LIFECELL DIGITAL LTD. PRIVACY POLICY

INFORMATION ABOUT THE PROTECTION OF YOUR PERSONAL DATA
The personal data collected and processed by Lifecell Digital Ltd. are under the protection of Lifecell Digital Ltd. Lifecell Digital Ltd. takes the necessary technical and administrative measures by using its technological and infrastructural facilities to ensure the safe storage and processing of personal data within the framework of the Personal Data Protection Law No. 89/2007 (the "Law") and the relevant legislation. Personal data is processed by Lifecell Digital Ltd. in accordance with the Law and related legislation within the scope of the Lifecell Digital Ltd. Privacy Policy. By examining the text below, natural persons whose personal data are processed within the scope of the law may obtain information about the personal data that can be processed by the controller Lifecell Digital Ltd. as a controller and the purpose of processing, the categories of recipients to which it can be transferred to, the method of collection and legal reasons and their rights regarding the said personal data.

I. WHAT ARE YOUR PERSONAL DATA?
Personal data refers to all types of information about an identified or identifiable person. Your personal data that may be processed by Lifecell Digital Ltd is stated below including but not limited to: 

Identity Information: This category of data refers to data types such as identity or passport number, name, surname, place and date of birth, marital status, gender, identity document copy, photograph. 
Contact Information: This data category refers to data types such as address, telephone / fax number, e-mail address. 
Subscription Information: This data category refers to data types such as customer number, subscription contract number, subscription type and status, tariff and bundle information, value-added service subscriptions, and your information about the use of products and services, invoices, debts and payments. Network, Traffic and Location Information: This data category refers to data types such as the date, time, duration of calls and messages, and your internet traffic data such as date and time of connection, exit date and time information, source and destination information, and other connection information regarding the access to the internet, information about the device used and the SIM card and the location information of the device in question, your usage data generated in line with the use of products and services and the technical data required for the provision of services. 
Information in Sales Channels: This data category refers to types of data such as; the information and documents you transmit during the sales processes; data obtained when communicating via electronic or physical means; your voice conversation recordings kept in accordance with call centre standards; your voice recording to be used as an authentication tool upon your request; your request and transaction information in sales channels. 
Information About Usage of Products and Services: This category of data includes your preferences, habits and other usage information regarding the use of products and services; your behavioural information and cookies on websites and mobile applications created for the provision, use or promotion of products and services by third parties that are in cooperation with or by Lifecell Digital Ltd itself, especially in www.lifecelldigital.com and refers to the types of data that can be collected through mobile applications such as device, network, web, application, location and usage information.
Payment, Banking and Risk Information: This data category is used to pre-evaluate financial adequacy as part of device offers and subscriptions to services; Payment performance including the past period, bank information where the payment was made, subscription age, subscription information, location information, mobile payment usage information of the line, prepaid line usage data, if any, etc., in case of providing service through Lifecell Digital Ltd, payment information types such as limit / risk, matters affecting the limit, payment delay and withdrawal data from financial institutions.
Sensitive Personal Information: This category of data refers to data types such as (i) health data belonging to segments that must be socially supported (such as the disabled, disabled veterans) and (ii) association, foundation or union membership information.

II. PURPOSES OF PROCESSING PERSONAL DATA
Your personal data may be processed for the following purposes in accordance with the legislation on the protection of personal data: Offering, pricing, and invoicing of products and services; performing and following up the transactions you request for the products and services ordered, purchased and / or used, Informing about the promotion and marketing of products and services, campaigns, discounts, benefits, conditions, pricing; providing opportunities such as membership, taking advantage of events and economic advantages and carrying out the necessary procedures for their use, providing you with offers, gifts and promotions, running targeted promotions; delivery of personalized celebrations, messages of wishes, awards, sweepstakes and content that you like, that you may want to access again, that you would be pleased to be reminded of; in case you participate in a prize, raffle, competition or similar event, the information you provide in this context is to be used for the event, confirming your identity information and documents when necessary; performing your credit check and reporting; taking necessary actions to prevent abuses, loss and fraud, management of network traffic, detection of irregularity / fraud and conducting similar procedures, and resolution of disputes, starting with consumer complaints, conducting studies such as developing, diversifying, measuring, auditing and analyzing products and services and networks, training of employees, financial reporting; evaluating your interest in products and services, researching customer satisfaction; providing call center service; Responding to questions, complaints and notifications from you, providing and promoting the products and services we provide together with our business partners and their own products and services and establishing a financial agreement with these people, detecting your location in case of emergency calls and sharing it with authorized institutions, preservation of your information that must be kept in accordance with the relevant legislation; copying and backing up to prevent information loss; providing the consistency check of your information; Taking necessary technical and administrative measures for the security of our networks and your information, fulfilling the legal obligations required or mandated by legal regulations with regulatory and supervisory institutions, carrying out legal proceedings and legal processes.

III. TRANSFER OF PERSONAL DATA
Lifecell Digital Ltd. will be able to transfer your personal data to the following domestic and foreign receiver categories within the scope of the Law and other legislation for the purposes specified in this Policy:

Turkcell group companies and their business partners and authorized persons acting on behalf and account of Lifecell Digital Ltd., the suppliers and business partners we work with to supply or deliver the products and services you want to purchase or use to you, our business partners, supplier companies, banks, and financial institutions that we cooperate with and / or receive services for the presentation, promotion of products and services and similar purposes, the competent authorities that will detect your location in case of an emergency call, lawyers, auditors, consultants, and service providers, your attorney, legal guardian and representatives authorized by you, regulatory and supervisory institutions and institutions or organizations authorized to request your personal data such as courts and enforcement offices and their designated persons, invoice amount and your payment information for electronic communication services that are needed to manage the risk related to collection and to prevent malicious use, your device information, your segment information in Lifecell Digital Ltd., and information about your product and service usage, Lifecell Digital Ltd. Legal entities that have a commercial relationship with that has your phone number,

IV. THE METHOD OF COLLECTING PERSONAL DATA AND ITS LEGAL REASON
Your personal data may be collected, processed and transferred through verbal, written, subscription agreements, dealers and other face-to-face channels, physical or website such as call centre, mobile applications, text message, e-mail, voice response system and all kinds of voice recording, written and verbal electronic media, based on your consent to the processing of your personal data or as stipulated in Articles 6 and 7 of the Law or on the legal grounds specified in other legislation and stated below, in whole or in part; it may be collected automatically or through non-automatic methods or tools, for the purposes specified in this Policy.

It is necessary to fulfil the legal obligation to which Lifecell Digital Ltd. is subject to, it is necessary for the fulfilment of a contract to which you are a party or to take action before becoming a party to the contract upon your request, it is necessary for the protection of your vital interests, it is necessary for the performing of a task in the public interest or for the exercise of public authority vested in Lifecell Digital Ltd or a third party to whom the data is transmitted, it is mandatory to process the data for the legal interests of Lifecell Digital Ltd. or the third party to whom the data is transmitted, provided that it does not harm your fundamental rights and freedoms.

V. YOUR RIGHTS FOR THE PROTECTION OF PERSONAL DATA
In accordance with Articles 14 and 15 of the Law or other legislation, by applying to Lifecell Digital Ltd. using the methods specified in the "Communication" section of this Policy, you have the rights mentioned below;

Learning whether your personal data is processed or not, all your processed personal data as well as their source, the purpose of processing your personal data, those who receive this information or the categories that receive this information, and the categories of the data processed or being processed, to obtain information about the progress made in processing since the notification of your personal data, requesting correction, deletion or blocking of personal data in case of incomplete or incorrect processing in accordance with the legislation rules, request notification of the third parties to whom your personal data is transferred, as long as it is not impossible and does not require disproportionate effort about procedure made pursuant to your above-mentioned correction, deletion and blocking rights, to object to the processing of your processed, being processed or data that is planned to be processed at any time, for legitimate reasons regarding the specific situation.

VI. CONTACT
You can send your requests under the law and questions regarding your personal data with a petition that you have prepared properly and approved by the certification officer Şht. Arif Salih Sokak, No: 7, Nicosia.

VII. ABOUT THE POLICY
This Policy will be effective as of the date of publication by Lifecell Digital Ltd. Lifecell Digital Ltd may make changes to this Policy at any time if necessary. Changes to be made by Lifecell Digital Ltd will become effective immediately upon publication of the Policy on its address. We recommend that you check our website periodically so that you can follow the changes in the policy.

The information in the policy may differ from person to person due to matters such as products and services that people benefit from or their requests and consents.