PRIVACY POLICY

EROM Bilişim ve Telekomünikasyon Ticaret A.Ş, hereinafter referred to as “EROM Bilişim”,   has adopted the principle of protecting the privacy of its website (www.usetappy.com, www.usetappy.biz, www.usetappy.us) and mobile application (TAPPY application) users, members and visitors. Therefore, this privacy statement (“Privacy Policy”) explains what kind of information about users is received by EROM Bilişim, how it is used and protected while using our website and mobile application. In addition, within the framework of this Privacy Policy, it is stated how you can control the accuracy of this information and how you can have this information deleted by contacting EROM Bilişim when you want. EROM Bilişim will carry out all kinds of processes necessary for the processing and use of the said information in accordance with the current and valid data protection regulations.

We would like to emphasize that the information to be used and processed by a certain person is only possible if this person enters data at his request or gives his express consent in this regard. Entering data or giving express consent in this regard is an indication that the person agrees with the conditions stated below.

A.    Purpose

-         The purpose of using the website and mobile application (“Platform”) is to mediate the best way to provide online psychological counseling services to people who need and demand it. We define experts who provide consultancy on the Platform as “Consultants”, real persons who receive consultancy as “Counselee”, and each person who is a member of the Platform as “Member”. In order to carry out the activities of the Platform, some personal data regarding the Consultant and the Member are processed and preserved. Although these are detailed in the Clarification Text, the summary is as follows: Some of the consultant's identity information, education information, academic publication information, professional experience information, CV information, bank and payment information. Some identity information of the Counselee, answers and comments shared for the purpose of evaluating the Consultants, and payment and transaction security data are processed in case of online payment transactions. Personal data processed for non-member Platform users are their name, surname, e-mail and notes on the subject they want to communicate with, if they contact us via the "contact" screen within the Platform.

In addition to the above, some information required by Platform management, statistics and "back up" applications of Platform users and visitors will be automatically stored on our servers. This data includes navigation information obtained during the use of the website and mobile application, IP address, browser information, and the search words you use to find our site.More detailed information about cookies can be found in the "Cookie Policy" document.

B.     Sharing of Personal Data

EROM Bilişim stores the aforementioned information about you securely. It takes all necessary measures to protect the said information against any loss, abuse or alteration. Contractual partners of EROM Bilişim, who have access to your information in order to provide you with the necessary service, are obliged to keep this information confidential and not to use it for any other purpose within the framework of their contractual obligations.

Your Personal Data, within the framework of the purposes set forth in Article 3 of the Law on Protection of Personal Data No. 6698 (“Law”) may be transferred

-         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, limited to the Member's ("Client") name-surname or, optionally, 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. If the "ClarificationText Abroad" on the website is accepted, it is deemed that express consent has been given to the storage of personal data in a foreign-based cloud system and thus to transfer abroad.

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.

As "Special Quality Personal Data" in the Law, the race, ethnic origin, political opinion, philosophical belief, religion, sect or other belief, disguise and dress, membership of the association, foundation or union, health, sexual life, criminal conviction and data on security measures and biometric and genetic data were counted. According to the Law, if explicit consent is given during your use of the Platform, personal data of special nature may be processed.

In addition, according to the Law, the processing of personal data of special nature is also possible in the following cases except for the explicit consent of the person concerned:

-         In cases clearly stipulated by laws, sensitive personal data other than health and sexual life,

-         Personal data relating to health and sexual life may only be processed, without seeking explicit consent of the data subject, by any person or authorized public institutions and organizations that have confidentiality obligation, for the purposes of protection of public health, operation of preventive medicine, medical diagnosis, treatment and nursing services, planning and management of health-care services as well as their financing.

C.  Data Subject's Rights

Persons whose Personal Data are processed have the right to request the following issues.

-         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.

D.    Application and Information Request

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.