PRIVACY POLICY

We, Bulundum Bilgi Teknolojileri Yazılım Pazarlama ve Ticaret A.Ş. (“bulundum.com” or “we”), attach remarkable importance for the protection of the personal data of bulundum.com website and mobile application (“Platform”) users. In this regard, as a data controller, we have developed this Privacy Policy (“Policy”) therefore to enlighten you on the rules and policies regarding the processing of your personal data, and usage of cookies and general technologies within the scope of Law No: 6698 on the Protection of Personal Data (“PPD Law”).

IMPORTANT NOTICE

Please be aware that you may only provide us with personal data of third parties, provided that you obtain their explicit consent by informing them about this Policy.

I. THE PRINCIPLES REGARDING THE PROCESSING OF PERSONAL INFORMATION

As bulundum.com, we shall process your personal data as explained in this Policy, for the purposes mentioned under “Purpose of Processing Personal Data” section below.  

You do not have to provide the personal data that we have requested. However, if you choose not to do so, we may not be able to provide you with the services and facilities offered in the Platform or respond to any queries or requests you may have. Therefore, you hereby accept that, if you refuse to provide your personal data required for bulundum.com to perform any of its obligations to you under the User Agreement or any other related agreement; we cannot be held liable for failure to perform such obligation.

1. Definition of Personal Data

“Personal data” refers to all kinds of data regarding a natural person whose identity is identified or identifiable. In this regard, anonymous information or information become anonymous and the information that does not enable to identify a specific person is not considered as personal data under this Policy.

2. Methods to Collect Personal Data

We can collect your personal data from you or your devices when you;

(i) Use the Platform,

(ii) Register bulundum.com user account or when this account is updated,

(iii) Use the services offered on the Platform,

(iv) Perform correspondences with the persons who found the lost items through the Platform,

(v) Contact with us/our business partners

Some examples for the types of personal data we, as bulundum.com may collect and collection methods are given below.

(i) Information collected when you register for and use a bulundum.com user account: In order to open a user account or use the services offered in the Platform, you may be asked to provide us with your name, surname, e-mail address and mobile phone number. We may also ask you to choose security questions to answer (e.g., your best friend’s name) when you have forgotten the password of your user account. Additionally, we may collect information regarding the transactions you execute with your user account.

(ii) Information collected when the delivery of lost item is demanded: In the event you demand the delivery of lost item through the Platform, we may collect necessary information in order to confirm the payment or your credit card information, identify you, ensure the security of the system, confirm your ownership on the lost item and fulfil our or our business partners’ legal obligations.

(iii) Information collected when you use a device: When you use the Platform through a device, we may collect the internet protocol (IP) address, and other information about the devices you use (such as device ID, unique identifier, device type, ID for advertising, unique device token, statistics on your page views, traffic, referral URL, your browsing history, your web log information, and geo-location data).

(iv) Information collected using cookies and general technologies: We may use cookies and other general technologies to collect information about the pages you view, the links you click and actions you take on the Platform and, in our advertising, or e-mail content. Further information about our use of these technologies is provided under “Cookies and Other General Technologies” section below.

3. Purpose of Processing Personal Data

We, as bulundum.com may collect, acquire, record, organize, store, adapt, alter, use, disclose, transfer, align, categorize, and combine or otherwise process your personal data for the following purposes:

(i) to fulfil our legal obligations,

(ii) to conclude and execute the agreements made with you,

(iii) to improve and specialize the services we offer, and make you exercise the privileges you obtained,

(iv) to keep you posted about our services and campaigns,

(v) to create, develop and improve our advertising and promotion,

(vi) to notify you any change in our terms, conditions and policies, including this Policy and send other notices that relates to you,

(vii) to secure and improve coordination, cooperation and efficiency within and between the departments of our firm,

(viii) to procure the security of our Platform and other electronic systems and our physical environment,

(ix) to poll your opinions through surveys or questionnaires,

(x) to respond your queries, requests or claims, in order to provide efficient customer services,

(xi) to update, or troubleshoot problems with your account,

(xii) to celebrate your birthday and other special occasions and to administer programs such as sweepstakes, contests or promotions in which you participated,

(xiii) to investigate and prevent any breach of law or agreements, and report such cases to competent judicial or administrative bodies or authorities, and

(xiv) to resolve legal disputes.

4. Transfer of Personal Data in and Outside Turkey

We may transfer personal data to state institutions and organizations as required by the legislation, and to our business partners and suppliers for the purposes listed in the section “Purpose of Processing Personal Data” hereof, provided that we comply with general principles set out in Article 4 of PPD Law and those terms and conditions set out in Articles 8 and 9 thereof and adopt necessary safety measures. Otherwise, we do not share your personal data with third parties for their marketing and advertising purposes without your explicit consent.

We may process and store your personal data in the servers in European Union countries, United States of America or another country outside Turkey.

5. Legal Grounds to Process Personal Data

We process your personal data based on your explicit consent or the following legal grounds:

  • if stipulated in the legislation explicitly,
  • if the collection of the personal data of contracting parties is required, provided that it is directly related with the conclusion or execution of an agreement,
  • if necessary to fulfil our legal obligation,
  • if the personal data are disclosed by the data subject,
  • if necessary in order to establish, use or protect a right,
  • to protect legitimate interests of data controller, provided that it does not harm the data subject’s fundamental rights and freedoms.

6. Storage Period of the Personal Data

Unless a longer storage period is required or permitted by law, we store your personal data only for the duration necessary for the achievement of the purposes set out in this Policy.

7. Your Rights as a Data Subject

Pursuant to Article 11 of PPD Law, you as a data subject shall have the following rights:

  • to inquire whether your personal data are processed,
  • to ask for information about your personal data that have been processed,
  • to inquire the purpose underlying the processing of your personal data and whether they are used in line with such purpose,
  • to learn third parties in Turkey or abroad to whom your personal data have been transferred,
  • to ask for correction where your personal data are processed inaccurately or incompletely,
  • to ask for their destruction or deletion where reasons underlying the processing of your personal data no more exist,
  • to request that such correction or deletion is notified to third parties to whom your personal data have been transferred,
  • to object to consequences to your detriment, arising from the analysis of the data processed exclusively via automatic systems,
  • to seek compensation for your loss where you suffer a loss due to unlawful processing of your personal data.

In the event you wish to exercise either of your rights above, you should send such request including your identity and sufficient information and explanation regarding the right you wish to exercise to the address of Maslak Mah. Eski Büyükdere Cad. İz Plaza Giz Apt.No:9/78 Sarıyer/İstanbul personally or via notary public or send the request to [email protected] by using registered electronic mail, secure electronic signature, mobile signature or e-mail address notified to us and registered in our system previously.

The requests that you transmitted to us as a data subject shall be evaluated and responded at latest in thirty days based on the nature of the request pursuant to Article 13 of PPD Law. Any favourable or unfavourable responses to the data subject’s request may be sent to him/her in writing or electronically. Although the data subject’s requests will be responded free of charge in principle, in case such a response results in additional cost, the data subject may be charged with a fee in such amount set out in the relevant legislation.

II. COOKIES AND GENERAL TECHNOLOGIES

1. General

When you interact with bulundum.com messages and advertisements, bulundum.com and/or its authorized service providers may place small data files on your computer or other devices in order to store data in your browser/device and collect information for the purposes outlined below.

These data files may be cookies, pixel tags, flash cookies, web beacons and other general technologies for storing information. We may use the terms “cookies” and “technologies” together or interchangeably in this Policy to refer to all technologies that we may use.

These technologies help us to:

(i) identify our users,

(ii) understand the user’s behaviour better,

(iii) see which parts of Platform have been visited,

(iv) facilitate and measure the effectiveness of the Platform, advertisements and promotions,

(v) operate and improve the Platform, and

(vi) promote safety of the Platform.

2. Types of Cookies

Cookies may be categorized by their life-span or domains they belong to. Where they are classified by life-span, they are divided into two groups: session cookies and permanent cookies. Session cookies refer to those deleted when the user closes the browser, while permanent cookies refer to those remaining at the user’s computer for a pre-defined term.

If cookies are categorized by the domains to which they belong, they are again divided into two categories: related party cookies and third-party cookies. Cookies embedded by the visited website are called related party cookies, whereas cookies embedded by a website different than the visited website are referred to as third party cookies. Third party cookies are the ones that are embedded to the user’s device by the third parties outside of the domain, through the domain the user has visited.

3. Purpose of Use of Cookies

We may make use of cookies and general technologies for the following purposes:

(i) Operational purposes: We may use cookies and general technologies that we found necessary for the operation of the Platform. Some examples to the technologies used for operational purposes are the technologies that are required to identify irregular Platform behaviour and ensure security; and technologies that allow you to access the Platform or make use of its functions.

(ii) Functionality purposes: We may use cookies and general technologies that allow us to offer you a more convenient personal experience with the Platform. Some examples of technologies used for functionality purposes are technologies that help us identify you when you interact with the Platform and remember your preferences and interests.

(iii) Performance purposes: We may use cookies and general technologies to evaluate the performance of the Platform. Some examples of technologies used for performance evaluation purposes are technologies that help us understand how you use the Platform, find out whether you have interacted with our messages, and improve the Platform.

(iv) Advertising purposes: We may use first-party or third-party cookies and general technologies to deliver content, including advertisements relevant to your interests, on the Platform or on third party websites. Some examples of technologies used for advertising purposes are technologies that measure effectiveness of advertisements, help us understand the content that has been delivered to you (such as, whether you have clicked on an advertisement) and control the number of times you see a given advertisement.

4. Declining or Deleting Cookies

Most browsers support cookies, but users can set their browsers to decline them and can delete them whenever they like. You may decline or delete cookies by changing your preferences in your browser. Settings for each browser may differ, therefore we recommend you to check with your provider to find out how to disable cookies.

Please be aware that certain features of the Platform may not be available once cookies are disabled.

5. Authorized Service Providers

We may receive support from some service providers that we authorize for the purpose of operation and advertisement of services provided through the Platform. Such service providers may also embed your computer cookies and general technologies (third party cookies) and collect information such as unique identifier and device identifier in order to identify your device’s IP address.

III. THIRD PARTY WEBSITES

The Platform may contain links to third party websites. Such links are governed by their own privacy policies, terms and conditions or notices, and it should be born in mind that third party websites are independent of bulundum.com and bulundum.com is not responsible for the practices of third parties regarding privacy. We recommend you to read the privacy policies of the linked websites that you visit.

IV. CHANGES

We may revise and update this Policy from time to time. You may always access to the most current version of this Policy via the Platform. By continuing to access or use the Platform after changes being applied, you agree to be bound by the revised version of the Policy.