BiP Privacy NoticePublication Date: 05/05/2021
Who We Are
The BiP Application (“Application”) is provided by BiP İletişim Teknolojileri ve Dijital Servisler A.Ş. (hereinafter to be referred to as “BiP”, “we”, “us”, “our”).
BiP is committed to protect and respect your Personal Data in accordance with the applicable data protection legislation, including the provisions of General Data Protection Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data and other applicable laws (hereinafter referred to as the “Data Protection Legislation”).
How are Your Personal Data Collected?
BiP collects your Personal Data, directly from you when you provide us with information or when you transmit information through the Application, depending on the products or services you use. This includes information you provide when you register to use the Application, create an account, set up a profile, complete a form or correspond with us, and use the Application.
Which Personal Data are Collected?
Although the information in this transcript may differ from user to user due to circumstances such as differences of products and services that people benefit from or their requests and consents, the categories of your Personal Data that are processed by BIP are as follows.
• Identity and Contact Details: data such as your phone number, user name (nickname), GSM operator, passwords which are used to keep the Application safe.
• Usage Information: Technical data collected from your device through technical equipment, the type of messages (text message, video, photo, sticker, emoji), active time, type of services used, usage habits related to the application interface, the last access to the application date, errors and information about the error that occurred during the use of the application, data related to the communication type (BiP Calls, instant messages etc.), the duration, time, type, parties and contacts of communication.
BiP does not collect any data related to the content of your communication made via the Application.
• Personalization Information Nickname, Profile Photo, Status Information, Blocked Numbers.
• Location Data: The location data of the users depending on whether you use the location related services and the settings of your device.
• Device Data: Device model, operating system of the device, preferred phone language, information regarding which operator the users use, country information.
• Backup Data: The communication data, if only the user requests data to be backed up by BiP.
• Address Book Data: Contact List containing phone numbers stored on the user’s device.
Purposes and Legal Basis for Processing Your Personal Data
Your Personal Data is processed for the purposes and legal basis which are explained below, by our web site, mobile apps, SMS, e-mail, call center and interactive voice response (IVR) system, via wholly automated or partly automated means.
- Where processing your Personal Data is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract;
We process; Identity and Contact Details, Usage Information, Personalization Information, Device Data, Back-up Data, Address Book Data,
For the purposes of; user registration, communication, complaint management, error/failure notice, prevention of unauthorized and fraudulent use, optimization of the Application and related services and enabling the device to work properly with the Application and its settings.
- Where processing is necessary for the compliance with a legal obligation to which BiP is subject;
BiP processes your Personal Data when we comply with a legal obligation as set out below.
We process; Identity and Contact Details, Usage Information, Device Data, Personalization Data, Location Data, Address Book Data,
For the purposes of; replying to a valid request as an order from authorized public institutions and organizations, execution of the complaint management processes, resolution of possible disputes arising from the laws or secondary legislation to which BIP is subject and in order to protect the rights or security of the parties.
- Where processing is necessary for the purposes of the legitimate interests pursued by BiP or by a third party:
BiP processes your Personal Data when processing is necessary for our legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms of users. When we process Personal Data for our legitimate interests, we identify these interests and establish the balance between those and data subjects’ rights. Users’ right to privacy and other personal rights are our top priority.
We process: Identity and Contact Details, Usage Information, Device Data, Personalization Information, Location Data,
For the purposes of: measurement of the service quality, service analysis, business, product and strategy development, intra-company evaluation, supervision and control, risk management, prevention of unauthorized and fraudulent use, management of the customer survey process, measurement and development of the service quality.
- Upon Your Request
BiP processes your Personal Data for the purposes described below when you have given us your consent or when you demand some of the features of the application:
Depending on whether you use the location related services and you set the settings of your device; your devices location data is processed for the purposes of allowing you to share your location with other users and supervising and controlling location services associated with the “Discovery” area.
Similarly, in case you wish to share photos or videos from your phone’s gallery to other users or take a photo in BiP, your photos and videos is processed for the purposes of enabling you to share visual and audio recordings.
When you use the translate services, your personal information is not shared, only the words you send are processed by a third-party service provider. We would like to state that when you use these services, you are subject to these service providers’ own terms and conditions and privacy policies.
When you would like to back up your communication history, the messages that you received from or sent to another user shall be archived only upon your request.
Where are Personal Data Being Stored and Processed?
BiP servers are located in Turkey, all data is stored for use in Turkey.
Within the scope of cooperation of operators abroad, in line with the use of BiP in their own countries, data related to users of these countries can be transferred to the relevant operator and stored on that operator’s servers. BiP takes all reasonable steps to ensure that the Personal Data is treated securely and transfer of Personal Data takes place only where appropriate safeguards are in place that ensure the level of protection of parties.
With Whom and For What Purposes are the Personal Data Shared?
BiP may share the Personal Data it has obtained with the following parties in accordance with the purposes and regulations set out in this Notice. The information under this section may differ from person to person due to circumstances such as the products and services that people benefit from or their requests and consents.
Law enforcement, regulators and other parties for legal reasons: BiP is obliged to provide Personal Data within a legal obligation and in order to protect both its own rights, property or security and the rights, property or security of third parties with authorities. BiP reviews whether the requesting parties are authorized for such request before sharing your Personal Data.
If you activate automatic translation functionality, personal information will not shared, the submitted words will be shared with a third-party service provider. BiP is not responsible for such third-party service providers. We would like to remind you that you activate this feature, you will be subject to terms and privacy policies of these third-party service providers.
Your Rights Regarding Your Personal Data
The Application users have the right to:
- Right of access – the right to be informed of, and request access to, the Personal Data BiP processes about you;
- Right to rectification – the right to request that BiP amends or updates your Personal Data where it is inaccurate or incomplete;
- Right to erasure – the right to request that BiP deletes your Personal Data;
- Right to restrict – the right to request that BiP temporarily or permanently stops processing all or some of your Personal Data;
- Right to object –
- the right, at any time, to object to BiP processing your Personal Data on grounds relating to your particular situation;
- the right to object to your Personal Data being processed for direct marketing purposes;
- Right to data portability – the right to request a copy of your Personal Data in electronic format and the right to transmit that Personal Data for use in another party’s service; and
- Right not to be subject to automated decision-making – the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
In order to exert any of your rights stated above in relation to your Personal Data, please contact us using the contact details set out in the “Contact Us” section below. In order to help you find the data you would like to use your abovementioned rights, please provide as much information as you can about the data you would like to use your rights. Information provided shall be free of charge, unless the request is clearly unfounded or disproportionate, in which case a reasonable fee may be requested, or the request may be refused. Users also have the right to lodge a complaint with a local supervisory authority.
Alternatively, you can forward your questions and requests regarding your Personal Data via one of the following methods:
(ii) Once you print out the Personal Data Application Form, by completing the form in writing and sending it to “BiP İletişim Teknolojileri ve Dijital Servisler A.Ş. Aydınevler Mahallesi İnönü Caddesi No:20 Küçükyalı Ofis Park B Blok – Maltepe/İstanbul” address via the notary public.
(iii) Send an e-mail to email@example.com by using your e-mail address which is previously notified to BiP, applied and registered in the BiP’s system.
Users must be 16 years of age or older to subscribe, register or share any Personal Data to the Application and we do not intend to solicit, collect or process Personal Data of Users under the age of 16. In certain jurisdictions, the age may be older than 16, in which case, you must satisfy that age in order to become a subscriber. If you believe we have inadvertently processed Personal Data of a User under the age of 16, please contact us at the details provided. If we discover that we have inadvertently processed the Personal Data of any user under the age of 16, we reserve the right to delete it.
Retention Period of Personal Data
Automated Decision Making
We do not use Personal Data to make automated decisions about users.
About This Notice
BiP shall update and change the provisions of this Notice, e.g. in case of any change/update in the Data Protection Legislation, in which case the updated Notice will be brought under your attention by publishing it via the Application. Updates and changes in the Notice made by BiP shall be effective as of the date of its publication on the Application. The information in this Notice may differ from person to person due to circumstances such as products and services that people benefit from or their requests and consents.
Questions, comments and requests regarding this Notice can be addressed via email at firstname.lastname@example.org or in writing to the below e-mail or postal addresses:
Data Protection Officer