PRIVACY AND SECURITY
The Client agrees that Lifecell Digital Ltd. (LDL and/or Paycell) to fully and completely fulfil its obligations in accordance with the legislation in transactions carried out primarily through the Representative, to determine the risk detection / level, to ensure the legitimate interests of LDL, to ensure the quality of service, to provide LDL Services and to fulfil its obligations arising from the relevant legislation, including expenditure and invoice information regarding the electronic communication services of the Customer, telephone number, identity number, name, surname, etc. identity information, address, contact information and the validity of this information, limit information, risk, transaction information etc., Turkcell Ödeme ve Elektronik Para Hizmetleri A. Ş. and other Turkcell Group Companies, Colendi Dijital Teknoloji ve Finansal Hizmetler A. Ş., Kıbrıs Türk Kooperatif Merkez Bankası Ltd. will process mutually with LDL personal information about the type of line (postpaid / prepaid, corporate / individual), the status of the line, the age of the line owner, the number of years the line has been active, the transfer of the line / change of line ownership, payment information of the line, temporary / permanent activation information, payment instructions, frequency and number of line top-ups, whether the line is active for mobile payment and making expenditures, and if active, the monthly expenditure limit and whether this limit has been reached, whether there is a failed transaction due to insufficient balance, and the number of failed transactions, and also that the information listed in this article should be processed mutually with Merchants / Payment Service Providers and Institutions / Business Partners / Representatives / External Service Providers / relevant Financial Institutions / Banks that provide goods and services to the Customer within the aforementioned periods and purposes. The Customer shall have the right to request LDL to provide any personal data relating to him/her in accordance with Articles 14 and 15 of the Personal Data Protection Act and this Agreement, to learn whether personal data are processed and their source, to request information if personal data have been processed, the purpose of the processing of personal data, the categories of recipients or recipients of this information and the categories of data that have been processed or are subject to processing, the progress made in processing since the previous information, the correction, deletion or blocking of the data, in particular the processing that has not been carried out in accordance with the rules of the relevant legislation due to inaccuracies and omissions, request notification of any correction, deletion and blocking made in accordance with the relevant legislation to third parties to whom the data is transmitted, unless it is not possible and does not require disproportionate effort, and at any time, for legitimate reasons related to the specific situation, has the right to object to the processing of the data of the customer that has been processed, is being processed or is planned to be processed. These rights can be exercised by sending a written request to paycelldestek@kktcell.com. In accordance with the above-mentioned requests, LDL may provide a reasoned positive/negative response in writing or digitally. It is essential that no fee is charged for the necessary transactions regarding the requests. However, if the transactions require a payment, it is possible to charge a fee based on the tariff determined by the Personal Data Protection Board in accordance with Article 37 of the Personal Data Protection Law. These rights can be exercised by sending a written request to paycelldestek@kktcell.com. In accordance with the above-mentioned requests, LDL may provide a reasoned positive/negative response in writing or digitally. It is essential that no fee is charged for the necessary transactions regarding the requests. However, if the transactions require a payment, a fee may be charged based on the tariff determined by the Personal Data Protection Board in accordance with Article 37 of the Personal Data Protection Law. The Customer may cancel the data processing permission within the scope of the above-mentioned by sending a written request to paycelldestek@kktcell.com. The cancellation of the data processing permission does not constitute an obstacle to the processing and sharing of Personal Data in the presence of exceptional circumstances listed by the Law on the Protection of Personal Data, such as the processing of information shared in accordance with this Agreement and which is mandatory to be processed for the provision of the LDL/Paycell Service under the Agreement and/or the performance of the legal obligations of LDL and the relevant Turkcell Group Company.
Information and Clarification Notice Regarding the Protection of Your Personal Data
Your personal data that you share with our Company (Lifecell Digital Ltd./LDL/Paycell) is under the protection of our Company. In this respect, in accordance with the Law No. 89/20027 on the Protection of Personal Data (KVKY), our Company takes all necessary technical and administrative measures by using all technological and infrastructural facilities to ensure that your personal data is securely stored, processed and accessed in accordance with the law. In line with the KVKY, your personal data are processed by our Company as the Controller in accordance with the KVKY and the relevant legislation, including but not limited to the following.
I.What are the LDL/Paycell Services?
LDL/Paycell offers payment and electronic money services provided by Turkcell Ödeme ve Elektronik Para Hizmetleri A.Ş. (TÖHAŞ), a Turkcell Group Company, within the scope of the authorisation obtained from the BRSA in accordance with Law No. 6493 and its subsidiary regulations. These services include Money Transfer, Bill Payment, Digital Money, Package/Contract Purchase, Mobile Payment, QR Payment.
II. What is Your Personal Data?
Your personal data means information that identifies or makes your identity identifiable. In line with the Purposes of Processing Your Personal Data, the following personal data may be processed.
· Identity, Address and Contact Information: Identification number, place and date of birth, name, surname, nationality, type and number of identity document, address and signature sample, telephone number, fax number, electronic mail address, if any, information related to work and profession. In the identification of legal entities registered with the Office of the Official Receiver and Registrar; the title, trade registry number, tax identification number, field of operation, open address, telephone number, fax number and e-mail address, if any, and the name, surname, place and date of birth, nationality, type and number of identity document, address and signature sample of the person authorised to represent the legal entity.
· Information on Service Usage: personal data containing usage details such as the amount of usage, the service you received and other records, voice call records kept by sales and customer representatives in accordance with call centre standards, data obtained when contacting our Company via e-mail, letter and other means, data obtained through sales such as requests and transaction information in sales channels. Information about the product/service, merchant, payment service provider, representative, etc. The amount related to LDL Services, service subscription information, information that will be requested to be processed or reported within the scope of the regulations to which our Company is subject, such as TRNC Central Bank, BRSA, and Masak.
· Other Personal Information: biometric signature, video/voice recording, photograph, address, location, risk/limit information, payment instruction information, whether the line is open to mobile payment, if the line is open to mobile payment, if the line is open to expenditure information, the monthly expenditure limit and whether there is a failed transaction due to reaching this limit/insufficient balance, the number of failed transactions, personal information about risk information.
· Line, data and transaction information: Personal data that enables us to identify the subscriber such as customer name, surname, telephone number, e-mail address, user ID for subscription and payment type, service subscriptions, line/subscription type (postpaid/postpaid, corporate, individual), status, channel, age of the owner, subscription period, transfer/line ownership change, balance, payment information and temporary/permanent activation information expenditure and invoice, upload frequency and number, phone number, limit (if the line is open, monthly spending limit and information on reaching this limit), whether there is a failed transaction due to insufficient balance, risk information on the number of failed transactions, whether the line is open to mobile payment, invoice date as included in the invoice, address information, invoice number information and any updates to this information.
III. Purposes of Processing Your Personal Data
Your personal data may be processed in order to ensure that LDL Services can be provided smoothly, obligations are fulfilled fully and completely in accordance with the legislation, including identification, complaint processes, and to ensure service quality. In this context;
· If you participate in a special prize, lottery, competition or similar event, the information you provide in this context is used for the event,
· In addition to billing for your usage, taking the necessary actions to prevent abuse, loss and fraud,
· Announcing our company's co-operations and contacting you in case you benefit from these rights,
· Confirmation of your identity information when necessary, transaction limit, monthly limit, etc. risk scoring and score control and reporting, realisation and follow-up of the transaction you have requested for the purpose of providing and informing the services, products and services ordered, purchased and / or used,
· To be used for internal purposes such as the development of our company's products, services and network, audit, data analysis, forecasting, and to respond to questions, complaints and notifications from you,
· The creation of a register with the intention of selling a specific service and/or product,
· Delivering/presenting our products and services to you, evaluating your interest in our products and services, researching your customer satisfaction with strategic partners who work with our Company to offer our products and services or assist our Company in providing services to you,
· Providing financial reconciliation with our business partners and other third parties regarding the products and services we offer you, ensuring the realisation of the products and services offered together with our business partners and other third parties,
· Identifying your location in case of an emergency call for help and sharing it with authorised institutions,
· Provision of services within our Company, determination/management/detection of risk level,
· Preservation of your information that must be kept for the performance of the service we provide to you in accordance with the relevant legislation, copying, backing up, ensuring the consistency of your information, taking all necessary technical and administrative measures for the data security of our networks,
· Sharing with regulatory and supervisory authorities and judicial authorities as required or obliged by legal regulations, in order to ensure the fulfilment of legal obligations,
· For the purposes falling within the exceptional circumstances set out in Article 6 of the KVKY
· Provision of ancillary services offered by our Company, diversification, measurement and announcement of products and services, such as the provision of call centre services, financial reporting, legal follow-up and similar issues may be processed.
In matters that do not fall within the exception of KVKY, if you give your consent to our Company in a way that does not raise any doubt about the processing of your personal data, your personal data may be processed within the scope of LDL Services in order to determine the risk detection / level, to carry out customer recognition processes and identity verification, to manage complaint processes more effectively, to recommend special products and services to you, to make promotions, campaigns and marketing and to achieve the targeted service quality. In this context, your personal data may be processed by our Company for the purposes of;
· Promotion of general and special campaigns regarding the products and/or services of our company, informing you about discounts, benefits, conditions, pricing and similar issues regarding the products and/or services of our company, providing opportunities such as membership, invitations, benefiting from events and carrying out all kinds of transactions necessary for their use,
· Informing and reminding you about special celebrations, wishes, awards, sweepstakes and content that you like, that you may want to access again, that you may be pleased to be reminded of, offering gifts in order to ensure your satisfaction and providing information about them, contacting you about the use of gifts,Size özel kutlama, temenni iletimi, ödül, çekiliş ve beğendiğiniz, tekrar erişmek isteyebileceğiniz, hatırlatılmasından memnuniyet duyabileceğiniz nitelikteki içeriklerin bilgilendirilmesi ve hatırlatılabilmesi, memnuniyetinizin sağlanması amacıyla hediyeler sunulması ve bunlar hakkında bilgi verilmesi, hediye kullanımları ile ilgili iletişime geçilmesi,
· Offering suggestions based on the way the products and services are used within the scope of your satisfaction and loyalty programmes, providing information about promotions, extending special offers, gifts and providing information about them, communicating about the use of gifts, announcing the collaborations made by our Company on your behalf and communicating to customers who benefit from these rights, promotional and marketing activities.
IV.Processing and Transfer of Personal Data
Our Company may process your personal data within the scope of the Law and other legislation in order to fulfil the processing purposes described above;
· Turkcell Grup Şirketleri
Turkcell group of companies in Turkey and abroad listed at https://www.turkcell.com.tr/tr/hakkimizda/genel-bakis/istiraklerimiz
· Business Partners: Courier companies, payment service providers and other financial institutions, representatives, External Service Providers, Merchants, Payment Service Providers and Organisations, business partners, Representatives, relevant Financial Institutions, Banks and other third parties contracted by LDL for the supply, delivery and presentation of the products and services you want to purchase or use,
Your personal data may be transferred to necessary and authorised persons and organisations in Turkey and abroad, including but not limited to all kinds of suppliers, banks, financial institutions and other real or legal persons and their business partners, courts and execution offices where lawsuits and legal proceedings regarding our Company's receivables are carried out, competent authorities that will determine your location in case of an emergency call for help, lawyers, auditors, consultants and other third parties from whom services are received, your attorneys and representatives authorised by you, regulatory and supervisory institutions and other official institutions, public institutions or organisations authorised to request your personal data.
V. Method and Legal Grounds for Collecting Personal Data
Your personal data may be collected, processed and transferred for the above-mentioned purposes by fully automated, partially automated or non-automated methods, based on your consent for the processing of your personal data or on the legal reasons specified in Article 6 of the KVKY or other legislation and specified below, through the contracts you have signed with LDL, its representatives and other face-to-face channels, call centre, website, mobile applications, text message, electronic mail, voice response system and all kinds of written, verbal and electronic media.
· It is stipulated in the local legislation to which LDL is subject,
· It is necessary for the fulfilment of a contract to which you are a party or, upon your request, to take measures before you become a party to the contract,
· It is necessary for the protection of your vital interests,
· Processing is necessary for the performance of a task on behalf of the public interest or for the performance of a public authority vested in our Company or a third party to whom the data is transmitted,
· It is necessary for the purposes of legitimate interests pursued by our Company or the third party to whom the data is transmitted, except where your rights, interests and fundamental freedoms prevail,
VI. VI. Your Rights Regarding the Protection of Personal Data
In accordance with Articles 14 and 15 of the Law, by applying to our Company, you have the right to;
· Enquire whether your personal data is being processed and the source thereof
· If it is processed, to request information about it,
· To be informed about the purpose of processing personal data, to be informed about the categories who have received or are receiving this information and the categories of data that have been processed or are subject to processing,
· The progress made in processing since the previous notification,
· Correction, erasure or blocking of data, in particular processing that has not been carried out in accordance with the rules of the relevant legislation due to inaccuracies and omissions,
· Request notification of any correction, deletion and blocking made in accordance with the relevant legislation to third parties to whom the data is transmitted, unless it is impossible and does not require disproportionate effort,
· Object at any time, for legitimate reasons relating to the particular situation, to the processing of your data that has been, is being or is planned to be processed.
VII. Security
Do not share your Paycell/LDL Card information; password, card number, expiry date and CVV number of your card with anyone.
· Do not share your password or one-time verification codes associated with Paycell/LDL products with anyone for your own security and ensure the necessary safety regarding your password, payment instrument and similar sensitive payment information.
· In case of theft / loss of the payment instrument or in cases that threaten the security of sensitive data, you must immediately notify Paycell (Company)'s call centre at 0533 878 10 18.
· In case of theft or loss of your Paycell Card, you can cancel your card via the call centre of Paycell (Company) at 0533 878 10 18, request the transfer of your current balance to a new card or refund to your bank account.
· If you detect a transaction that does not belong to you during your transactions using Paycell products or while reviewing the transactions made, or if you notice a transaction that is suspected of fraud and scam; You should notify Paycell (Company)'s call centre by calling 0533 878 10 18 without delay. The Company is not responsible for any damages and losses that may arise due to transactions made by third parties. Your rights and responsibilities as a Paycell/LDL user are included in the Framework Payment Services and Electronic Money Agreement signed/approved with our Company.
· Paycell/LDL does not, under any circumstances, ask for your e-mail address, password, credit card password, CVV number or money transfer via call or SMS. Therefore, do not rely on any calls received on behalf of our Company or on behalf of someone else with the aforementioned and similar requests.
· Do not use easy-to guess numbers such as date of birth, repetitive numbers or consecutive numbers when setting your password for Paycell Card and Paycell app.
· For your Paycell Card password blocking transactions, you can contact the call centre of Paycell (Company) at 0533 878 10 18 and request unblocking after completing the necessary security steps.
· You can change your password for your Paycell Card via Paycell app and set a new password.
· If your password for the Paycell app is blocked, you can change your password from the "Change App Password" section on the Paycell app.Paycell uygulamasına ait şifrenizi Paycell uygulaması üzerinde yer alan “Uygulama Şifresini Değiştir” kısmından değiştirebilirsiniz.
· You can open the Paycell app on only one device at a time. If you log in on a different device, your session on the other device will be automatically terminated.
· To protect your mobile phone on which you use the Paycell app, use security software from reliable software companies, do not install unlicensed apps or those of unknown origin.
· Make sure you are using the latest version of the Paycell app.
· You can use the Paycell app to check your transaction and balance information. Please download the Paycell app to your mobile phone from the official app stores (such as Google Play, Apple Store).
· You can share your feedback about the Paycell app or your Paycell Card via the call centre of Paycell (Company) at 0533 878 10 18 or by using the "contact us" section on the Paycell app.
· The e-mails that we send have kktcell.com extension. Do not rely on any e-mail address that appears to be sent from our company but does not have kktcell.com extension.
· Do not enter your personal information, app password, card numbers or card passwords on the pages you access by clicking on links received via SMS or e-mail.
· Enter any information (password, reference code, etc.) in a way that is not viewable by others while making transactions at the ATMs. Do not leave the ATM while making a transaction and do not seek help from others.
· As Paycell, we contact you about innovations in our products and services via your e-mail address or mobile phone number that you have entered in your Paycell account.
· For any questions and issues regarding PAYCELL POS transactions, you can contact the Paycell (Company) call centre at 0533 878 10 18.
You can send your requests regarding the implementation of the law and any questions regarding your personal data to Lifecell Digital Ltd. Organize Sanayi Bölgesi. 7. Sokak. No.8 Lefkoşa (notary, registered letter with return receipt, etc.) in writing. *Pursuant to the Law No. 89/2007 on the Protection of Personal Data, the processing of personal data refers to the implementation of any, several or all actions such as collecting, recording, processing, storing, storing, deleting, evaluating, using, adapting or modifying, halting, destroying all data relating to the person, using any method and means.