CLARIFICATION TEXT

EROM Bilisim ve Telekomunikasyon Ticaret A.S. attaches importance to the confidentiality and security of your personal data that you share through the www.usetappy.com, www.usetappy.biz, www.usetappy.us sites, and the TAPPY application; We show maximum sensitivity to the principle of protection of fundamental rights and freedoms guaranteed by the Constitution, especially the privacy of private life. Accordingly, by the disclosure obligation, we have under the Law on the Protection of Personal Data No. 6698 and other relevant legislation entered into force with the Official Gazette dated 07.04.2016, we present the following issues for your information.

1.      Definitions

Explicit Consent: Consent on a specific subject based on information and expressed in free will.

 Anonymization:   Making personal data unlikely to be associated with any identified or identifiable real person in any way even when personal data is paired with other data.

Member: means a person who receives or intends to receive online psychological counseling services through the website and/or mobile application.

Consultant: Itrefers to persons who provide online psychological counseling services through the website and/or mobile application and who have the title of clinical psychologist.

Person Concerned(Relevant Person):  A Real person whose personal data is processed.

Law: Law No. 6698 on the Protection of Personal Data, which entered into force with the Official Gazette dated 07.04.2016

Personal Data: Any kind of information belonging to a real identified or identifiable person.

Processing of Personal Data: All kinds of processes performed on personal data including obtaining, recording, storing, keeping, changing, re-arranging, disclosure, transmission, acquisition, making available, classification or prevention of use in whole or in part, automatically or in non-automatic ways, being part of any data recording system.

Clinical Psychologist: A professional who has completed a master's and/or doctorate in clinical psychology on the basis of undergraduate education in Psychology or Guidance and Psychological Counseling or who has a doctorate in clinical psychology upon a master's degree in clinical psychology. 

Board: It means the Personal Data Protection Board.

Authority: It means the Personal Data Protection Authority.

Data Processor: A natural or legal person who processes personal data on his behalf on the basis of the authority conferred by the data officer.

Data Recording System: Recording system in which personal data is processed by structuring these according to certain criteria

Data Controller: It refers to real or legal person responsible for identifying the purposes and means of personal data processing and installing and managing data recording system.

2.      Who is the Data Controller?

 www.usetappy.com, www.usetappy.biz, www.usetappy.us sites and TAPPY application ("Platform"), the Data Controller regarding all kinds of personal data you share during the stage of membership to the Platform and on the communication screen through the Platform is EROM Bilişim ve Telekomünikasyon Ticaret A.Ş. Şti. registered with the Istanbul Trade Registry with the number 274304-5 with the head office address at Vişnezade Mahallesi, Süleyman Seba Caddesi, No:79/1 Beşiktaş.     

3.      For What Purposes Do We Process Your Personal Data?

Our Company may collect personal data from parties such as website and/or mobile application users, members, employees, potential employees, potential users, business partners and suppliers, in categories such as name, surname, date of birth information, contact information, resume information, user information, user transaction information, transaction security information, legal transaction and compliance information and marketing sales information.

Personal data processed through the  www.usetappy.com, www.usetappy.biz, www.usetappy.us and TAPPY application:

-         Name, surname, date of birth, gender, mobile phone, e-mail address, diploma information, CV information (education, experience and academic publication information), social media information, biography, titre and bank account number, payment information such as IBAN, navigation information obtained during the use of the website and mobile application, IP address, browser informationfor theconsultant .

-         The personal data processed for themember are the name, surname, nickname, e-mail address, navigation information obtained during the use of the website and mobile application, IP address, browser information and the questionnaires and form information participated with the consent of the Relevant Person, the answers and comments shared for the purpose of evaluating the Consultants, and the data related to payment and transaction security in case of online payment transactions.

-         Personal data processed for non-member Platform users is their name, surname, e-mail address and notes on the subject they want to communicate with, if they contact us via the "contact" screen within the Platform. 

-         If the Person concerned prefers, it is also possible to make a membership from the person's social media accounts. In this case, the user name of the relevant social account of the relevant person is also processed. We would like to emphasize that we do not have access to the password and other confidential information of the relevant social media account.

The Personal Data collected are processed for the following purposes.

·     Performing membership transactions to the site and/or mobile application, matching the Member and the Consultant in the most accurate way in line with the purpose and need, and providing the best service for online psychological counseling services to the members,

·     To provide special advertising, campaigns, advantages and other benefits to members for sales, promotion and marketing activities to be carried out to increase the quality of services and products, to provide information processing requirements, the necessity of support services, to convey the necessary information to the members regarding these services and products, to measure user satisfaction, to receive your opinions and suggestions about new services and products and to contact the members when necessary, and informing members,

·     Increasing the quality of service and making the best use of the services provided through the website and mobile application of the Relevant Person, detecting system errors and performing performance monitoring, improving system functioning, providing maintenance and support services and backup services,

·     In case of using the online payment option, the payment transactions are carried out in accordance with the relevant legislation,

·     Carrying out the Company's activities in accordance with the law and relevant legislation,

·     Carrying out the financial, accounting and legal affairs of the company,

·     Execution and supervision of the company's business activities,

·     carrying out storage and archiving activities,

·     Carrying out the strategic planning and R&D activities of the company,

·     execution of investment processes,

·     Execution of Management Activities

4.   What Legal Reasons Do We Rely On When Processing Your Personal Data?

While processing your personal data, we are based on the provisions of the Constitution on fundamental rights and freedoms, the Law on the Protection of Personal Data No. 6698 and related regulations and communiqués, Board decisions, the Regulation on the Procedures and Principles for the Regulation of Publications on the Internet No. 26716, the Law on the Regulation of Electronic Commerce No. 6563 and other relevant legislation and case law.

However, the Company respects the following principles adopted in the Law with great importance and meticulousness:

- Personal data processing activities are in accordance with the law and the rule of honesty,

- Ensuring that personal data is accurate and up-to-date when necessary,

- Processing of Personal Data for Specific, Clear and Legitimate Purposes

- Being Relevant with, Limited to and Proportionate to the Purposes for which it is Processed

- Maintaining the time required for the purpose foreseen in the relevant legislation or for the purposes for which it is being processed.

5.   How Long Do We Retain Your Personal Data?

EROM Bilişim ve Telekomünikasyon Ticaret A.Ş  pays attention to keep the Personal Data subject to this Clarification Text for the period stipulated in the relevant legislation or for the period required for the purpose for which they are processed.In this context, our Company initially determines whether a period of time has been set out for the retention of personal data in the relevant legislation; if it does, it complies with this period of time; otherwise, it retains personal data for the period of time required for the purpose for which they are processed.

In the event that the period expires or the reasons requiring its processing disappear, personal data are destroyed in accordance with the Law. The retention periods of Personal Data are regulated in the Data Retention and Destruction Policy on the website.

6.   In Which Ways Do We Collect Your Personal Data?

Your Personal Data may be collected verbally, in writing, or electronically through our website, social media channels, parties with whom we have a business relationship, and/or receive services as a complement to our activities, contracted organizations, and other similar channels by automatic or non-automatic methods.  Your personal data will be stored in electronic and/or physical environments. In order to ensure that your personal data provided and stored by our Company is not exposed to unauthorized access, not to be manipulated, not lost and damaged, all technical measures stipulated and required in the relevant legislation are taken and security improvements are implemented.

7.   To Whom Can We Transfer Your Personal Data?

Your Personal Data, within the framework of the purposes set out in Article 3,

-         to the Company shareholders, employees, business partners,

-         Legal, financial and tax consultants, auditors, consultants, organizations or persons with whom the Company receives services in relation to its commercial activities,

-         Consultants serving on the platform (In case the members purchase sessions, the name and surname of the Member ("Client") or, depending on the preference of the Member, the "Nickname" data)

-          and to regulatory and supervisory institutions and public institutions or organizations that are expressly authorized to request personal data in-laws.

-         The personal data of the consultants can be shared publicly through the Platform's social media accounts and website.

If your personal data is transferred abroad, sufficient protection must be provided in the foreign country under Article 9 of the Law to which personal data will be transferred, and if there is no adequate protection, consent from the person concerned, Data controller in Turkey and in the relevant foreign country will be observed to undertake adequate protection in writing and to obtain permission from the Personal Data Protection Agency. 

Your Personal Data is stored in the cloud system called MongoDB Atlas, headquartered in Frankfurt, Germany. In the event that this Clarification Text and the "Clarification Text Abroad" on the website are accepted, explicit approval is deemed to be given to the storage of personal data in the foreign-based cloud system and thus to transfer it abroad. You can get detailed information about the subject from the text of "Clarification Text Abroad" on the website.

8.   Under What Conditions Can Your Personal Data Be Processed Without the Need for Explicit Consent?

Your Personal Data may also be processed without seeking your explicit consent in the following cases:

-         In the event that it is clearly stipulated in the laws.

-         In the event that the person who cannot explain his/her consent due to the actual impossibility, or is not legally valid at his/her discretion, or is obliged to protect the life or physical integrity of the person himself/herself or someone else.

-         In the event that the processing of personal data belonging to the parties of a contract, is necessary provided that it is directly related to the conclusion or fulfillment of that contract,

-         It is mandatory for us to fulfill our legal obligations as a data controller;

-         In the event that it is publicized by the person concerned himself/herself.

-         In the event data processing is required for the establishment, exercise or protection of a right,

-         In the event that data processing is required for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the relevant person are not damaged.

9.      Personal Data What are the Rights of Personal Data Owners Enumerated in Article 11 of the Law ?

Personal Data owners have the following rights in accordance with Article 11 of the Law .

-         To learn whether your personal data is processed or not,

-         Request the relevant information if her/his personal data has been processed,

-         Learn the purpose of the processing of her/his personal data and as to whether those have been used for the intended purpose,

-         To have the knowledge of the third parties to whom the personal data is transferred domestically or overseas,

-         Request the rectification of the data in the event they are processed incompletely or inaccurately,

-         To request the rectification of any incomplete or incorrectly processed personal data, as well as the notification of any transaction carried out in this context to any third parties to whom the personal data are transferred,

-         To request the erasure or destruction of the personal data which were processed under the provisions of the Law and other related laws, upon the disappearance of reasons which require its process and the notification of the process performed within this context to third persons to whom the personal data has been transferred,

-         To express opposition to any negative effects brought on by processed data only being examined by automatic systems,

-         To claim compensation in case of suffering loss due to illegal processing of the personal data.

10.  In Which Way Will Personal Data Owners Be Able to Use Their Rights?

In the event that the Relevant Person requests information on the above-mentioned issues;

-         The Data Owner can fill out the Application Form on our website and/or application and send it to us.

-         They can forward their questions about the subject to the "destek@usetappy.com" e-mail address.

-         He can send a notification through a notary public and convey the issue he wants to get information about.

-         It may prefer other methods determined and/or to be determined by the Board.

The application request of the Relevant Person will be responded to as soon as possible and within thirty (30) days at the latest in accordance with the law. However, if the transaction requires an additional cost, our Company reserves the right to charge a fee in accordance with the Law over the tariff determined by the Personal Data Protection Board.

* Due to legislative changes, current case law provisions, innovations in judicial decisions, and other reasons within this Clarification Text, changes may be made without any notification to users. For this reason, we recommend that the said text be reviewed and checked periodically.