Privacy Policy

This Privacy Policy regulates the principles followed by PALMİYE GLOBAL HAREKETLI YAPI SISTEMLERI SAN VE TIC. A.S (“Palmiye”) while collecting and using personal data on the website (“Website”) depending on the wishes of the user(s) (“User(s)”).

Personal Data That Can Be Collected

Depending on the users’ access to the Website and the actions to be taken by the User, Palmiye, may collect the following data on the Website;

  • Identity Information
  • Transaction Security Information
  • IP Information
  • Legal Transaction and Compliance Information
  • Contact Information
  • Request/Complaint Management Information
  • User Information
  • Incident Management Information
  • User Transaction Information

Palmiye will be able to collect other information that may be required for the performance of the services subject to the Website and which is considered to be personal data in accordance with the Law on Personal Data Protection and all relevant legislation. The user expressly consents to the processing of the data that he/she can share with Palmiye of his/her own accord within the scope specified in this Privacy Policy for the purposes specified in this Privacy Policy.

Data that have been irreversibly anonymized in accordance with Articles 3 and 7 of the Law on Protection of Personal Data will not be considered as personal data in accordance with the provisions of the said law, and processing activities related to this data will be carried out regardless of the provisions of this Privacy Policy.

Using "Cookies"

Palmiye automatically collects such data as sections visited and clicked areas during the users’ navigation on the Website. The data obtained by using “Cookie” technology are statistical information. The aim of this technology is to make the content of the sections visited by Users easier to access for the Users since their first visit to the site. Most browsers are designed to accept these “cookies”, which are primarily the technical communication file, but Users can always change the browser settings to ensure that the technical communication file does not arrive or that the technical communication file is notified when it is sent.

Palmiye is entitled to associate the behaviour of the Users on the Website with a “cookie” in the browser and define remarketing lists based on metrics such as the number of pages viewed, duration of visit and goal completion number in order to conduct on-line behavioural advertising and marketing. Afterwards, targeted advertising content may be displayed to the User on the Website or other sites in the display network based on interests.

Purpose of Using the Data

Palmiye may use the collected personal data in order for the User to benefit from the Website, to ensure its membership registration to the Website as the case may be, to enhance the services provided, to introduce new services and inform the Users of the new services, to make the necessary notifications in this regard, to contact the User and to perform the obligations arising from the nature of the services provided.

The personal data in question may be processed within the scope of Palmiye’s reporting and business development activities, and may be used for making statistical evaluations, creating databases and conducting market researches without disclosing the identity of the User. If the User also gives consent, the information in question may be processed, stored, transmitted to third parties for the purpose of direct marketing by Palmiye and its collaborators, and the User may be contacted for the purpose of making notifications regarding the promotion, maintenance and support activities of various applications, products and services through such information.

Palmiye will also be able to process and share personal data with third parties in accordance with Articles 5 and 8 of the Law on Personal Data Protection and/or in case of exceptions in the relevant legislation. Listed below are major situations:

Processing clearly prescribed by law,

Processing is necessary to protect the vital interests or bodily integrity of the data subject or a third person if the data subject is not in a condition to express his/her consent due to actual impossibility; processing is necessary for execution or performance of a contract between User and Palmiye, processing of personal data is necessary, provided that it is directly related to its performance; processing is necessary for compliance with legal obligations; personal data has been made public by the User itself; processing is necessary for the establishment, exercise or protection of a right; processing is required for the purpose of the legitimate interests pursued by Palmiye, provided that such interest does not harm the fundamental rights and freedom of the User.

Sharing Data

Palmiye may transfer User’s personal data and new data generated by using such personal data to third parties providing service to Palmiye for the performance of the services provided to the User within the scope of the Website, provided that such transfer is limited to the purpose of the provision of such services.  In this regard, for the purposes of improving User experience (including enhancing and customization), ensuring the security of the User, identifying fraudulent or unauthorized use, operational evaluation research, recovery of errors in relation to the Website or Palmiye services, and realizing any of the objectives set forth under this Privacy Policy or other privacy notes provided to the User, Palmiye may share the User data with third parties such as outsource service providers, hosting service providers, law firms, research companies and call centers.

User agrees in advance that aforementioned third parties may store the User’s personal data in the servers located in any part of the world, limited to the aforementioned purposes.

Right of Access of the User to the Personal Data and Correction Requests

By applying to Palmiye the User is entitled to:

  • earn whether or not his/her personal data have been processed;
  • request information as to processing if her/his data have been processed;
  • learn the purpose of processing of the personal data and whether use of data fit the purpose;
  • know the third parties in the country or abroad to whom personal data have been transferred;
  • request correction in case personal data are processed incompletely or inaccurately;
  • request deletion or destruction of personal data within the framework of the conditions set forth under the Law;
  • request notifying the third persons to whom the personal data are transferred, about the correction, deletion or destruction processes made in accordance with the relevant legislation,
  • object to occurrence of any result that is to her/his detriment by means of analysis of personal data exclusively through automated systems;
  • request compensation for the damages in case the person incurs damages due to unlawful processing of personal data.

The may submit his/her requests mentioned above by the methods available at   on our website. Palmiye may give its reasoned positive/negative response with regard to the above listed requests, in written form or digitally.  It is essential that the actions undertaken to answer the requests be free of charge.  However, in case the actions require a cost, a fee may be charged pursuant to the tariff specified by the Data Protection Authority pursuant to Article 13 of the Law on the Protection of Personal Data.

The User undertakes that information provided to Palmiye by himself/herself under this Privacy Policy is complete, accurate and up to date, and shall immediately update such information in case a change occurs with respect to such information. Palmiye shall not be held responsible in case the User does not update such information.

User agrees and represents that he/she may not fully benefit from the services undertaken by Palmiye in case he/she makes a request that will prevent Palmiye from using any of its personal data and that he/she shall be held liable for any matter arising in this regard.

Storage Period of Personal Data

Palmiye shall store the personal data provided by the User for the purposes of performing the obligations arising from the nature of the services, during the entire period in which the services are provided.

Additionally, Palmiye may keep the personal data, in case a conflict arises between Palmiye and the User, limited to the purpose of making the necessary defences within the scope of the conflict and for the period of time limitation specified by the applicable legislation.

Measures with respect to Data Security, Warranties and Liability

Subject to the terms set forth under the applicable legislation or this Privacy Policy, Palmiye undertakes to:

  • prevent the unlawful processing of personal data,
  • prevent the unlawful access to personal data,
  • take necessary technical and administrative measures for ensuring the appropriate security level for the purposes of preserving personal data and carry out the required audits.

In case the website provides links to other applications, Palmiye shall not be held liable for the privacy policies and contents of such applications.

Palmiye may not be held liable for damages that may arise from any use of personal data which falls within the scope of the above mentioned terms.

Amendments to the Privacy Policy

Users benefiting from the services provided on the Website shall be deemed to have read and accepted all terms herein. Palmiye  reserves the right to amend the provisions of the Privacy Policy without prior notice.  The updated Privacy Policy shall become effective on the date it is presented to the User in any manner.