Clarification Text on The Processing of Personal Data

As Simpledo Financial Technology Corporation ("Company" or "Simpledo"), we strongly believe it is important to protect and secure personal data we obtain over our official websites, and mobile applications, in the framework of the Turkish Law No. 6698 on Protection of Personal Data and secondary regulations ("Protection of Personal Data (PPD) Legislation").

Personal data is defined as any information relating to an identified or identifiable natural person within the scope of the Personal Data Protection Law No. 6698 entered into force on 7 of April 2016 (“Law�?), and the protection of your personal data and to be informed about your personal data is your fundamental rights as per the Constitution of the Republic of Turkey (“Constitution�?). In this regard your data is processed and protected by Simpledo within the scope of the Constitution, Law and General Data Protection Regulation (“GDPR�?).

This Clarification on Protection of Personal Data ("The Clarification on Protection of Personal Data"), has been prepared to fulfil our obligation arising from Protection of Personal Data legislation as Simpledo, the data controller.

This clarification text is prepared by Simpledo Financial Technology Corporation ("Company" or "Simpledo"), in its capacity as a data controller (“Data Controller�?) within the scope of Article 10 of the Personal Data Protection Law No. 6698 and the Communique on Principles and Procedures to be Followed in Fulfillment of the Obligation to Inform.

Data Controller is obliged to inform the related persons at the time of collection of personal data, under the Article 10 of the Law, about the identity of the data controller and of its representative, if any, the purpose of processing of personal data, to whom and for which purposes the processed personal data can be transferred, the method and legal basis of collection of personal data and other rights referred to in Article 11 of the Law, and it is aimed to inform you by making statements about personal data processing operation carried out by Simpledo.

1. The Purpose of Processing Your Personal Data

Personal data of our clients such as name and surname, date of birth, place of birth, mother's name-father's name, mobile phone number, e-mail address, identification number/numbers, other identification information, photos, bank account numbers, address, occupation information, device type and identity personal data in the form of tracking information about usage, IP address and information obtained from WLAN (Wireless Local Area Network), transaction history, access date and time, browser type and version and location information within the scope of all stages, including the conclusion, execution and termination of the agreements you will make shall be processed in accordance with Article 20 of the Constitution of the Republic of Turkey and Article 4 of the Law for the following purposes by Simpledo as data controller:

1.1 Providing our services and verifying your customer identity for the same purpose;

1.2 Compliance with legal and administrative regulations;

1.3 Ensuring customer account and system security;

1.4 To comply with anti-money laundering and know your customer legislations and prevention of fraud and crime;

1.5 Qualifying you to perform Fiat Currency transactions;

1.6 Qualifying you to perform Credit Card transactions;

1.7 Safeguarding the security of our website, mobile applications, other online applications and products;

1.8 Fulfilling our obligations within the scope of the Law on Electronic Commerce. Use of the products and services that you receive/to be received, communication of offers for new product and service to you;

1.9 Compliance with the information retention, reporting and disclosure obligations stipulated by all judicial and administrative authorities in accordance with the relevant legislation, and ensuring the execution of the requests or decisions made by these authorities;

2. Transferring Your Personal Data

Your personal data is stored safely under the control of Simpledo. However, under certain necessities and conditions we share your personal data with third parties, and third parties whom we share your data are bound and limited for sharing purposes unless otherwise foreseen in the Protection on Personal Data legislation, and they are obliged to process and protect your personal data within the scope of our contractual relationship.

2.1 Third parties from whom we receive services in the fields of credit card processing, wire transfer services, payment systems, AML, KYC, law, tax, etc. to carry out our activities;

2.2 Provided that the necessary security measures are taken, electronic media such as servers, hosting companies, programs, cloud information technology etc. (located in Turkey or globally) from which storage, archiving, information technology support provided;

2.3 Simpledo affiliated companies, groups of companies;

2.4 Domestic or International organizations and/or partners with whom we cooperate (such as banks, funds, audit services. etc.);

2.5 Your personal data shall be transferred by Simpledo to its affiliated companies, groups of companies, business partners, consultants and competent courts and/or enforcement of�?ces and public institutions and organizations for the purpose of legal and �?nancial audits;

2.6 All kinds of public legal entities and authorities authorized to receive personal data;

2.7 The data processing activity in the form of transferring the data abroad will be carried out on the condition that the “explicit consent�? of the person concerned is obtained.

2.8 Simpledo will make reasonable effort to precure such third parties take necessary technical and administrative measures to protect the personal data being transferred.

3. The Method of Your Personal Data Collection

Your personal data is collected and processed by means of various methods:

3.1 With all agreements/information forms and other documents;

3.2 Through our website, mobile applications, other online applications and products;

3.3 Through our call center service, SMS, electronic mail, electronic media. etc.;

3.4 Through third party service providers such as KYC, KPS (ID Share System), etc.;

4. Your Rights Under Article 11 of the Law

You have the following rights regarding your personal data by applying to Company within the scope of Article 11 of the PPD Law:

4.1 Learn whether personal data is processed;

4.2 Request information if personal data has been processed;

4.3 Learn the purpose of processing personal data and whether they have been used in accordance with the purpose;

4.4 be informed of the third parties from which personal data is transferred domestically or abroad;

4.5 request personal data to be corrected if it is incompletely or improperly processed;

4.6 request the deletion or destruction of personal data within the framework of the conditions stipulated in the Article 7 of the Law;

4.7 requesting the transactions made in accordance with paragraphs (5.5) and (5.6) to be notified to third parties to whom personal data has been transferred;

4.8 object to the appearance of a result against you by analyzing the processed data exclusively through automated systems;

4.9 claim to recover damages in case of damage caused by illegal processing of personal data.

If you want to apply within the scope of your rights stated in this article regarding your personal data, you can submit your applications through one of the channels listed below in accordance with the Article 13 of the Law on Protection of Personal Data and the Article 5 of the Communiqué on the Principles and Procedures for the Request to the Data Controller, published in the Official Gazette dated 10.03.2018 and numbered 30356 that regulates the application procedure:

In writing to the address of Fatih Sultan Mehmet Mah., Balkan Cad., Meydan Istanbul, Block # 62A Umraniye/Istanbul - Turkey by providing your identity verification in person, or By sending an e-mail to legal@simpledo.io by using a registered e-mail address (KEP), secure electronic signature, mobile signature, or via the e-mail address that has been previously declared and to registered in the systems of Simpledo.

Company will finalize the requests duly, according to the nature of the request and within the statutory period. In case the operation requires cost, the tariff determined by the Personal Data Protection Council will be applied. If the request is rejected, the reason(s) for rejection will be justified in writing or electronically.

  • Company Legal Title: Simpledo Financial Technologies Inc.
  • Trade Registry No: 361177-5
  • Mersis (Central Trade Registry System) No: 0770105304500001
  • Address: Fatih Sultan Mehmet Mah., Balkan Cad., Meydan Istanbul, Block # 62A Umraniye/Istanbul - Turkey
  • The website address: www.simpledo.com.tr

You can check related info at Privacy Policy, Cookie Policy, Explicit Consent Statement.

If you have questions or concerns regarding this policy, or any feedback that you would like us to consider, please email us at legal@simpledo.io.