Contents
1. Introduction and purpose of the Data Controller and this Privacy Notice
2. Contact Information
3.How Do We Collect Your Personal Data?
4.Which Personal Data Do We Collect and Process?
5.Why Do We Process Your Personal Data and What Is the Legal Basis for This Use (purpose of the processing)?
6.To Whom, Why and Where We Transfer Your Personal Data?
7.How long will you retain my data?
8.Principles relating to personal data privacy
9.Use of cookies
10.Use of Digital Platforms
11.Data security
12.Changes to this Privacy Notice
1. Introduction and Purpose of the Data Controller and this Privacy Notice
The GDPR enforcement puts the control of personal data collected by businesses in the hands of the individuals it belongs to, protecting the rights of EU residents.
The regulation delineates individuals’ rights to access, rectify, and restrict the processing of personal data, among other key provisions, and aims to unify privacy and security laws for all organizations operating within the EU.
In the context of this user document, we will be focused on how to implement the different rights once invoked by the Data Subjects.
Netmera provides customers (“Customers”) with an online cloud-hosted solution that allows them to analyze how their end users (“Customer End Users”) interact with Customers’ websites or mobile applications and communicate with Customer End Users through Netmera’s platform (the “Service”).
Netmera is committed to respecting your privacy and protecting your personal data. This privacy statement will inform you about Netmera’s roles in managing personal data, the categories of personal data it collects, the sources, the purposes of using personal data, the practices for disclosing personal data and how it protects personal data. This notice also tells you about your privacy rights and how you will use them.
This privacy statement governs, among other things, netmera’s privacy practices with respect to: netmera.com the website (hereinafter referred to as the “Site”), the relationship with representatives of business and organizational clients, representatives of other businesses and job candidates at Netmera.
2. Contact Information
Please direct all privacy questions, comments, complaints, or requests to exercise privacy rights to Netmera’s Data Protection Officer by using the following contact information:
Netmera Ahmet Başaran Eren Acar Başaran Kollektif Şirketi
BUDOTEK Dudullu OSB Mah. DES 2. Caddesi No:8 D:8, 34776 Ümraniye/İstanbul Turkey
Website: https://netmera.com
Email: privacy@netmera.com
Phone number: +908507578321
Personal data owners will be able to submit their requests regarding their rights stated in the GDPR and quoted above to our company. To apply, you can fill out and submit the Application Form available on this link.
3. How Do We Collect Your Personal Data?
We may collect and process your personal data personally, through our representatives, employees or through various channels in accordance with the regulations of our Personal Data Protection, Storage and Destruction Policy, the Law and other relevant legislation; through all kinds of written, verbal, electronic means, image recording, filling out other forms on the website or belonging to our Company, contracts, surveys, interviews, electronic/digital platforms and sites, online channels including social media platforms, e-mail, sales, marketing or support units, events or in other ways.
4. Which Personal Data Do We Collect and Process?
Personal Data Types:
• Identity Information Data that clearly belongs to an identified or identifiable natural person, which is processed partially or fully automatically or non-automatically as part of the data recording system, and contains information about the identity of the person. Name, surname, Turkish ID number, marital status, nationality, parents’ name-surname, date of birth, place of birth, gender and other identity information and driver’s license, identity card, passport and other documents containing this information, tax number, SSI number, signature information, vehicle license plate and other information.
• Contact Information Phone number, address, e-mail address, fax number, IP address, and other information.
• Customer Information Information that clearly belongs to an identified or identifiable natural person, processed partially or completely automatically or non-automatically as part of the data recording system; information obtained and produced about the relevant person because of our commercial activities and the operations carried out by our business units within this framework.
• Financial Information Personal data processed regarding information, documents and records showing all kinds of financial results arising in accordance with the employee-employer or other commercial relationship established by the Company with the Relevant Person and bank account number, branch code, bank card information, IBAN number, credit card information, financial profile, credit rating, asset data, income information and other information.
• Visual and Auditory Information Photographs and camera recordings, audio recordings and all data and other information containing such data.
• Personal Information All kinds of personal data processed for obtaining information that shall be the basis for the protection of the personal rights of natural persons who are in a working relationship with the Personal Data Owner.
• Location Information information that determines the location of the Relevant Person while using the Company vehicles by the Relevant Person within the framework of the activities and operations of the Company or the companies and institutions in cooperation with the Company; GPS location, travel data and other information.
• Family Members and Relatives Identity information and contact information, as defined above, about the Relevant Person’s family members, (e.g. spouse, mother, father, child), relatives and other persons who can be reached in case of emergency, within the framework of the activities and operations of the Company or the companies and institutions in cooperation with the Company or in order to protect the legal and other interests of the Company and the Relevant Person.
• Special Quality Personal Information Data specified under Article 6 of the Law (health data, biometric data)
• Request/Complaint Management Information Personal data related to the receipt and evaluation of the request or complaint addressed to our Company.
Processing Personal Data Our Company processes Personal Data for specific, explicit, and legitimate purposes. In this context, Personal Data may be processed.
5. Why Do We Process Your Personal Data and What Is the Legal Basis for This Use (purpose of the processing)?
We process your personal data for the following purposes:
Obtaining information about the actions you take during your visit in order to personalize your website experience, such as saving your preferences and settings, personalizing your website experience, and collecting statistics to help us improve and further develop our websites, products and services, such as recording information needed to provide access to you, such as passwords, IP addresses and browser settings, for the operation of a website when you use the online service or access one of our websites and to comply with security and legal requirements related to the operation of our site, Ensuring website security, website usage analysis, meeting the requests submitted via the contact form on the website, ensuring the membership of customers via the website and sending a welcome e-mail based on these memberships, calling our Company’s call center, providing call center and remote support services,
When you communicate with us online or offline in connection with a request for information to order a product or service, request support, or participate in a forum or other social networking tool, to fulfill your request, provide you with access to products or services, improve your user experience, provide support and contact you, Conducting advertising / campaign / promotion processes, conducting marketing analysis studies, conducting activities for customer satisfaction, conducting marketing processes of products / services and ensuring the delivery of commercial messages in this context, Providing products and services, Customizing the products and services offered in accordance with the demands, Updating and developing products and services due to customer needs / legal and technical developments, Carrying out company / product / service loyalty processes, Carrying out goods / service
purchasing processes, Carrying out goods / service sales and after-sales support services and return processes, Carrying out goods / service production and operation processes, Carrying out marketing processes, Sending e-bulletins and information letters to customers within the scope of marketing, Participating in trainings, seminars or organizations organized by our Company, Carrying out customer relationship management processes, Providing information to authorized persons, institutions and organizations in the context of fulfilling legal obligations and requests of administrative authorities, protecting the rights of the Company and its employees and defending these rights before authorized institutions and courts. In our relationships with customers or potential customers, solution partners and suppliers, they provide us with business contact information (such as name, business contact information, employee position or title, contractors, consultants, and authorized users) for purposes such as contract management, order management, delivery of products and services, provision of support, invoicing, payment, service, or relationship management.
To ensure the physical security and supervision of locations and to ensure workplace health and safety, we record people who visit our locations (name, identity and workrelated contact information) and use video surveillance technology for the safety and security of people and their belongings, as well as legal regulations.
Your personal data may be processed within the scope of the execution of our company’s human resources policies, conducting employee candidate / intern / student selection and placement processes, conducting the application processes of employee candidates, fulfilling the obligations arising from the employment contract and legislation for employees, conducting the processes of fringe benefits and benefits for employees, Defining employee user account, Tracking pool vehicles, Defining work computer/phone and e-mail address, Issuing company ID and meal card, Planning human resources processes, Conducting occupational health / safety activities, Conducting performance evaluation processes, Foreign personnel work and residence permit procedures, Conducting talent / career development activities.
Also, your personal data may be processed for Execution of emergency management processes, excarrying of information security processes, Execution of audit / ethical activities, Execution of risk management processes, Execution of training activities, Execution of access authorizations, Execution of strategic planning activities, Execution of activities in accordance with the legislation, Fulfillment of legal and contractual obligations, Follow-up and execution of finance, legal and accounting affairs, Ensuring physical space security, Execution of assignment processes, Execution / supervision of business activities, Receiving and evaluating suggestions for improving business processes, Organization and event management, execution of contract processes, execution of sponsorship activities, execution of supply chain management processes, execution of remuneration policy, execution of investor relations, Carrying out management activities Carrying out internal audit / investigation / intelligence activities, Following up requests / complaints, Providing information to authorized persons, institutions and organizations, Carrying out social responsibility and civil society activities.
6. To Whom, Why and Where We Transfer Your Personal Data?
Personal Data held by our Company may be transferred to the following real or legal Third Parties in or outside the country in accordance with the regulations of the Law on the transfer of data, with your explicit consent or by complying with the exceptions in the law (performance of the contract, legitimate interest, etc.) and the obligations required by the Law.
Consultants / Service Providers : Accounting Firm, Agencies, BES Firm, Life Insurance Firm, Legal Consultants, Health Insurance Firm, Payroll Company, Financial Consultancy Firm, etc,
Suppliers: Personal Data may be transferred to the companies/persons from whom services are received as specified in this article within the scope of the products, services, services received and the commercial, legal, contractual relationship established with these persons, limited to the data and purposes that will need to be processed.
Employees: In order to properly fulfill the duties undertaken by our Company and employees within this scope and to ensure communications, Personal Data belonging to other employees and other persons who are required to be in contact with employees in order to fulfill their duties may be shared with employees.
Event Sponsors: Personal Data may be transferred to sponsors to be used for the purpose of fulfilling sponsorship activities and obligations and limited to what is necessary to achieve this purpose.
Natural Persons or Private Law Legal Entities: Personal Data may be transferred to private law persons legally authorized to request information and/or documents from our Company, limited to their requests and legally required to be transmitted.
Business Partners and Cooperating Companies: Your data may be transferred to business partners that we have authorized, companies operating on behalf and account of our Company, in order to establish a business partnership with our representatives and / or to fulfill the purpose of the cooperation, in accordance with this purpose and limited to this purpose.
Shareholders/Affiliates: Personal Data may be shared with shareholders limited to the purposes of monitoring activities, determining and developing commercial strategies, auditing and informing shareholders.
Customers: Personal Data of employees may be shared with customers in order to provide products and services received by customers within the framework of the relationship between us and customers.
Judicial Authorities and Public Authorities: Personal Data may be transferred to legally authorized public institutions and organizations, limited to their requests and legally required to be transmitted.
Audit Firms
R&D Management Company
Banks and Financial Institutions Your personal data shall be processed by taking all necessary information security measures, provided that they are not used outside the purposes and scope notified to you, and shall be stored and processed for the legal retention period or, if no such period is stipulated,
for the period required by the purpose of processing. When this period expires, your personal data will be removed from our Company’s data streams by deletion, destruction or anonymization methods.
7. How long will you retain my data?
Our Company stores Personal Data in accordance with the periods stipulated in the laws and other legislation. If there is no time regulation in the laws and other legislation regarding how long Personal Data should be stored, Personal Data is processed for the period until the realization of the purpose of processing the Personal Data of the activity carried out when our Company processes that Personal Data, and then it is deleted, destroyed or anonymized.
8. Principles relating to personal data privacy
Our company acts in accordance with the principles stated below in all data processing activities. “lawfulness, fairness and transparency”, “purpose limitation”, “data minimisation”, “accuracy”, “storage limitation”, “integrity and confidentiality” and “accountability”.
9. Use of cookies
Netmera collects information using “cookie” technology, JavaScript tags and other technologies when End Users access the Websites. Netmera uses both session cookies (which expire once End Users close their browser) and persistent cookies (which stay on End Users’ computer until deleted by them) to help us collect information and to enhance End Users’ experience using the Websites. If End Users do not want us to place a cookie on their hard drive, they may turn that feature off on their computer.
For further information regarding cookies, please refer to the Entire Cookie Privacy Notice located at
https://netmera.com/cookie-policy-eu.
10. Use of Digital Platforms
Your personal data may be processed while your use of Digital Platforms to manage and operate the Website, to perform activities for optimizing and improving the user experience related to the Website and Application, to detect in what ways the Website is being used, to support and enhance the use of location based tools, to manage your online accounts and to inform you about the services offered near you.
In case you desire to benefit from the offered product and services, your personal data will be processed only to make you get such product and services.
12. What are Your Rights as Data Subjects?
Under the GDPR you are entitled to the following rights (further information is available under
https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens/my-rights_en):
● Right to withdraw consent (Art. 7 GDPR)
● Right of access (Art. 15 GDPR)
● Right to rectification (Art. 16 GDPR)
● Right to erasure (Art. 17 GDPR)
● Right to restriction of processing (Art. 18 GDPR)
● Right to data portability (Art. 20 GDPR)
● Right to object (Art. 21 GDPR)
Under the GDPR or national laws, these rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which We are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in the GDPR or in applicable national laws. We will inform you of relevant exemptions We rely upon when responding to any request you make.
In order to exercise these rights please contact the above mentioned contact addresses. Please specify which individual rights according to Art. 15 et seq. you want to exercise. For this purpose, We may have to confirm your identity before responding to your request. Please provide the following details so that We can identify you:
● Name
● Postal address
● E-mail address
If you send us a copy of your ID, please black out all other information apart from your first and last name and address. When sending copies of the ID card, it must be clear that this is a copy. Therefore, please make a note on the copy of the ID as following: “This is a copy”.
In order to be able to process your request, as well as for identification purposes, please note that We will use your personal data in accordance with Art. 6 para. 1 (f) of the GDPR as a legal obligation.
If you believe that We have failed to comply with data protection regulations when processing your personal data, you can lodge a complaint with the competent supervisory authority in accordance with Art. 77 GDPR. The competent supervisory authority can be identified according to the list provided under: https://edpb.europa.eu/about-edpb/board/members_en.
14. Data security
We take all appropriate technical and organizational measures to safeguard your personal data and to mitigate risks arising in connection with unauthorized access, accidental data loss, deliberate erasure of or damage to personal data.
In this respect our Company;
● Ensures data security by utilizing protection systems, firewalls and other software and hardware containing intrusion prevention systems against virus and other malicious software,
● Access to personal data within our Company is carried out in a controlled process in accordance with the nature of the data and on a strict need-to-know basis,
● Ensures the conduct of necessary audits to implement the provisions of the GDPR, in accordance with Article 32 of the GDPR,
● Ensures the lawfulness of the data processing activities by way of internal policies and procedures,
● Applies stricter measures for access to special categories of personal data,
● In case of external access to personal data due to procurement of outsourced services, our Company obliges the relevant third party to undertake to comply with the provisions of the GDPR,
● It takes necessary actions to inform all employees, especially those who have access to personal data, about their duties and responsibilities within the scope of the GDPR.
12. Changes to this Privacy Notice
We reserve the right to make changes to this Privacy Notice in order to provide accurate and up-to-date information concerning practices and regulations relating to the protection of personal data. Data subjects will be informed by appropriate means in the event of a substantial change to the Privacy Notice.
