• INFORMATION NOTICE ON THE PROTECTION OF PERSONAL DATA

    The personal data within Winfluencer Digital Marketing Services Inc. (“Company”) is protected under the responsibility of the data controller, which is the Company. The Company takes necessary technical and administrative measures using its technological and infrastructure facilities to ensure the lawful processing and secure storage of personal data in accordance with Law No. 6698 on the Protection of Personal Data (“Law”).

    We process your personal data in compliance with the procedures and principles prescribed in the Law and other legislation. We process your personal data in a lawful and fair manner, accurately and, if necessary, up-to-date, for specific, explicit, and legitimate purposes. We assure you that we will retain your personal data for the maximum duration specified in the relevant legislation or for the period necessary for the purpose for which they are processed, and in any case, for the statutory limitation periods.

    You can access more detailed information about the processing of your personal data shared with Winfluencer.app through the text available on our homepage.

     

    • METHODS OF COLLECTING PERSONAL DATA AND LEGAL GROUNDS

    Winfluencer collects personal data in accordance with the provisions of Article 5 of the Law on the Protection of Personal Data, which are explicitly stipulated as follows:

    Being explicitly prescribed by the laws,
Being necessary for the performance of a contract to which the data subject is a party or for the conclusion of a contract,
Being made public by the data subject,
Being necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject,
Being necessary for the establishment, exercise, or protection of a right,
based on legal grounds through websites, mobile applications of websites, social media accounts, cookies, call centers, administrative and judicial notifications, and other communication channels in an audio, electronic, or written manner.

    Categorization of Data Subject Groups


    Winfluencer categorizes the data subject groups whose personal data is processed in the personal data processing processes and related activities as follows. However, personal data of other individual groups (consultants, educators, bloggers) may also be processed in accordance with the personal data processing conditions specified in Articles 5 and 6 of the PDPL and within the legal grounds stated in this text.

    Data Categories and Examples of Data Types


    i. Member Customer


    – Identity Information: Name, surname, date of birth, gender, national identification number


    – Location Information: City of residence, district (delivery address of purchases made through Winfluencer.com)


    – Contact Information: Mobile phone number, email address, address, postal code, landline phone


    – Financial Information: Tax office, invoice details


    – Customer/Member Information: Membership information, membership ID number


    – Customer/Member Transaction Information: Purchased product(s), purchase amount, purchase date, call center conversation records, commercial communication permission, utilized campaigns/contests, used coupons, information related to the order
Risk

    – Management Information: IP address
Transaction Security Information: Password, password information


    – Marketing Information: Cookie records, targeting information, evaluations showing habits and preferences


    – Audio Data: Call center conversation records


    – Legal Process and Compliance Information: Start and end time of the provided service, type of service utilized, amount of transferred data, electronic commercial communication consent given by the Data Subject, approved membership agreement, corporate membership agreement, other legal texts and contracts enabling the use of services provided by Winfluencer


    – Direct Marketing Information: Marketing SMS, email messages, or calls made by the call center sent based on the commercial electronic communication consent given by the Data Subject


    – Request/Complaint Management/Reputation Management Information: Records regarding complaints and/or requests submitted by the Data Subject through the website, mobile application, social media accounts, or call center regarding the purchased product or service, and the processes for evaluating or managing these requests

    ii. Guest Customer (non-registered users)


    – Identity Information: Name, surname, date of birth, national identification number


    – Location Information: City of residence, district (delivery address of purchases made through Winfluencer.com)


    – Contact Information: Mobile phone number, email address, address, postal code, landline phone


    – Financial Information: Tax office, invoice details


    – Guest Customer Transaction Information: Purchased product(s), purchase amount, purchase date, call center conversation records, commercial communication permission, utilized campaigns, information related to the order


    – Risk Management Information: IP address


    – Transaction Security Information: Password, password information


    – Marketing Information: Cookie records, targeting information, evaluations showing habits and preferences


    – Audio Data: Call center conversation records


    – Legal Process and Compliance Information: Start and end time of the provided service, type of service utilized, amount of transferred data, electronic commercial communication consent given by the Data Subject, other legal texts and contracts enabling the use of services provided by Winfluencer


    – Direct Marketing Information: Marketing SMS, email messages, or calls made by the call center sent based on the commercial electronic communication consent given by the Data Subject


    – Request/Complaint Management/Reputation Management Information: Records regarding complaints and/or requests submitted by the Data Subject through the website, mobile application, social media accounts, or call center regarding the purchased product or service, and the processes for evaluating or managing these requests

     

    iii. Online Visitor


    – Transaction Security Information: Password, mobile phone, password information


    – Legal Process and Risk Management Information: IP address


    – Legal Process and Compliance Information: Start and end time of the provided service, type of service utilized, amount of transferred data. 

    iv. Seller/Supplier/Seller Candidate/Seller or Supplier Employee or Representative


    – Identity Information: National identification number, name, surname


    – Contact Information: Email address, phone number, registered electronic mail (KEP) address, address, mobile phone


    – Financial Information: Account number, tax office, tax identification number, tax certificate, IBAN


    – Legal Process and Compliance Information: Signature circular, business license
Sensitive

    – Personal Data/Legal Process Information: Signature


    – Visual Information: Photograph

     

    1. HOW DO WE COLLECT YOUR PERSONAL DATA AND WHAT ARE THE LEGAL GROUNDS?

    We collect your personal data based on the following legal grounds: explicitly prescribed in the laws, necessity for the establishment of a commercial contract within the intended legal relationship between the Company and you, mandatory for us to fulfill our legal obligations, publicly disclosed by you (to the extent it is compatible with the purpose of disclosure), necessity for the establishment, exercise, or protection of a right, and necessity for the legitimate interests pursued by the Company, provided that it does not harm your fundamental rights and freedoms.

    We obtain your personal data electronically through channels such as email, relevant websites, and mobile applications that allow access to Winfluencer, as well as through social media accounts that you provide access to the Company. We may also collect your personal data through the call center channel or physically through mail/courier channels.

    We process your personal data based on your consent.

    • PURPOSES OF PROCESSING YOUR PERSONAL DATA

    Your personal data, as stated above, is processed within the scope of the following purposes, which are limited, reasonable, and proportionate:

     

    In order to fulfill the contract regarding the services provided by the Company:


    Delivery of orders to you


    Performance of the contract established with Winfluencer


    Follow-up of other processes related to the contract


    For the enhancement of user experience and the customization, recommendation, and promotion of products and services offered by the Company based on the preferences, usage habits, and needs of the relevant individuals:

    Planning and/or execution of user satisfaction activities


    Planning and execution of market research activities for the sale and marketing of products and services


    Planning and execution of marketing processes for products and/or services


    Planning and execution of processes aimed at obtaining the highest benefit from the products or services offered by the Company, enhancing the user experience, including making instant notifications by Winfluencer, determining user habits for targeting, profiling, and analysis, offering discounted campaigns, providing personalized content, digital marketing, targeting, remarketing (on-site remarketing), and advertising


    Planning and execution of sales, marketing, and optimization processes to improve user experience


    Evaluation, analysis, and optimization activitiesregarding advertisements targeting you, as well as the improvement of user experience, within the scope of the Company’s business and strategy processes


    Planning and execution of market research activities for the sale and marketing of products and services offered by the Company, including conducting market research and surveys


    In order to provide benefits to the relevant individuals from the products and services offered by the Company, and to carry out the necessary work and related business processes to enhance the experience of these users:

     

    Planning and execution of sales processes for products and/or services
Planning and/or execution of after-sales support service activities


    Planning and execution of user relationship management processes
Monitoring user requests and/or complaints


    Tracking of contract processes and/or legal claims

    In order to ensure the legal, technical, and commercial security of the Company and individuals associated with the Company in their business relationships, we undertake the following activities:

    • Planning and execution of Company audit activities
    • Planning and execution of operational activities to ensure that Company operations are conducted in accordance with Company procedures and/or relevant legislation
    • Ensuring the security of Company operations
    • Ensuring the accuracy and currency of data
    • Providing information to authorized institutions in accordance with the legislation
    • Carrying out necessary work by relevant departments to carry out the commercial activities conducted by the Company and the related business processes, including:
      • Planning, auditing, and execution of information security processes
      • Establishment and management of information technology infrastructure
      • Monitoring of financial and/or accounting affairs
      • Monitoring of legal affairs
      • Conducting effectiveness, efficiency, and/or appropriateness analysis of business activities
      • Planning and execution of business activities
      • Planning and execution of corporate communication activities
      • Planning and execution of logistics activities
      • Planning and execution of production and/or operation processes
      • Prevention of fraudulent activities
    • In the context of planning and executing the Company’s commercial and/or business strategies:
      • Management of relationships with business partners and/or suppliers
      • Execution of strategic planning activities
      • Planning of processes related to the Company’s business and strategies
      • Planning and execution of performance management processes. 
      •  
      • a.    Personal Data of Registered Customers
    • Processing of personal data for the registration process.
    • Improvement of services provided through the “Winfluencer.com” e-commerce platforms (“platform”) operated by Winfluencer, development of new services, and related information updates.
    • Analysis of preferences, likes, and needs of registered customers for the performance of the Membership Agreement; providing personalized promotions, opportunities, and benefits to registered customers.
    • Conducting marketing, targeting, profiling, and analysis based on the explicit consent of registered customers to promote and market applications, goods/products, and services in line with their preferences and likes.
    • Resolution of issues and complaints of registered customers.
    • Enhancement of the customer experience on both the platform and mobile application.
    • Tracking accounting and purchasing transactions.
    • Compliance with legal processes and regulations.
    • Responding to information requests from administrative and judicial authorities.
    • Ensuring information and transaction security and preventing malicious use.
    • Making necessary arrangements to ensure the accuracy and currency of processed data.
    •  
    • b. Personal Data of Guest Customers (users who make purchases without registering)
    • Ability to make purchases through the platforms as a “guest.”
    • Improvement of services provided through the platforms, development of new services, and related information updates.
    • Analysis of preferences, likes, and needs of guest customers for personalized promotions, opportunities, and benefits.
    • Conducting marketing, targeting, profiling, and analysis based on the explicit consent of guest customers to promote and market applications, goods/products, and services in line with their preferences and likes.
    • Resolution of issues and complaints of guest customers.
    • Enhancement of the customer experience on both the platform and mobile application.
    • Tracking accounting and purchasing transactions.
    • Compliance with legal processes and regulations.
    • Responding to information requests from administrative and judicial authorities.
    • Ensuring information and transaction security and preventing malicious use.
    • Making necessary arrangements to ensure the accuracy and currency of processed data.
    • Fulfillment of legal obligations.
    •  
    • c. Personal Data of Online Visitors
    •  
    • Processing of online visitor data in accordance with Law No. 5651.
    • Compliance with legal processes and regulations.
    • Responding to information requests from administrative and judicial authorities.
    • Ensuring information and transaction security and preventing malicious use.
    • Fulfillment of legal obligations.
    •  
    • d. Personal Data of Seller/Supplier/Seller Candidate/Seller or Supplier Employee or Representative
    •  
    • Execution of contract processes.
    • Tracking accounting and purchasing transactions.
    • Compliance with legal processes and regulations.
    • Responding to information requests from administrative and judicial authorities.
    • Ensuring information and transaction security and preventing malicious use.
    • Making necessary arrangements to ensure the accuracy and currency of processed data.
    • Fulfillment of legal obligations.

    Winfluencer is committed to taking all necessary technical and administrative measures to ensure the confidentiality, integrity, and security of your personal data.

    Winfluencer takes necessary precautions to prevent unauthorized access, misuse, unlawful processing, disclosure, alteration, or destruction of personal data. When processing personal data, Winfluencer employs generally accepted security technology standards such as security firewalls and Secure Socket Layer (SSL) encryption. Additionally, when you submit your personal data to Winfluencer through the website, mobile application, or mobile site, the data is transmitted using SSL.

    In order to prevent unlawful access, unlawful processing, and ensure the protection of personal data, Winfluencer:

    • Secures all areas of the website or mobile application where personal data is collected with SSL.
    • Establishes and implements access authorization and control matrices for employees to prevent unlawful processing of personal data collected from the website or mobile application.
    • Conducts periodic penetration tests to ensure the system’s resilience against unauthorized access.
    • Uses pseudonymization methods for all secondary data processes that deviate from the primary purpose of processing. Pseudonymous data is encrypted and subject to stricter access authorization and control policies to make it impossible to identify the relevant individual.
    • Ensures that personal data in paper form is securely stored in locked cabinets and accessed only by authorized individuals.
    • Deletes personal data processed through cookies belonging to third parties once the membership ends.

    In the event that personal data is compromised or accessed by unauthorized third parties as a result of attacks on the platforms operated by Winfluencer or the Winfluencer system, despite the necessary information security measures taken by Winfluencer, Winfluencer will immediately notify you and the Personal Data Protection Board and take necessary measures.

     

    Transfer of Personal Data to Third Parties

     

    Your personal data processed by Winfluencer may be shared with our domestic affiliates, shareholders, business partners, legally authorized public institutions, and private individuals, in accordance with the legal grounds specified in Article 2 and the purposes detailed in Article 3, in accordance with Article 8 of the Law. Additionally, your personal data may be shared with our overseas affiliates, shareholders, and business partners based on your explicit consent and in accordance with Article 9 of the Law, limited to the same purposes.

    Winfluencer only transfers personal data to third parties in accordance with the purposes stated in this document and in compliance with Articles 8 and 9 of the Personal Data Protection Law (PDPL). Within this scope, the Member Customer/Guest Customer data being processed, as well as the information about the person to whom the purchased product will be delivered, is shared with the seller and the courier company of Winfluencer, and these data can also be accessed by the call center when necessary. The information about the person to whom the invoice will be issued is shared with the courier company of Winfluencer for the purpose of delivering the invoice to the relevant person.

    The mobile phone number and/or email address belonging to the Member Customer/Guest Customer may be shared with a commercial electronic communication service provider for the purpose of sending promotional and advertising materials, benefits, and opportunities based on the consent for commercial electronic messages.

    Website or mobile application usage preferences and browsing history are shared with our domestic/foreign business partners for the purpose of segmentation and communication with the Member Customer/Guest Customer based on their preferences and choices, through the use of cookies.

    In this context, the personal data transfers are carried out through secure environments and channels provided by the relevant third party. Depending on the content and scope of the services received from third parties, data transfer is performed using pseudonymous data in all cases where the transfer of personal data of the Member Customer/Guest Customer is not necessary.
Data belonging to the Member Customer/Guest Customer is shared with Winfluencer’s conducting market research for the purpose of increasing customer satisfaction and loyalty.
Your personal data will also be shared with our overseas business partners for the provision of business development services, provision of statistical and technical services, and management of customer relations.

    If the Member Customer/Guest Customer/Online Visitor contacts Winfluencer via the corporate WhatsApp line, they will have sent their personal data abroad due to the fact that WhatsApp is a service provided from abroad. If the Member Customer/Guest Customer/Online Visitor does not want to send their personal data abroad by using WhatsApp, they can use other communication channels provided by Winfluencer.

    During the sharing of information as mentioned above, when personal information is transferred to countries outside of Turkey, the transfer of data is ensured to be made in accordance with the applicable data protection laws and in compliance with this policy, as allowed by the applicable law.

    In addition to technical measures ensuring their security, the personal data subject to the domestic and international transfers mentioned above are legally protected through the provisions included in our contracts, taking into account whether the counterparty of the legal relationship is the data controller or the data processor, in compliance with the PDPL.

    When transferring personal information to countries outside of Turkey as mentioned above, the data is ensured to be transferred in compliance with this policy and in a manner permitted by the applicable data protection laws.

     

    1. STORAGE PERIODS OF PERSONAL DATA

    Winfluencer retains the personal data it processes in compliance with the Personal Data Protection Law (PDPL) for the periods prescribed in the relevant legislation or as required by the processing purposes. Additionally, your personal data may be stored on a limited basis for the purpose of providing necessary defenses in case of any disputes between you and Winfluencer.

    You can refer to our Cookie Policy for information on the storage periods of personal data obtained through cookies.

     

    1. PROFILING AND SEGMENTATION

    By processing the personal data of Member Customers/Guest Customers, Winfluencer conducts profiling and segmentation to:

    1. Prepare more suitable content, advertisements, promotions, and discounts based on the preferences and choices of Member Customers/Guest Customers who have given consent to receive commercial electronic messages.

    2. Conduct product improvement by determining the best-selling or underperforming product categories.


    Analyze shopping preferences, create models to identify customer groups with a potential to purchase specific products, and organize and upload campaigns tailored to those customer groups, aiming to increase sales potential.

     

    Within the scope of profiling and segmentation, the personal data of Member Customers/Guest Customers, such as their full name, mobile phone number, email, or address information, are not directly used. Instead, these data are processed using Member Customer/Guest Customer IDs assigned to them. By using Member Customer/Guest Customer IDs or, in other words, pseudonymous data, the protection of personal data of the Customer/Member is ensured. Member Customer/Guest Customer IDs are only accessible to the relevant individuals or departments within Winfluencer. These IDs are encrypted and securely stored within the system by Winfluencer, and access is granted only to authorized personnel.

     

    1. RIGHTS OF DATA SUBJECTS AND HOW TO EXERCISE THOSE RIGHTS

    The rights that the data subjects have regarding their personal data processed by Winfluencer, in accordance with Article 11 of the PDPL, are listed below:

    • To learn whether their personal data is being processed,
    • To request information if their personal data has been processed,
    • To learn the purpose of the processing of personal data and whether it is used in accordance with its purpose,
    • To know the third parties to whom personal data is transferred, domestically or internationally,
    • To request the correction of personal data if it is incomplete or inaccurate,
    • To request the deletion or destruction of personal data in accordance with the conditions stipulated in Article 7 of the PDPL,
    • To request the notification of the operations carried out as per subparagraphs (d) and (e) to third parties to whom personal data has been transferred,
    • To object to the occurrence of a result against the data subject by solely relying on automated systems,
    • To request the compensation of damages in case of suffering damages due to the unlawful processing of personal data.

    To exercise your rights regarding your personal data, you can access your account through the “My Account” section on the Winfluencer website, mobile application, or mobile site and perform necessary changes, updates, and/or deletions. Additionally, you can make a request and exercise your rights through the “Application Form” provided in accordance with Article 13 of the PDPL on the website or mobile application of the electronic commerce platforms operated by Winfluencer.

    You can access the Personal Data Subject Application Form here.

     

    1. HOW INDIVIDUALS CAN CHANGE THEIR PREFERENCES REGARDING RECEIVING COMMERCIAL ELECTRONIC COMMUNICATIONS

    When signing up for or using the website or mobile application of electronic commerce platforms operated by Winfluencer, you can change or update your positive or negative preferences regarding receiving commercial electronic communications at any time by accessing the “My Account” section.

    Terminating your membership does not imply revoking your consent to receive commercial electronic communications. Therefore, make sure to complete all the necessary procedures to withdraw your consent.

    Regarding cookie management, you can follow the steps outlined in our Cookie Policy.

     

    1. SHARING PERSONAL DATA WITH OFFICIAL AUTHORITIES

    Winfluencer may share your personal data, including your visit or membership-related information, such as traffic data, with public institutions and organizations authorized to request such information legally when it is necessary for Winfluencer to fulfill its legal obligations (such as combating crime, threats to state and public security, and similar cases where Winfluencer has a legal or administrative obligation to provide notification or information).

     

    1. USE AND MANAGEMENT OF COOKIES

    For detailed information about the cookies used by Winfluencer, cookie types, purposes, storage periods, and cookie management, you can refer to our Cookie Policy.

     

    1. CONDITIONS FOR DELETION, DESTRUCTION, AND ANONYMIZATION OF PERSONAL DATA

    Winfluencer retains the personal data it processes through its website, mobile application, or mobile site for the periods stipulated by the Law on the Protection of Personal Data (PDPL) Article 7, 17, and the Turkish Penal Code Article 138, as well as the periods required by the processing purposes. At the expiration of these periods, Winfluencer will delete, destroy, or anonymize the personal data in accordance with the provisions of the Regulation on Deletion, Destruction, or Anonymization of Personal Data.

    Deleting personal data means making it permanently inaccessible and unusable for the relevant users. Winfluencer establishes and implements an access authorization and control matrix at the user level for this purpose and takes the necessary measures to carry out the deletion process in the database.

    Destroying personal data means making it permanently inaccessible, irretrievable, and unusable by anyone.

    Anonymizing personal data means rendering the personal data unable to be associated with an identified or identifiable natural person, even if it is matched with other data.

    Winfluencer’s Personal Data Storage and Disposal Policy, prepared in accordance with the Regulation on Deletion, Destruction, or Anonymization of Personal Data, provides detailed explanations of the methods, technical and administrative measures taken for deletion, destruction, and anonymization. The Policy also sets the time interval for periodic disposal as 6 months, as prescribed by the Regulation.

     

    1. MEASURES AND COMMITMENTS FOR DATA SECURITY

    Winfluencer undertakes to take the necessary technical and administrative measures, as well as perform the necessary audits, to ensure that personal data is not processed unlawfully, accessed unlawfully, and to safeguard the preservation of personal data at the appropriate security level in accordance with the relevant legislation or as expressed in this Policy.

    Winfluencer cannot disclose the personal data obtained about the Data Subject to third parties or use it for purposes other than the processing purposes, contrary to this Personal Data Protection and Processing Policy and the provisions of the Law.

    If there are links to other applications through the site, Winfluencer does not assume any responsibility for the data storage policies and contents of those applications.

     

    1. CHANGES

    Winfluencer may change the provisions of the Personal Data Protection and Processing Policy at any time within the scope of the legislation. The updated Policy shall become effective on the date it is presented to the Data Subject through any means.

    Winfluencer may make changes to this document at any time. These changes will take effect immediately upon publication of the modified new document. To be informed about these changes, necessary notifications will be made to our members.

     

    CONTACT INFORMATION

    Winfluencer Digital Marketing Services Inc.

    Email address: [email protected]