose of fulfilling the objectives set out in this Privacy Policy, in a limited scope for providing such services. In this context, The Company will also be able to transfer your personal data to The Company’s shareholders, subsidiaries, public authorities and private legal entities. Anonymized or limited data transfer can be made to third parties and suppliers who benefit from the services of our business partners and further approval can be obtained in such cases.

The Company may share your personal data with third parties such as outsourced service providers, hosting service providers including those that send e-mails and SMS’, and law firms for improving your user experience (including improvement and personalization), security assurance, detection of fraudulent or unauthorized use, investigation of operational evaluation, troubleshooting of site services and any other purpose stated in this Privacy Policy.

As Data Owner, you acknowledge that you agree in advance to this effect that third parties may store your personal data on their servers at any place in the world, provided that they are limited to the above-mentioned purposes.

As Data Owner, you undertake that your personal data which this Privacy Policy covers is complete, accurate and up-to-date and that you will update it immediately in the event of any change to this information. If you fail to update the information, The Company will not have any responsibility.

As Data Owner, you acknowledge that you may not fully utilize the operation of the Site or the Mobile application in the event that you made a claim that would result in the inability of The Company to use any of your personal data, and you declare that you will bear all responsibilities arising therefrom.

As Data Owner, you acknowledge that we work with third party suppliers and service providers during the collection of your Face Scan Information data. But after the data is collected, your Face Scan Information data is not shared with any third party. Your data on Face Scan Information will be shared to business partners, suppliers and customers limited to statistical data for the purpose of achieving the purposes set out in the Privacy Policy.

For How Long Do We Store Your Data?

Your personal data you share with The Company will be kept for the period required for the fulfillment of the purposes set out in this Privacy Policy and for the time limits set forth in the applicable legislation. In addition, your personal data may be retained for a limited purpose of defending against any dispute that may arise between you and The Company.

How Do We Ensure the Security of Your Data?

The Company takes necessary technical and administrative precautions and has necessary audits performed to ensure prevention of

• illegal processing of personal data,
• illegal access to personal data, and
• protection of personal data

for the purpose of providing the minimum level of security by considering appropriate conditions and costs set out under the applicable legislation or expressed in this Privacy Policy.

In addition, The Company does not disclose any personal data obtained from you to third parties in contravention of the provisions of this Privacy Policy, the Protection of Personal Data Law and GDPR and does not use it for purposes other than processing.
For links located in the Site to other applications, The Company does not bear any responsibility for the privacy policies and content of such applications and advises that you review them.

To Which Parties and For What Purposes Your Personal Data May Be Transferred

Your personal data may be shared with and transferred to ongoing business partners, intermediary service providers, real or legal entities that provides various services, suppliers and consultants, for purposes such as fulfilling the abovementioned data processing Purposes, sending electronic mails, processing, storing and protecting data, in line with legal limitations and to the extent of the necessity and purpose of such transfer, in line with the abovementioned Purposes and in accordance with the Articles 8 and 9 of the Law numbered 6698.

Furthermore, personal data may be shared with public bodies or institutions authorized to demand and obtain such data out of legal necessity.

Amendments to the Privacy Policy

This Privacy Policy may be updated from time to time in order to comply with any changes in requirements and the legislation.

OVERSEAS DATA TRANSFER

Personal data mentioned above may be transferred to real or legal entities residing in Turkey as well as abroad on the condition that they shall be processed in Turkey or processed and stored outside Turkey (to countries that have sufficient measures regarding the protection of personal data and/or to countries falling short of such measures provided that the conditions specified by the Personal Data Protection Law shall be satisfied).

COOKIES POLICY

As the Company, we use cookies to enable the most efficient use of our internet sites and to improve your user experience. If you do not choose to use cookies, you can delete or disable cookies from your browser's settings. However, we would like to remind you that this may affect your use of our internet sites. We will assume that you accept the use of cookies on our internet sites unless you change your cookie settings from your browser. You can access the policies regarding the collected data in the Privacy Policy in our internet site.

What are cookies and why are they used?
Cookies are small text files stored on your device or on network server through browsers by internet sites that you visit. The main objective of using cookies on our site is to improve the functionality and performance of our internet sites, to improve the services offered to you, to improve our internet sites and to offer new features through our site and to customize the features according to your preferences, and to ensure the legal and commercial security of our internet sites, you and The Company.

Types of Cookies Used on Our Internet Sites

Session cookies: Session cookies are temporary cookies that are used during your visit to our internet site, which are deleted after you close the browser. The main purpose of using such cookies is to ensure that the Internet sites function properly during your visit. For example; enabling you to fill online forms consisting of more than one page.

Persistent Cookies: Persistent cookies are types of cookies that are used to increase the functionality of internet sites and provide a quicker and better service in our sites. Such cookies are used to remember your preferences and are stored on your device via browsers. Some types of persistent cookies; can be used to present customized offers to you, taking into consideration such factors as your intended use of the internet site.

Through the use of persistent cookies, if you visit our internet site through the same device, your device will be checked for a cookie placed by our internet site in your device, and if so, it will be understood that you have visited the site before and content to be presented to you will be determined accordingly.

Categories of Cookies Used in Our Website

Technical Cookies: Technical cookies are used for the operation of the website, and the pages and areas of the website that are not working are detected.

Authentication Cookies: In case visitors use their passwords to login to the internet site, such cookies will prevent the user from re-entering their password on every page by determining that the visitor is the site user on each page visited by the visitor on the internet site. Customization Cookies: These are cookies used to remember users' preferences when visiting different pages of different websites. For example, remembering your preferred language preference.

Analytical Cookies: These are cookies that enable the production of analytical results such as the number of visitors of the website, the pages that are displayed on the website, the time of visit of the websites, and scrolling movements of the pages of such websites.

Cookies Used in Our Website

Cookie Description, Duration and Preferences Analytical Cookies

Advertisement: Used to show behavioral and target-oriented ads to visitors. 

Google analytics: Such cookies provide the collection of all statistical data in such a way as to improve the presentation and use of the site. Google provides us to understand the users better, by adding societal statistics and data regarding the relevant users, to the related information. Our site uses Google Analytics cookies. Such cookies and collected data are transferred to Google servers in the U.S. and are maintained in accordance with Google's data protection guidelines. You can click here to learn more about the principles of Google's analytics data processing activities and the protection of personal data. 2 years from last update. Cookie Control https://tools.google.com/dlpaqe/gaoptout

Can the Use of Cookies Be Prevented by Data Owners?

 You have the option of customizing your preferences for cookies by changing your browser's settings.