Protection of Personal Data

OCTET EXPRESS ÖDEME KURULUŞU A.Ş. (OCTET EXPRESS PAYMENT ORGANIZATION JOINT STOCK COMPANY) DISCLOSURE TEXT ABOUT PERSONAL DATA PROCESSING

As Octet Express Ödeme Kuruluşu A.Ş. (Octet Express Payment Organization Joint Stock Company) (“Octet”), we attach great importance to the protection of your personal data in connection with the transactions you carry out through the Octet portal, the website with www.octet.com.tr extension and other related applications (collectively, “Octet Service Platforms”). 

In this context, this Disclosure Text (“Disclosure Text”) was prepared by Octet, the data controller, the information of which is set forth below, in accordance with Law No. 6698 on the Protection of Personal Data (“Law”) and the Communiqué on the Procedures and Principles to be Followed in Complying with the Disclosure Obligation, and is intended to inform individuals using the Octet Service Platforms about the personal data processing activities carried out by Octet. 

Data Controller 

Trading Title : Octet Express Payment Organization Inc.
Address : YTÜ Yıldız Teknopark Maslak Yerleşkesi Maslak Mah. Taşyoncası Sk. Maslak 1453 Sitesi No: 1G İç Kapı No: B12 Sarıyer/İstanbul
Tax Office and Number : Maslak Tax Office/6330502741
Mersis (Central Registration System) No. : 0633050274100012
Commercial Register Number : Istanbul Commercial Register Directorate/8228-5
Telephone : +90 212 275 2305 / +90 850 360 1511
Website : www.octet.com.tr 
Company Email  : info@octet.com.tr

I. PURPOSE OF PROCESSING PERSONAL DATA

We process your personal data on the basis of the following legal bases in order to fulfill the purposes set out below:

Legal Bases Purposes
Processing of personal data of the parties of a contract is necessary, provided that it is 

directly related to the establishment or performance of the contract 
  • In order to provide services to users under the activity authorization;
  • So that Octet Service Platforms may be activated;
  • In order to provide the necessary support for applications submitted to Octet;
  • In order to send notifications to persons using Octet Service Platforms regarding the transactions they have performed or will perform;
  • In order to communicate with applicants in accordance with the applications submitted to Octet by calling them on their telephone numbers, via short messages (SMS) or email messages;
  • In order to maintain relationships with users;
  • In order to collect fees and issue invoices.
Fulfillment of our legal obligations
  • To ensure Octet’s compliance with the obligations brought by the legislation, the institutions whose decisions Octet is obliged to comply with or the business partners with whom it has concluded contracts, including in particular by Law No. 6493 on Payment and Securities Settlement Systems, Payment Services and Electronic Money Institutions and Law No. 5549 on Prevention of Laundering the Proceeds of Crime and Law No. 6415 on Prevention of Financing of Terrorism and Law No. 7262 on Prevention of Financing the Proliferation of Weapons of Mass Destruction and Law No. 5651 on Regulation of Publications on the Internet and Combating Crimes Committed through These Publications and MASAK regulations and CBRT instructions;
  • Identification and confirmation of identity;
  • To ensure the control and accuracy of the information shared;
  • In order to ensure the security of the Octet Service Platforms and other persons/companies conducting transactions on the Octet Service Platforms;
  • In order to assist official authorities in all judicial proceedings, including investigations and prosecutions.
The data processing is strictly necessary for the establishment, exercise or protection of any right
  • To be able to establish the rights of Octet;
  • To be able to verify that individuals using the Octet Service Platforms are acting in accordance with the contracts entered into with Octet, the Terms and Conditions of Use of the Octet Portal and the policies accepted in the context of membership transactions, in order to clarify objections and resolve problems. 
The processing of data is compellingly necessary for our legitimate interests provided that your fundamental rights and freedoms are not violated
  • To be able to carry out marketing and promotional activities;
  • To implement the payment service;
  • To be able to monitor the processes;
  • To be able to send notifications regarding the transactions when necessary;
  • To manage and maintain the information technology infrastructure;
  • To control the creditworthiness and solvency of the users;
  • To ensure the satisfaction of users of Octet Service Platforms;
  • To be able to help persons using Octet personalize and improve their experience.;
  • To be able to identify potential users;
  • To manage and maintain the information technology infrastructure;
  • To be able to develop Octet’s marketing activities and advertising;
  • In order to improve Octet’s business performance.

II. PERSONAL DATA PROCESSED

During your use of Octet Service Platforms, the following data is processed, which varies depending on the purpose of use:

Individuals who visit the Octet website and Portal or call Octet by phone
  • Information sent by devices;
  • Telephone calls that are recorded to ensure the quality of the service and the security of the service;
  • Information about the course of the use of the system; 
  • Data about the pages accessed;  
  • IP information;
  • Device ID or identifier;
  • Device type;
  • Geographical location information;
  • Computer and connection information;
  • Mobile network information;
  • Page view statistics;
  • Website traffic information; 
  • URL redirect;
  • Advertising data, and standard web log data;
  • Anonymous information;
  • Additionally, the first and last names, the contact information of the individuals who contacted  Octet  by filling a form on https://www.octet.com.tr/iletisim/ extension and other information these individuals submitted through this section. 
Octet customers, users of Octet’s Service Platforms (“Users”), signatories and employees of Users and other third parties associated with Users
  • If you are a real person who is an owner of a commercial enterprise: Your identity/passport information, tax identification number and tax office information, address, information about your business and profession, your specimen signature, contact information (address, email address, phone and fax number), financial information including your bank account information, credit card number, transaction information, website URL information of your business, Octet Service Platforms’ login information identity/passport information; name-surname, job title, contact information (address, email address or phone number) and specimen signature of your signatories;  identity/passport information, name-surname job title, contact information (address, email address or phone number), specimen signature of your employees who communicate with Octet, and other information you provide to Octet during the application or your use of Octet Service Platforms.
  • If you are a legal entity , in addition to the above information: Identity/passport information, name and surname, job title, contact information (address, email address or phone number) and specimen signature of your signatories; name and surname, job title, contact information (address, email address or phone number), specimen signature of your employees who communicate with Octet, and other information you provide to Octet during the application or during your use of Octet Service Platforms.
  • If you are a legal entity user, in addition to the above information: First and last names of all real person shareholders of your company and identity/passport information, address, telephone number, details of work and profession, specimen signature, contact information (address, email address, telephone and fax number) of your real person shareholders who directly or indirectly hold shares of more than 25%.
  • If you are a legal entity, in addition to the above information: Identity/passport information and specimen signature of your legal entity shareholders’ authorized signatories who directly or indirectly hold more than 25% of your company’s shares.
  • If you are an authorized representative authorized by Users to use the Octet Portal, in addition to the above information: Identity/passport information, contact information (email address and phone number) and address, business and professional information, specimen signature, Octet Service Platforms’ login information, and other information you submit to Octet during your use of Octet Service Platforms.
Recipients performing payment transactions through the Octet Service Platforms and their agents authorized by them to use the Octet Portal, as well as third parties to whom money transfers are made through the Octet Service Platforms
  • Name-surname/title, identity/passport information, financial information, including bank account information, tax identification information, credit card number, transaction information, your contact information (address, email, and phone number), Octet Service Platforms’ login information, and other information you submit to Octet during your use of Octet Service Platforms.

III. METHOD AND LEGAL BASIS FOR COLLECTING PERSONAL DATA

Personal data belonging to persons using Octet Service Platforms is collected through contracts, cookies, and information they provide to Octet or generated by Octet during the use of Octet Service Platforms, in whole or in part, by automated or non-automated means, if it is expressly provided for by law, if it is necessary to process personal data of the parties to the contract (provided that it is directly related to the establishment or performance of a contract), if the personal data is publicized by the person concerned, if it is mandatory for Octet to fulfill its legal obligations, if the data processing is mandatory for the establishment, exercise or protection of a right, if the data processing is mandatory for the legitimate interests of Octet, provided that it does not harm your fundamental rights and freedoms. 

If none of the above legal grounds apply and this is required, your express consent will be obtained. 

For information on the purpose for which your personal data is used, please refer to the section “I” in this Disclosure Text. 

IV. TRANSFER OF PERSONAL DATA

Based on the legal grounds set out under section “III” and in accordance with Articles 8 and 9 of the Law and applicable legislation, your personal data may be transferred to public institutions and organizations, including regulatory and supervisory institutions and judicial authorities, judicial authorities and law enforcement agencies, Octet officials, institutions belonging to the Octet corporate family or financial institutions that have a contract with Octet, service providers, business partners, suppliers, external service providers, main dealers and parent companies to which dealers are affiliated, payment parties, lawyers, tax and financial advisors, credit bureaus and collection agencies and other users, depending on how you use Octet Service Platforms. Octet takes all reasonable steps to protect your personal data and makes every effort to ensure that third parties to whom it discloses personal data also take these steps.

V. YOUR RIGHTS AS OWNER OF PERSONAL DATA

As a data subject, you have the following rights under Article 11 of the Law:

  • To know whether or not your personal data is being processed;
  • If your personal data is being processed, to request information regarding the processing of your personal data;
  • To know the purposes for which your personal data is processed and whether such data is used in accordance with the intended purpose;
  • To know the third parties to whom your personal data is transferred, whether in the country or abroad;
  • To object to the processing of your personal data or request its restriction;
  • To request the rectification of your personal data in the event of incomplete or inaccurate processing;
  • To request the erasure or destruction of your personal data under the conditions set forth in Article 7 of the Law;
  • To request the notification to the third parties, to whom your personal data is transferred, of the transactions carried out in the exercise of your rights of rectification, erasure or destruction in the aforementioned articles;
  • To object to the occurrence of a result to your detriment through the analysis of your processed data exclusively by automated systems;
  • To claim damages if you have suffered damage as a result of the unlawful processing of your personal data.

You can exercise your rights regarding your personal data mentioned above by applying physically to YTÜ Yıldız Teknopark Maslak Yerleşkesi Maslak Mah. Taşyoncası Sk. Maslak 1453 Sitesi No: 1G İç Kapı No: B12 Sarıyer/İstanbul, as specified in the introduction section of this Disclosure Text, or by applying to Octet online at info@octet.com.tr or by other methods to be determined by the Personal Data Protection Board. 

In order for your applications to be evaluated, the application must be completed in full with the following in accordance with the relevant legislation: 

(a) First name, last name and signature if the application is in writing; 

b) Turkish Republic identification number for citizens of the Republic of Turkey, citizenship, passport number or identification number, if any, for foreigners; 

c) Residential or work address for serving notices; 

ç) Email address, telephone and fax number for serving notices, if any; 

(d) Subject matter of the request.

In order for your requests to be considered appropriately, you must include with your request the information and documentation regarding the subject and, as noted above, a copy of your official identification so that we can recognize you. 

Octet will complete the applications no later than 30 (thirty) days from the date of receipt. Octet reserves the right to charge a reasonable fee for the requests you submit, in accordance with the tariff determined by the Personal Data Protection Board. 

VI. UPDATES

Octet reserves the right to update or modify this Disclosure Text at any time. In this regard, updates and changes to this Disclosure Text will be posted on the Octet website.

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