This Privacy Policy contains the terms and conditions of use of personal data shared with Ultimasoft Yazılım ve Teknoloji A.Ş. ("Company") by users/members/visitors ("Data Owners") of the web site www.phomo.io ("Site")/Mobile applications or the personal data collected by the Company during the operation of the Site/Mobile applications during the Data Owner's use of the Site.

Which Data are Processed?

Your personal data processed by The Company is categorized according to (i) the Law for Protection of Personal Data ("Law"); and (ii) General Data Protection Regulation("GDPR") as provided for in the following. Unless expressly stated otherwise, the terms "personal data" under the terms and conditions of this Privacy Policy shall cover the following information.

• Identity and Contact Information: Name, surname, phone, birthdate, gender, address, workplace information, e-mail address
• User Data and Content: Membership data, membership ID number, data on the date and time of using The Company services, reasons for communication with The Company, terms you use when searching at the Site and filtering preferences, scores and remarks, preferences, pages you have visited, errors during use, invoice and payment information, balance information (such as bills sent to the user and vouchers showing payments received from users, such as invoice number, invoice amount, invoice date, etc.).
• Location Information: Specific or approximate location information about your location, such as GPS data, that we have received while using the services of The Company.
• Security and Authentication: Log in credential information, password information
• Marketing and Communications: Reports and evaluations showing your habits and likes, notifications, targeting information, and information on cookie records, etc.
• Complaints and Disputes: Complaints you make through the Site
• Risk Assessment and Monitoring: IP address
• Face Recognition and Biometric Data: Hair, face posture, gender, age, facial hair, makeup, facial expressions, emotional reflection, accessory, eye-mouth-nose alignment, Identifying marks / stains
• User-Generated Content: Created events, event information (name, location, date), shared photos

Data anonymized under Articles 3 and 7 of the Law will not be considered as personal data in accordance with the provisions of the said law and the processing of such data will be conducted without being bound with the provisions of this Privacy Policy.

Please apply to the Company whether your data is being processed.

What is the Purpose of Use of Your Data?

Personal data you share with The Company may be processed for making your membership registration on the Site, updating the membership registration, conducting commercial activities including improvement of the services offered by The Company and providing new services through the Site, and providing you with information on these activities, determining and implementing commercial and business strategies, ensuring legal and commercial security of the persons who are in business relationship with The Company and providing necessary information to you and fulfilling responsibilities arising from the nature of these activities to allow you to utilize the services provided through the Site or via the Mobile Application.

Such personal information may be used to communicate with you or to improve your experience on the Site or on the mobile application (such as managing the communication management process, conducting research on customer satisfaction, etc.), and also to perform internal reporting and business development, and to make various statistical evaluations without disclosing your identity, to create database and perform market research. This information can be processed, stored and transmitted to third parties by The Company for the purposes of direct marketing, digital marketing, remarketing, targeting, profiling and analysis, and you may be contacted for promotion, maintenance and support activities on various applications, products via the aforementioned information.

The Company will also be able to process and share your personal data with third parties, pursuant to Articles 5 and 8 of the Law, and/or in the presence of exceptions under the applicable law, without obtaining your consent as Data Owner. Such conditions mainly include:

• If clearly prescribed in the law.
• If necessary to protect the life or physical integrity of a person or third parties, where the person is unable to explain his consent or the consent of such person is not legally accepted.
• If the processing of personal data is required for performance or execution of an agreement between the Data Owner and The Company.
• If it is compulsory for The Company to fulfill its legal obligations.
• If it has been revealed to the public by the Data Owner.
• If its compulsory for the establishment, use or protection of a right.
• Data must be processed for the legitimate interests of The Company, provided that it does not jeopardize fundamental rights and freedoms of the Data Owner.

Your Rights

As Data Owner, you have the right to request information about whether your personal data is processed or not, and if processed, to request information about such processing. You also have the right to request correction of incomplete or incorrect data, deletion or destruction of data under certain conditions, notification of correction, deletion or destruction to third parties to whom data has been transferred, objection to processing that leads to negative consequences, and compensation for damages incurred due to unlawful processing.

Contact Information

For any questions regarding this Privacy Policy, you may contact us at:

Ultimasoft Yazılım ve Teknoloji A.Ş.
Feneryolu Mah. Yazıcıbaşı Sk. No: 19/15
Kadıköy, İstanbul / TR
Email: hello@phomo.io