PRIVACY POLICY AND INFORMATION DISCLOSURE TEXT
The purpose of this privacy policy and information disclosure text is to explain to you in detail which personal data of you are processed for which purposes in connection with the service of TABİİ. We attach utmost importance to your privacy. We would like to inform you that, while providing the service of TABİİ and collecting, using and transferring your personal data, we process and protect all your personal data that you have provided to us, in accordance with the general principles of the data protection law, particularly the Law on Protection of Personal Data no. 6698 (“LPPD”), General Data Protection Regulation (“GDPR”) and the general principles of these regulations.
Turkish Radio and Television Corporation (“TRT") is the data controller of your personal information, and it uses its best efforts to protect your data in the best manner. In case you contact us in relation to your personal data, we may require you to pass through a security and identity verification process to be determined by TRT, in order to avoid any breach of security of your data.
To the extent not prohibited by applicable laws, group companies or affiliates of TRT may access your data (as data controllers) to use them on their own behalf for the purposes described in this policy, where they provide the services (as data processors) on behalf of data controllers.
Which Personal Data of You Do We Collect?
When you sign up to TABİİ;
Category of Personal Data Processed | Category Detail
| Applications Processed
|
User Data
| This is the personal data provided by you or collected by us for your subscription to TABİİ and use of the Services of TABİİ. Depending on your sign-up method, your name, surname, e-mail address, gender, date of birth, payment methods, user name/title or nickname information may be collected. Within the scope of our customization function, your age, phone number, profile adult setting, and information on your viewed content may also be collected. The exact scope of the personal data collected depends on the type of TABİİ Network Application and/or TRT Network Application to which you signed up, your method of creating an account, and your signing up to TABİİ and/or TRT Network services. If you use a third-party service to create an account and permit such third party service to disclose your data to 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 have provided to TABİİ through the service of TABİİ or other server may be collected. Information about the network connections, devices, boxes, and devices competent with the TABİİ application, which you directly or indirectly use in order to access the service of TABİİ (smart TV, mobile devices, receiver boxes, monitoring devices, game consoles, and devices providing related digital platform services), as well as advertising information, cookies, internet advertising, signs and data provided, may be collected about you as a user, with respect to your usage data, In this context, we may collect data about your choices for the content while receiving the service of TABİİ, together with your search inquiries, for customization in order to provide you with better services. In order that we can provide you with better services through notifications sent to the personal information you have disclosed and through related interactions, your calls, voice and notification recordings that you will send to our call centers, e-mail addresses and TABİİ customer services, may be collected. | TABİİ |
Data automatically collected and received from third-party resources | In order to enable the use of the service of TABİİ and to ensure service supply, we may obtain information from the companies and business partners you interact as a user, particularly GSM operators, service providing devices, smart TV, TV, internet service providers, service providing boxes (decoders, boxes, game consoles etc.), intermediary payment institutions used for payment methods, platform support service providers, voice response systems and digital application systems. Personal data you disclosed to the applications of TRT and the services connected to the network of TABİİ and TRT are also considered in this context. Your IP address, location services, security service providers providing information to TABİİ, for the purpose of ensuring the safety of accounts, in order to prevent fraud and smuggling, in case a payment method is used, the method of payment to TABİİ and the payment service providers providing current information related to the payment, as well as publicly available resources, internet service providers, publicly accessible databases and any information that is accessible in this context, are in this context. 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 disclose such information to us as per the local laws. |
Category of Personal Data Processed
| Category Detail
|
| Applications Processed |
Usage Data | Technical Usage Data: | We may use online identifiers such as URL information, cookie data and IP addresses, unique device ID numbers, information regarding the types of devices you use, such as device brand, device model, network connection type (for example, wireless, 3G, LTE, Bluetooth), network access point name and SSID, service provider, network and device performance, browser type, browser version, language, information activating management of digital rights, operating system, screen resolution, time zone, and application version of the Network of TABİİ and TRT, device features (such as device ID) or other unique identifiers of the devices on your wireless connection network that can connect to the Network of TABİİ and TRT (for example, smart speakers, smart TVs, game consoles, connected devices), device and software features (such as type and configuration), connection information, page viewing statistics, application source (for example, 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 TABİİ and TRT
|
Data Regarding Inapp Activities: | Searches made and search history (activity history, including date and time of your requests) | Other Websites and Applications connected to TABİİ and TRT
| |
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 ads | TABİİ and all websites of TRT providing video content services.
|
Data that You Select to Provide to Us and Allow Us to Provide You with Additional Features
Category of Personal Data Processed
| Category Detail
| Applications Processed
|
Purchasing Data
| Name, Surname, Mobile phone number, E-mail, Address details | TABİİ |
Contest, Survey, Electronic Message, 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 TABİİ and TRT |
How Do We Collect Your Personal Data?
We may collect your personal data;
if you sign in and create a membership,
if you use our services, applications and websites,
if you forward your information to us through relevant forms and other means,
if you forward your information for any application or service of TRT previously or subsequently,
by automated means, through our website and mobile applications. We may also obtain the aforementioned information through third parties in accordance with the following methods.
Information Provided by Third Parties
Third Parties
| Information Provided
|
Identity verification partners
| If you sign up or log in to our services by using third party identity information (for example, Facebook, Apple, Google, Twitter, etc.), we transfer your information from such third parties to our own systems in order to assist you in creating your account with us. |
Technical service partners
| We work with technical service partners that provide us with certain data, such as matching IP addresses with imprecise location data (for example, city, country), in order to ensure that we can provide the services, contents and features of TABİİ and TRT. |
Payment partners
| If you select to make payments against a bill for any service or feature, we may obtain data from our payment partners, in order to ensure that we can send a bill to you, process your payment and deliver your purchase to you. |
Advertisers and other partners
| We may collect certain data regarding you, such as cookie ID, mobile device ID, e-mail address and inferences regarding your areas of interest and preferences, from certain advertising partners, to provide you with more relevant ads, to organize campaigns and to send notifications and to measure their effectiveness . |
Analytical service provider partners
| We may 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 advertising campaigns. |
Our Purposes of Processing Personal Data, and Methods of and Legal Grounds for Collection of Personal Data
We process your personal data in accordance with the general principles in article 4 of LPPD and article 5 of GDPR and within the scope of the data processing conditions set out in LPPD and GDPR.
Personal Data 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 Services of TABİİ and TRT (such as websites, applications, social media accounts etc.), to produce statistical and scientific data, to improve our products and services accordingly, to increase satisfaction regarding our products and services, and to customize according to the user in this context.
| Where it is necessary to process the personal data of parties to 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 express consent |
User Data, Usage Data
| To understand and detect your requests, to overcome problems, and to solve problems with the Service of TRT.
| 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 Services of TABİİ and TRT.
| 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, by using any means of communication, for marketing, promotion and advertising purposes, within the scope of the services and developments, service programs and activities of TABİİ and TRT.
| Existence of express consent
|
User Data, Usage Data, Payment and Purchase Data, Contest, Survey and Lottery/Raffle Data
| To comply with the legal obligations and the 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 fulfill the contractual obligations with third parties, for example, license contracts, and to take proper actions regarding the related reports.
| 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 them.
| Where data processing is absolutely necessary for compliance with a legal obligation which the data controller is subject to Where data processing is mandatory for establishing, exercising or protecting a right
|
User Data, Usage Data, Payment and Purchase Data, Contest, Survey and Lottery/Raffle Data
| To make business planning, to prevent data losses, to archive, analyze, report and predict.
| 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 purchasing.
|
Where it is necessary to process the personal data of parties to 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 for participation in organizations such as trainings and seminars. | Where it is necessary to process the personal data of parties to 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 Where data processing is mandatory for establishing, exercising or protecting a right |
Transfer of Personal Data
We may transfer the personal data we process, within the scope of the Laws and other legislation, to our relevant business partners and affiliates, and public or private legal entities operating on behalf of our Corporation, that we have authorized, for the purposes that we have explained and in order to carry out business processes, in accordance with the provisions regarding the transfer of personal data that are set out in the legislation, and to authorized public institutions and organizations in order to fulfill our legal obligations.
Since the application infrastructure is provided by cloud systems, your data may be transferred abroad. Regarding the global transfer, storage and processing of your personal data, since we, as the platform of TABİİ, aim to provide you with a global service, your data may be transferred, within the scope of the purposes specified in this policy, to our affiliates and business partners located in different locations, particularly TRT, and to their affiliated third parties. 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 disclosed to our business partners to the extent they are fit for the purpose, limited to the following purposes: Your personal data may be disclosed to third parties, our business partners, and our suppliers with which we have a contractual relationship, for the purpose of advertising, website and application analytics, website and application testing and customization, usage, recording and display service, website and application analytics, mobile analytics, mobile notifications, advertising campaign analytics, social media posting service, target setting for app installation campaigns, conversion and monitoring, test applications distribution and collapse notifications, inapp notifications, customization of user behaviors, marketing service, solution suggestions, mobile application analysis and efficiency measurements, live broadcast monitoring, player performance development of TABİİ, analysis of errors and accuracy of the content viewed and of the user experiences, and for processing payments made by credit cards, debit cards or various gift cards for the sale of paid packages that may be provided to users in our website and/or mobile applications.
Except for the limited conditions specified in this Privacy Policy, your personal data are not disclosed to any third party other than TRT and other business partners of us. When you prefer to disclose your personal data to third-party companies and in case you allow the disclosure of your personal data to third-party companies and forward us your instructions for the disclosure of your personal data to third-party companies after upon your request, in order to ensure the sending of offers and promotions with regard to products and services, and in case you forward an instruction for the disclosure of your personal data to transport companies, companies providing hotel and travel services, catering companies, and third-party networks, websites and platforms used, when we disclose your personal data to 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
As TABİİ, Our Corporation TRT stores personal data in line with and proportional to their purpose of processing. Maximum level of technical and administrative measures stipulated under LPPD and GDPR is taken to ensure the security of the personal data that are stored. When the purpose of and/or the grounds for processing of personal data ceases to exist, they are stored until the end of the storage period prescribed by the applicable legislation, by also observing our legal obligations. When the purpose of and the grounds for processing of personal data ceases to exist, personal data shall be destroyed once the lapse of time periods required for fulfillment of our obligations arising from the relevant legislation expires.
Issues Exclusive to Children
TABİİ pay utmost attention to the protection of 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 express consent should be obtained from parents/guardians where express consent is required for processing of data.
Rights of the Data Subject
Everyone has the following rights pursuant to article 11 of LPPD:
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 personal data and whether or not such data are used in line with their intended purpose,
4. To obtain information about third persons to whom their personal data have been transferred domestically or abroad,
5. To request the correction of their personal data that may have been processed incompletely or inaccurately, and to request that the third parties to whom their personal data have been transferred be notified of the procedure carried out in this context,
6. In case, although they have been processed pursuant to the provisions of LPPD and other relevant laws, the reasons requiring them to be processed have ceased to exist, to request the deletion or destruction of personal data and to request that the third parties to whom their personal data have been transferred be notified 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 analysis of data processed, exclusively through automated systems,
8. To request compensation for any damage incurred due to unlawful processing of personal data.
You may forward to us your requests under article 11 of LPPD, “which sets out the rights of data subjects”, in accordance with the Communiqué on the Procedures and Principles for Application to the 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:
Your right to 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.
Your right to correction: 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.
Your right to destruction: You are entitled to request 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 a consideration related to your special case, that is the reason for your objection to the processing on that ground). 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 data: Under certain circumstances, you are entitled to consult us in order to restrict the processing of your personal data.
Your right to data portability: Under certain circumstances, you are entitled to request us to transfer the information that you provided to 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: Türkiye Radyo ve Televizyon Kurumu/TRT
Website: Tabii.com
Email Address: support@tabii.com
Address: TRT Genel Müdürlüğü Turan Güneş Bulvarı TRT Sitesi 06550 Oran ANKARA
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 amendments are essential and we will also obtain your consent if this is required under the applicable laws. We may serve notifications, by sending an e-mail to the e-mail address that you provided to us or publishing the aforementioned amendments on our website and applications, or through other means in accordance with the applicable laws.