PRIVACY POLICY AND INFORMATION DISCLOSURE
The purpose of this privacy policy and information disclosure text is to explain in detail which personal data of yours are processed for which purposes in connection with the TABII service. We attach utmost importance to your privacy. We would like to make you aware that, while we provide the TABII service, we protect all your personal data that you have submitted to us, in terms of their collection, use and disclosure, in line with the general principles of the data protection law, including especially Personal Data Protection Law No. 6698 (“PDPL”), General Data Protection Regulation (“GDPR”), and general principles of such legislation.
TABII LIMITED acts as the data controller for your personal data. TABII LIMITED is an affiliate of Turkish Radio and Television Agency (“TRT") and it makes best efforts to protect your data to the greatest extent possible. If you contact us in relation to your personal data, we may require you to pass through a security and identity verification process that will be designed by TABII, in order to avoid any security breach involving your data.
To the extent not prohibited under the applicable laws, group companies or affiliates of TABII LIMITED may have access to your data (as data controllers) in order to utilize the same on their own behalf for the purposes defined in this Policy at those locations where they (as data processors) provide the services on behalf of the data controllers.
Which Personal Data Do We Collect?
When you sign up for TABII;
Category of Personal Data that are Processed | Category Detail | Applications Subjected to Processing |
| User Data | These are the personal data provided by you or collected by us for your subscription to TABII and use of TABII Services. Depending on your sign-up method; your name, surname, e-mail address, gender, date of birth, payment methods, and user name/title or nickname data may be collected. Within the scope of our personalization function, your age, phone number, profile adult setting, and information on your viewed content may be collected. The exact scope of the personal data collected depends on the type of TABII Network Application and/or TRT Network Application for which you subscribe, your method of creating an account, and your signing-up for TABII and/or TRT Network services. If you use a third party service to create an account and permit such third party service to share your data with us, we will collect your personal data from this third party service. If you update your personal preferences regarding likes and ratings, information that you accepted to provide and you have provided to TABII through TABII service or other server may be collected. Information about the network connections, devices, boxes, and devices competent with TABII application, which you directly or indirectly use in order to access the TABII service (smart TV, mobile devices, receiver boxes, monitoring devices, game consoles, and devices providing related digital platform services) may be collected about you as a user with respect to your usage data, as well as advertisement information, cookies, internet banking, signs, and supplied data. In that regard, we may collect data about your choices for the content when you purchase the TABII service, together with your search inquiries, for customization and to improve our services offered to you. Your calls, your audio recordings, and recordings of your notifications to be made to/created on/in our call centers, our e-mail addresses and the TABII customer services may be collected in order for us to improve our services offered to you, through notifications sent to the personal information you shared and through related interactions. | TABII, |
| Data automatically collected and received from third-party resources | In order to allow the use of the TABII service and to ensure service supply, we may obtain information from the companies and business partners with whom you, as a user, interact, including specifically GSM operators, service-providing devices, smart TV, TV, internet service providers, service-providing boxes (box, game consoles etc.), intermediary payment institutions used for payment methods, platform support service providers, audio response systems, and digital application systems. Personal data you disclose to the applications owned by TRT, TABII, and the services connected to TRT network are also considered to fall within this scope. Your IP address, location services, security service providers providing information to TABII in order to prevent fraud, smuggling and deception, and guarantee the safety of the accounts, and if a payment method is used, the payment service providers providing current information to TABII about the payment method and the payment, as well as publicly available resources, internet service providers, publicly accessible databases and any information that is accessible in this respect are considered to fall within this scope. We may also obtain information from other reliable resources in order to update or supplement the information that you provide or that we automatically collect, such as verification of e-mail addresses by using third party services. Before you provide us with any of your information, you may need to authorize third parties to share such information with us as per the local laws. |
Category of Personal Data that are Processed | Category Detail | | Applications Subjected to Processing |
| Usage Data | Technical Usage Data: | We can use online identifiers such as URL information, cookie data and IP address, unique device ID numbers; information regarding the type of devices you use such as device model, network connection type (for instance, wireless, 3G, LTE, Bluetooth), network access point name and SSID, service provider, network and device performance, browser type, browser version, language, digital right management activating information, operating system, screen resolution, time zone, and TABII and TRT Network application version; device features (such as device ID) or other unique identifiers of the devices on your wireless connection network which can connect to TABII and TRT Network (for instance, smart speakers, smart TVs, game consoles, connected devices), device and software features (such as type and configuration), connection information, page viewing statistics, application resource (for instance, application URLs), browser and standard web server directory details, and third party map applications and/or your device’s location service to verify your address. | Other Websites and Applications connected to TRT and TABII |
| Data Regarding Activities on Application: | Searches made and search history (activity history, including date and time of your requests) | Other Websites and Applications connected to TRT and TABII | |
| Visual content such as TV series, films, documentaries or programs watched by you, and actions on the application such as adding such content to list, watching duration and skipped advertisements | TABII and all TRT websites offering video content services |
Data that You Select to Provide to Us and Allow Us to Provide You with Additional Features
Category of Personal Data that are Processed | Category Detail | Applications Subjected to Processing |
| Purchasing Data | Name, Surname, Mobile phone number, E-mail, Address details | TRT Market, TABII |
| Contest, Survey, Electronic Communication, Lottery/Raffle, Application and Communication Forum Data | We collect your personal data (name, surname, mail address, phone number; Turkish identity number and phone number for information-obtaining processes) that you provide when you fill in a form, give a message approval, answer any research or survey or participate in any contest. | Other Websites and Applications connected to TRT and TABII |
How Do We Collect Your Personal Data?
We may collect your personal data automatically on our website and mobile applications:
- when you subscribe to become a member,
- when you use our services, applications and websites,
- when you submit information to us via forms and other methods,
- when you forward your information before or after, in connection with any TRT application or service.
We can also collect such data via third parties.
Information Provided by Third Parties
Third Parties | Information Provided |
| Identity verification partners | If you subscribe to or log in our services by using third party ID details (for instance, Facebook, Apple, Google, Twitter, etc.)), we will import your information from such third parties in order to make it easier for you to create an account with us. |
| Technical service partners | We work with technical service partners who provide certain data to us, such as matching IP addresses with imprecise location data (for instance, city, country), in order to enable us to provide the TABII and TRT services, content and features. |
| Payment partners | If you select to make payments against invoice for any service or feature, we can request data from our payment partners to submit an invoice to you, process your payment and present your purchased item to you. |
| Advertisers and other partners | We can collect certain data regarding you such as cookie ID, mobile device ID, e-mail address and inferences regarding your interests and preferences, from certain advertisers and advertisement partners, to offer advertisements, organize campaigns and send notifications that interest you more and to measure their effectiveness. |
| Analytical service provider partners | We can collect data from our analytical service provider partners in order to assist us in getting to know our users visiting and using our websites and applications in more detail, to understand the expectations of our users, to contribute to the development of our content in line with the demands of our users, and to take the correct steps regarding promotion and advertisement campaigns. |
Our Purposes of Data Processing and Legal Ground of Processing
We process your personal data in accordance with the general principles under the article 4 of the PDPL and article 5 of the GDPR and in line with the data processing terms under the PDPL and GDPR.
Personal Data that are Processed | Our Purpose of Processing | Legal Ground |
| User Data, Usage Data, Payment and Purchase Data, Contest, Survey and Lottery/Raffle Data | To provide and manage the TABII services and TRT Services (such as websites, applications, social media accounts etc.), to produce statistical and scientific data and improve our products and services accordingly, to increase satisfaction regarding our products and services, and to customize user experience accordingly | Where it is necessary to process the personal data of parties of a contract, for the conclusion or performance of the contract Where it is absolutely necessary to process the personal data for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed Existence of explicit consent |
| User Data, Usage Data | To understand, detect and resolve problems, and to solve problems regarding the TRT Service | The processing of personal data belonging to parties to a contract being required for the conclusion or performance of such contract; and the data processing being mandatory for the data controller’s legitimate interests provided that the fundamental rights and liberties of the data subject are not impaired |
| User Data, Usage Data | To evaluate and develop new features, technologies and improvements regarding the TABII services and TRT Services | Where it is absolutely necessary to process the personal data for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed |
| User Data, Usage Data, Payment and Purchase Data | To communicate through any means of communication as part of the TABII and TRT services and developments, and service programs and activities, for marketing, promotion and advertisement purposes | Existence of explicit consent |
| User Data, Usage Data, Payment and Purchase Data, Contest, Survey and Lottery/Raffle Data | To satisfy legal obligations and requests of law enforcement authorities | Where data processing is absolutely necessary for compliance with a legal obligation which the data controller is subject to |
| User Data, Usage Data, Payment and Purchase Data | To satisfy contractual obligations under the agreements made with third parties (for instance, license agreements) and to take proper actions regarding their reporting | Where it is absolutely necessary to process the personal data for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed |
| User Data, Usage Data, Payment and Purchase Data, Contest, Survey and Lottery/Raffle Data | To file legal claims, to satisfy such claims or to defend against such claims | Where it is mandatory to process data for securing, exercising or protecting a right |
| User Data, Usage Data, Payment and Purchase Data, Contest, Survey and Lottery/Raffle Data | To make business planning; to archive, analyze, report and make projections based on data in order to prevent data losses | Where it is absolutely necessary to process the personal data for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed |
| User Data, Purchase Data | Processing of purchases | Where it is necessary to process the personal data of parties of a contract, for the conclusion or performance of the contract Where data processing is absolutely necessary for compliance with a legal obligation which the data controller is subject to |
| User Data, Usage Data, Contest and Survey Data | To organize researches, contests, surveys and lotteries/raffles To receive requests to participate in organizations such as trainings and seminars | The processing of personal data belonging to parties to a contract being required for the conclusion or performance of such contract; and the data processing being mandatory for the data controller’s legitimate interests provided that the fundamental rights and liberties of the data subject are not impaired Where it is mandatory to process data for securing, exercising or protecting a right |
Transfer of Personal Data
We transfer the personal data that we process to relevant business partners and affiliates in order to carry out the business processes and to authorized public authorities and institutions in order to satisfy our legal obligations.
Since the application infrastructure is provided by cloud systems, your data may be transferred to abroad (Evergent, Amazon Web Services, İnsider, Appsflyer, Mux and Google). Regarding global transfer, storage and processing of your personal data, we, as TABII platform, strive to provide you with a global service and therefore, your personal data may be transferred for the purposes detailed in this policy to our affiliates and business partners operating at different locations, including specifically TRT, and any third parties affiliated to them. We are committed to taking the most stringent measures to protect confidentiality of your personal data, regardless of where they are stored, to where they are transferred, or where they are processed.
Your personal data may also be shared with our business partners to the extent it fits the intended purposes, which purposes will be limited to the following: Your personal data may be shared with third parties, our business partners, and suppliers having contractual relations with us, for the purpose of advertisement, website and application analytics, website and application testing and personalization, utilization, recording and display service, site and application analytics, mobile analytics, mobile notifications, advertisement campaign analytics, social media posting service, target setting for app installation campaigns, conversion and monitoring, test applications distribution and collapse notifications, in-application notifications, personalization of user behaviors, marketing services, solution suggestions, mobile application analysis and efficiency measurements, live broadcast monitoring, TABII player performance development, analysis of errors and accuracy of the content viewed and of the user experiences, and for processing data about the payments made by credit cards, debit cards or various gift cards for the sale of paid packages that may be offered to the users through our website and/or mobile application.
Except for the limited conditions defined in this Privacy Policy, your personal data are not shared with any third party other than TRT and our other business partners. When you prefer to share your personal data with third-party companies and when you forward us your instructions for the sharing of your personal data with third-party companies after you allow the sharing of your personal data with them, in order to ensure the sending of offers and promotions about the products and services, and when you provide an instruction for the sharing of your personal data with transport companies, companies providing hotel and travel services, catering companies, and third-party networks, websites and platforms used, and when we share your personal data with these third-party companies, we would like to remind you that such personal data received by those companies will be under the supervision and responsibility of those companies and will be subject to the privacy policy of those companies.
Storage and Destruction of Personal Data
Our company, TABII, and the Corporation which it is an affiliate of, TRT, keep personal data in line with and in proportionate to the purpose of their processing. Maximum level of technical and administrative measures stipulated under the PDPL and GDPR is taken to ensure the security of the personal data that are stored. When their purpose and/or reason of processing ceases to exist, the personal data are stored until the end of the storage duration prescribed by the applicable legislation, by taking into consideration also our judicial and legal rights. When the purpose and reason of processing of personal data ceases to exist, personal data shall be destroyed once the statute of limitations required to ensure satisfaction of our obligations arising from the laws expires.
Important Matters Regarding Children
TABII shows utmost care regarding the protection of the personal data of children. Taking into consideration the actual difficulty to monitor children on the internet, the internet use by children should be supervised by their parents/guardians and the explicit consent should be obtained from parents/guardians where explicit consent is required for processing of data.
Rights of the Data Subject
Everyone has the following rights pursuant to article 11 of PDPL:
1. To learn whether or not their personal data have been processed,
2. To request information on the procedure, if their personal data have been processed,
3. To learn the purpose of processing of their personal data and whether or not such data are used in accordance with their purpose,
4. To obtain information about the identity of third parties to whom their personal data have been transferred domestically or abroad,
5. • If their personal data have been processed incompletely or inaccurately, to request correction of the same, and to request that the third parties to whom their personal data are transferred be also informed about the transaction executed in this regard,
6. In the case where, although they have been processed pursuant to the provisions of PDPL and other relevant laws, the reasons requiring them to be processed have ceased to exist; to request that their personal data be deleted or destroyed and to request that the third parties to whom their personal data are transferred also be informed of the procedure carried out in this context,
7. To object to the emergence of an outcome which is to the detriment of the data subject as a result of the analyzing of the processed data exclusively through automated systems,
8. To request compensation for any loss incurred in the case that their personal data are processed unlawfully.
You can submit your requests under article 11 of the PDPL, “regulating the rights of the data subjects”, to us in accordance with the Communiqué on Principles and Procedures for Applications to Data Controller. Requests will be evaluated and decided upon free of charge as soon as possible and in any case within thirty (30) days at the latest. In the case that the evaluation and decision procedure requires an additional cost, the fee specified in the tariff designated by the Personal Data Protection Board will be taken as a basis.
Your Rights under GDPR
As an individual, you have certain rights in connection with our processing of your personal data, including the right to lodge a complaint with the relevant supervisory authority.
Under GDPR, you have the following rights:
•Right of access- you are entitled to request copies of your personal data. This right will enable you to take a copy of your personal data stored by us about you and to check whether or not we lawfully process your data.
•Right to correct- you are entitled to request correction of any information that you think is incorrect. You are also entitled to request completion of incomplete/missing information.
•Right to destroy- you are entitled to ask us under certain circumstances to destroy your personal data. This right will enable you to request us to delete or remove your personal data unless there is a valid reason to continue the processing of such personal data. You are also entitled to raise an objection to the processing of your personal data for the purpose of deletion or destruction. (Please see below for these circumstances.)
• Your right to object to the processing
-Under certain circumstances, you are entitled to object to the processing of your personal data (when we process them on the basis of a legitimate interest or interests of a third party and there is an issue that is the reason of your objection to our processing on that ground, based on your specific circumstances). You are also entitled to raise an objection to our processing of your personal data directly for commercial purposes.
• The right to restrict the processing of your personal data - under certain circumstances, you are entitled to consult us in order to restrict the processing of your personal data.
• Your data mobility right- under certain circumstances, you are entitled to ask us to transfer your personal data that you provided us to another entity or to you.
You do not need to pay any fee in order to exercise your rights. If you send us any request, we have one month to provide you with a response.
(ENG)
As an individual you have certain rights regarding our processing of your personal data, including a right to lodge a complaint with the relevant supervisory authority.
Under GDPR, you have rights including:
Your right of access - You have the right to ask us for copies of your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances (where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.). You also have the right to object where we are processing your personal information for direct marketing purposes.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances.
Your right to data portability - You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Identity of Data Controller
Title: TABII LIMITED
Website: Tabii.com
Phone Number: 444 0 878
E-Mail Address: destek@tabii.com
Address: 200 Gray's Inn Road, London, England, WC1X 8XZ
Annex: Form of Application to the Data Controller
Amendments to the Privacy Policy
We may amend this privacy policy from time to time in order to adapt to the new technologies, sector practices, legal conditions or other purposes. We will notify you when these changes are important and we will also obtain your consent if this is required under the applicable laws. We may send notices about these changes to the latest e-mail address you provided to us or we may publish these changes on our website and applications or we may notify you of the same through other means in accordance with the applicable laws.