Information on Protection of Your Personal Data

(UPCALL Privacy Policy)

Your personal data which you share with our company (Turkcell İletişim Hizmetleri A.Ş.) are under the protection of our Company. As per the Law on Protection of Personal Data numbered 6698 (the Law), our Company takes all necessary technical and administrative safeguards by using all of its technological and infrastructural facilities to provide that your personal data is kept safely and that processed and accessed lawfully.

In accordance with the Law, your personal data including but not limited to the below are processed by our Company in the capacity of controller, in compliance with the Law and the relevant legislation.*

I. What are Your Personal Data?

Your personal data refers to any information which identify you or render you identifiable. In relation to our Company, your personal data are indicated below, in a manner not limited to such;

Identification Information: Turkish ID number, place and date of birth, marital status, gender and any other identification information,

Subscription Information: Personal data by which we can identify the subscriber such as costumer number, name, surname, telephone number, e-mail address, subscription agreement number and the type of identification used in subscription, as well as basic subscription information such as payment choice, segment information, tariff and package information, line activation information, subscriptions for value added services, invoices, financial and debt information, subscription type and channel, subscription status (cancelled, active, etc.), and invoice date as shown on the invoice, tariff type, address information, reference number information and invoice number information,

Network, Traffic and Location Information: Usage data generated from traffic data, dates, times and durations of messages and calls sent or received via our network from mobile devices or provided by 3rd parties, estimated location data of such communications, date and time information of connection to the system with regard to any kind of access made on the internet, date and time information for disconnection from the system, source and target point information, relevant location information and similar types of traffic data, brand and model information of the device used, technical specifications of such device, dates of change of devices, information on change of SIM cards, instant information whether the line is on/off/busy,

Sales Channels Information Personal data which include usage details such as usage size, audio call recordings that are kept by the sales and customer representatives as per call center standards and the data you have provided when our Company is contacted via e-mail, mail and any other means, and the data including requests and transaction information which are obtained through sales,

Value Added Service, Product, Service Usage Information:Behavioural information collected through including but not limited to www.turkcell.com.tr, www.superonline.net, http://blog.turkcell.com.tr/, http://www.turkcelltech.com.tr/ and https://arikovani.com/ which are designed to promote products and services offered by Turkcell itself as well as with cooperation of other entities, preferences regarding the use of Turkcell’s specific products and services, the data such as device, network, application, location and usage information which may be collected through Turkcell’s mobile applications, on the internet websites and mobile applications,

Payment, Bank and Risk Information: (i) In relation to device campaigns and service subscriptions, for the purposes of pre-assessment of financial qualification; credit rating information, credit card and debit card information, branch code, account number and other banking information; (ii) in case you make an application to group company Turkcell Ödeme Hizmetleri A.Ş. to receive Turkcell Mobile Payment services or receive such services and/or in case you make an application to receive services Turkcell Finansman A.Ş or receive such services; the number of Turkcell lines you have subscribed for, your expenses and invoice information and line type information (postpaid/prepaid, corporate etc.) regarding such lines, status information of your line (on/off), subscription period (years), account balance on your prepaid line if any, payment performance of the invoices for your including previous periods, whether your line has been temporarily deactivated, invoice address and changes to such if any, whether it has an automatic payment/top-up order, top-up frequency, number of top-ups, whether your line is allowed for mobile payment processes, and if so, mobile payment monthly spending limit, whether such monthly limit is reached, whether there has been any expenses via mobile payment, whether there has been any unsuccessful transaction due to insufficient balance, number of insufficient transactions, in case of credit card use, limit/risk, deposit default, credit agreement and its appendixes as well as other relevant information

UPCALL Application Information; The data regarding contacts saved on the device on which UPCALL application is installed, call history and information regarding calls held on such device, communications information including call types, processes you make on the application, preferences and usage habits, application usage data, information used for identification and authentication while accessing the account, location data, data which identify base stations and Wi-Fi hot spots along with GPS data, IP address, navigation data, invoice and payment information for the purchased services within the application, invoicing information and payment information for services purchased through the application, sent invoices, received payments and copies of bank receipts for such, information such as payment number, invoice number, invoice amount, invoice date, and brand, operation system, language settings of the device, identity of the user’s network operator, country information.

II. Purposes for Processing Personal Data

Your personal data may be processed for the purposes of, including but limited to;

Promotion of general and special campaigns regarding products and/or services of our Company, communication of discounts, benefits, conditions, pricing and similar information, provision of opportunities such as membership, invitation and events and to pursue all kinds of processes which are required for use of such,
In case you participate in special award, draw, contest or similar event, use of the information you have provided within the context of such event,
Communication of good wishes, communications and reminders for prizes, draws and contents that you might like to re-access or to be reminded of, presenting gifts for your satisfaction and provision of information on such, communication regarding used of gifts,
For your satisfaction and loyalty; presentation of offers based on your use of products and services, provision of information on promotions, gifts and special offers for you and on use of such, communication regarding use of gifts, announcements of the cooperations our Company makes on your behalf of you and communication of customers who would benefit from these rights,
Invoicing your usage, as well as handling the processes necessary to prevent misconducts, losses and fraud,
Announcement of the cooperations of our Company and communication with you in case you would benefit from these rights,
Verification of your identity information where necessary, credit rate control and reporting, provision of products and services which have been ordered, purchased or in use, provision of information on such, processing and following up your requests,
Internal purposes such as improving our Company’s products, services and network, auditing, data analysis, and responding to your questions, complaints and notices,
Creating a record in order to purchase a specific service and/or product,
Delivery/provision of our products and services with strategic partners, which work with our Company to provide such products and services or assist us in provision of such, evaluation of your interest in our products and services, and your customer satisfaction with the same,
Making financial agreements with our business partners and other third parties regarding the products and services offered to you, provision of products and services which are offered with our business partners and other third parties,
In case of emergency calls, locating and sharing your location with official authorities,
Provision of services by Turkcell Finansman A.Ş. and Turkcell Ödeme Hizmetleri A.Ş., determination/management/detection of risk levels and performance of the liabilities under the relevant legislation by the financing company and the payment service provider,
Storing your information that are required to be kept as per the relevant legislation for the purposes of provision of service, copying and backing up in order to prevent information losses, monitoring accuracy of your information, maintaining necessary technical and administrative safeguards for data security of our networks,
Sharing the data with the regulatory and supervisory authorities, where legislation necessitates or requires, and sharing for the purpose of compliance with legal regulations,

In terms of UPCALL application, in addition to the purposes listed above, performance of the application, fulfilling its functionality, provision of services in the context of the application, and responding to your needs by means of your processes and preferences as performed on the application, improvement of such services, carrying out monitoring and controllingas well as for the purposes of providing telecommunications services, marketing activities such as diversification, measurement and announcement of products and services, provision of call center services, financial reporting, legal proceedings and similar purposes.

III. Transfer of Personal Data

Our Company, in accordance with the processing purposes listed above, may transfer your personal data to required or authorized persons and institutions in Turkey or abroad, including but not limited to;

Turkcell group companies in Turkey or abroad which are listed in https://www.turkcell.com.tr/en/aboutus/company-overview/our-subsidiaries
The courier companies and other business partners with whom we work to supply and deliver the products and services which you wish to purchase or use,
Courts and enforcement offices where lawsuits and legal proceedings regarding Company receivables,
Official authorities which would locate you in case of an emergency call,
Our business partners, suppliers, banks, financial institutions, TBB Risk Center and other real and legal persons with whom our Company cooperates to provide you services and/or from whom we supply such services,
Lawyers, auditors, consultants and other third persons from which we receive services,
Your proxies and representatives which are authorized by you,
Regulatory and supervisory institutions, other legal institutions, and official institutions and organizations which are authorized to request access to your personal data.

IV. The Method of Collecting Personal Data and Cause of Action

Your personal data are collected for the purposes of providing electronic communication services and any other products and services of our Company within legal framework as well as for the above mentioned purposes, via subscription agreement, dealers of our Company and other in-person channels, our Company website, call center, short message, electronic mail, mobile applications, interactive voice response and via all kinds of written, oral or electronic environments.

V. Your Rights Regarding Personal Data Protection

As per Article 11 of the Law; you have the right to make an application to our Company and;

Learn whether your personal data have been processed,
If processed, request information regarding such,
Learn the purpose of processing of personal data and whether the data have been used in accordance with their purpose,
Know the third parties in Turkey or abroad to whom the data have been transferred,
Request rectification in case personal data are processed incompletely or inaccurately,
Request deletion or destruction of personal data under the conditions set forth under article 7 of the Law,
Request notification of the operations performed in accordance with your rights to rectification, deletion and destruction to the third persons to whom the personal data have been transferred,
Object to the outcome of any result that is against your interests which is generated by means of analysis of personal data exclusively through automated systems,
Request indemnification for the damages in case you incur damages due to unlawful processing of personal data,

You can send your requests regarding the application of the Law and any other questions regarding your personal data, in writing, to Turkcell Genel Mudurluk Aydinevler Mahallesi İnonu Caddesi No:20 Kucukyalı Ofis Park B Blok - Maltepe / ISTANBUL (via notary or registered letter with return receipt, etc.).

* As per the Law on Protecting of Personal Data numbered 6698, processing of personal data refers to any operation which is performed on personal data such as collection, recording, storage, retention, alteration, adaptation, disclosure, transfer, retrieval, making available for collection, categorization or blocking its use by wholly or partly automatic means or other than automatic means which form part of a filing system.