BiP PRIVACY POLICY (Clarification Text)

Release date: 05/05/2021

If you live in one of the European Union’s member states, you can review the Clarification Text we prepared for you.

Who are We?

BiP Application (“Application”) is offered by BiP İletişim Teknolojileri ve Dijital Servisler A.Ş.  (Hereinafter referred to as “BiP”, “We” or “our” in this document).

BiP, 6698 sayılı Kişisel Verilerin Korunması Kanunu’na (işbu belgenin devamında “Kanun” olarak ifade edilecektir) uBİP commits to safeguarding and protecting your personal data in accordance with the provisions of Law No. 6698 on Personal Data Protection (hereinafter referred to as the “Law”). This Clarification Text regulates the methods for obtaining, using, and sharing personal data. For the purposes of interpreting terms that are not defined in this Clarification Text, the definitions contained in BiP’s Terms of Use (“Terms of Use”) will be used. Additionally, you can read our  Cookie Policy or additional information about cookies.

Your Personal Data That Can Be Processed by BiP

While the information contained in this text may vary according to the products and services used by individuals, as well as their requests and consent, the categories of personal data that BiP may process are listed below.

  • Identity and Contact Information: Phone number, username (nickname), GSM operator and passwords used to keep the account secure.
  • Usage Information: Technical data collected from your device via technical equipment, type of messages sent (text message, video, picture, sticker, emoji), times actively used, type of services used, usage habits related to the Application interface, date of last login to the Application, usage of the Application Errors and information about the error that occurred during communication, type of communication (BiP Calls, instant messages), duration, date and time of communication. BiP does not collect any information about the content of the communications you send via the Application.
  • Personalization Information: Nickname, Profile Photo, Status Info, Blocked Numbers.
  • Location Information: Information about a user’s (approximate) location based on the settings of their device if they use location-based services.
  • Device Information: Model of the device, operating system, preferred phone language, information about the operator the user uses, and data about the country.
  • Backup Information: Contact data backed up upon request by users
  • Address Book Information: Contact list and phone numbers stored on the user’s device.

Method, Purpose and Legal Basis of Processing Personal Data

Your personal data may be processed in accordance with the legal reasons and purposes listed below via the website, mobile applications, short message, e-mail, and voice response system, using fully automated or partially automated methods.

  • Circumstances expressly stipulated in the law

Personal data listed in this Clarification Text may be processed in accordance with applicable law, provided that such processing is expressly permitted by the applicable laws to which BiP is subject.

Processed data: Identity and Contact Information, Subscription Information, Usage Information, Device Information, Location Information, Address Book Information.

Processing purposes: Fulfilling legal obligations required or mandated by legal regulations with regulatory and supervisory institutions, execution of legal proceedings and legal processes.

  • Provided that personal data processing is directly related to drawing up or performing an agreement, it is required to process personal data of the parties of the agreement.

BiP processes your personal data in order to present you with the application in accordance with the Terms of Service and our service standards.

Processed data: Identity and Contact Information, Usage Information, Personalization Information, Device Information, Backup Information, Address Book Information.

Processing purposes: Processing purposes include registering the application, providing communication, managing complaints, reporting errors and malfunctions, resolving them and responding to requests, detecting unauthorized and fraudulent use, performing and improving the service, optimizing the Application and services related to the Application, and ensuring that the user’s device belongs to the Application and works properly with the application’s settings.

  • Requirement for BiP to process data in order to comply with legal obligations

Personal data listed in this Clarification Text may be processed in accordance with applicable law, provided that such processing is expressly permitted by the applicable laws to which BiP is subject.

Processed data: Identity and Contact Information, Usage Information, Device Information.

Processing purposes: This scope includes data processing activities that arise from secondary legislation to which Turkcell is subject and are required to protect the parties’ rights or security, to respond to requests from authorized institutions and organizations, to manage the processes for responding to user requests and complaints, and to resolve potential disputes.

  • Making personal data public by the person concerned

During the course of using the application, your personal data that you voluntarily share with BiP and other users is processed.

Processed data: Identity and Contact Information, Personalization Information

Processing purposes: To enable other users to view your profile photo, nickname, and status information at your request.

  • Processing of personal data is required for the establishment, exercise, or protection of a right

Personal data may be processed to enable the user and third parties to exercise their legal rights or for BiP to provide services.

Processed data: Identity and Contact Information, Usage Information

Processing purposes: Utilization of statutory rights, particularly the user’s and third parties’ fundamental rights and freedoms, before all competent authorities, additional benefits provided by BiP and other institutions and organizations, the lottery, and fulfillment of all requests relating to these, execution of complaint management processes.

  • Processing personal data is required to protect BiP’s legitimate interests

BiP may process personal data if doing so is necessary for the company’s legitimate interests, provided that the user’s fundamental rights and freedoms are not harmed. When personal data is processed on this basis, BiP clearly defines its legitimate interests and maintains a balance between those interests and the users’ rights. The first priority should be to safeguard users’ fundamental rights, particularly their privacy, confidentiality, and personal rights.

Processed data: Identity and Contact Information, Subscription Information, Usage Information, Device Information, Location Information.

Processing purposes: Include determining and improving service quality, conducting service analysis, auditing and controlling services, risk management, detecting unauthorized and fraudulent use, and developing products and strategies.

If you give your explicit consent

If you activate some settings of your device (location information, access to camera and photos), your personal data is processed based on your explicit consent. For instance, if you give your explicit consent to share your location with a contact, your device’s location information will be processed.

If you wish to use certain services in “Keşfet” area, your location data will be processed as well.

If you choose to use the automatic translation feature, the words you send will be processed by a third-party service provider, which in this case will be the translation service provider. Within the scope of the translation service, user information is not shared with the translation service providers. We would like to remind you that if you use this feature, you will be subject to the terms and privacy policies of these service providers.

If you request a backup of your communication with other users, that communication will be archived in a secure manner accessible only to you.

Where is Personally Identifiable Information Stored?

BiP’s servers are based in Turkey, and all usage data is stored there as well.

Within the context of cooperation with operators located outside of this country, data relating to users in this country may be transferred to and stored on the servers of the relevant operator, consistent with their use of BiP in their home countries.

To Whom and For What Purposes Your Personal Data Are Transferred?

BiP may share the personal data it collects with the following parties in accordance with this Clarification Text. The information contained under this heading may vary by individual, depending on the products and services used by individuals, their requests and consent, and the legal reasons for compliance.

Authorized institutions and organizations in line with legal obligations: BiP does not share any data regarding the content of your communication established through the Application, even if there is a request from authorized institutions and organizations. BiP may share user data with the competent authorities to whom it is required to submit personal data in order to comply with a legal obligation and to protect its own rights and safety, as well as the rights and safety of third parties. BiP verifies the authorization of the requesting parties prior to sharing personal data.

If you choose to use the automatic translation feature, the words you send will be processed by a third-party service provider, which in this case will be the translation service provider. Within the scope of the translation service, user information is not shared with the translation service providers. We would like to remind you that if you use this feature, you will be subject to the terms and privacy policies of these service providers.

Your Rights about Your Personal Data

Users of the application will be able to use the following rights in accordance with Article 11 of the Law:

•  To learn whether personal data is processed or not,

• To request the information related to personal data if personal data has been processed,

• To learn the purpose of processing personal data and whether they are used in line with their purpose,

• To learn the third parties to whom personal data is transferred in the country or abroad,

•  To request the rectification of the incomplete or inaccurate data, if any,

• To request the deletion or destruction of personal data within the framework of the provisions specified in Article 7 of the Law,

• To request notification of the operations carried out for rectification, deletion, or destruction of personal data to third parties to whom his/her personal data has been transferred,

• To object to the processing of personal data exclusively through automated systems,

• To request compensation in case of suffering loss due to illegal processing of the personal data.

Please contact us using one of the following methods to exercise any of your respective rights. Kindly provide as much detail as possible about the data on which you wish to exercise your rights so that we can assist you in determining which data on which you wish to exercise your legal rights. Unless the request is manifestly unfounded or disproportionate, the information will be provided free of charge (in which case a reasonable fee may be charged or your request denied).

You may contact us via one of the following methods with any questions or requests regarding your Personal Data:

  • By using e-mail you have notified to BiP for the registration, send an e-mail prepared in accordance to Communiqué on the Procedures and Principles of Application to the Data Controller to kisiselverilerikoruma@bip.com
  • After printing out the Application Form on Personal Data  (https://bip.com/form/kisisel-veri-basvuru.pdf),  fill out in writing and send it to the address “BiP İletişim Teknolojileri ve Dijital Servisler A.Ş. Aydınevler Mahallesi İnönü Caddesi No:20 Küçükyalı Ofis Park B Blok – Maltepe/Istanbul” by attaching the documents proving your identity information to your application.
  • After printing out the Application Form on Personal Data, fill it out in writing and send it to the address “BiP İletişim Teknolojileri ve Dijital Servisler A.Ş. Aydınevler Mahallesi İnönü Caddesi No:20 Küçükyalı Ofis Park B Blok – Maltepe/Istanbul” through a notary public.

About the Clarification Text

BiP reserves the right to make changes to this Clarification Text at any time. In this case, the updated Clarification Text will be published and brought to your attention via the Application. BiP’s updates and changes to the Clarification Text are effective as of the date they are published in the Application.

The information contained in the Clarification Text may vary according to the products and services obtained by individuals, as well as their requests and consent.