BiP PRIVACY NOTICE

Publication Date: 14/01/2021

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 the Law No. 6698 on the Protection of Personal Data, 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”).

This Privacy Policy (“Policy“) regulates the ways in which information (“Personal Data“) that makes your identity specific or identifiable (“you”, “you” or “belonging to the user”) can be collected, used and shared. If you have a request concerning this Notice or if you have a complaint, please contact us through our Data Protection Officer whose contact details are provided under “Contact us” section below. You may also contact your local data protection authority. For the interpretation of undefined terms stated in this Notice, we refer to the definitions as used in the internal BiP terms of use of BiP (“Terms of Use”).For more information about cookies please also read our cookie policy.

In What Way are Your Personal Data Collected?

BiP collects your Personal Data, depending on the products or services used, if you directly provide us with your own will or when you transmit information through the Application.This include information you provide when you register to use the Application, create an account, set up a profile, complete a form, correspond with us, purchase products through the Application or respond to surveys or promotions. In the following sections, you may find detailed information on which data are collected for which purposes.

Which Personal Data are Collected?

Although the information in this transcript may differ from person to person due to issues such as the products and services that people benefit from or their requests and consents, the categories of your personal data that can be processed by BIP are as follows.

For What Purposes Your Personal Data are Processed?

Depending on the relationship you have established with BiP, your Personal Data may differ from person to person depending on the product / services used, but in accordance with the legislation on the protection of personal data, it may be processed for the following purposes and legal grounds specified in the legal basis article.

BiP may anonymize and aggregate any of the data which has been collected (so that it does not directly or indirectly identifies or specifies the users). BiP may use anonymized data for purposes that include testing its IT systems, research, data analysis, improving the Application, developing new products, advertisement, profiling and features or displaying information via the Application

What is The Legal Basis for Processing the Personal Data?

BiP is obligated to process the Personal Data in accordance with the above-mentioned purposes and in compliance with the applicable Data Protection Legislation. The Personal Data processed by BiP may be required for registering the use of the Application, creating an account, setting up a profile, completing a form, corresponding with BiP, purchasing products through the Application or responding to surveys or promotions, for which the user has given its consent.

Although the legal basis for the processing of Personal Data may differ from person to person due to the following legal reasons, products and services used by individuals, or requests and consents, the user can withdraw the consent at any time in cases where the user has given consent as the legal basis for the processing of Personal Data, the user always has the right to withdraw consent at any time.

Personal Data may be collected wholly or partially via automatic or non-automatic methods, processed and transferred for the purposes contained in this Notice based on legal grounds indicated in Articles 5 and 6 of Law on the Protection of Personal Data and listed hereunder and also Article 6 of GDPR (or other Applicable Data Protection Legislation)

Purpose Limitation

The Personal Data may only be processed to the extent necessary for the purposes described above. Personal Data may not be processed for other purposes other than that for which the Personal Data were collected. If there is a necessity or need to process Personal Data for other purposes, BiP shall investigate whether the purposes of the intended data processing are compatible with the original purposes. BiP shall provide the user prior to that further processing with information on that other purpose. BiP shall minimize data processing as is reasonable and appropriate to do so.

Where is 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 in compliance with this Notice and the Data Protection Legislation. The transfer of Personal Data take place only in compliance with the applicable Data Protection Legislation, and where appropriate safeguards are in place that ensure the level of protection of parties as required by the applicable laws.

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 Policy:

BiP may provide third parties with aggregate statistical data and analyses about users of the Application. BiP declares that no one can be identified from the data shared like this as long as it has not been disclosed by BiP.

If you activate automatic translation functionality, the submitted words will be shared with a third-party service provider Microsoft and Google. BiP is not responsible for such third-party service providers.

Communication content between users is not monitored.

Your Rights Regarding Your Personal Data

Application users, pursuant to the Article 11 of Law on the Protection of Personal Data, may be entitled to exercise the following rights:

Learn the purpose of the processing of Personal Data and whether these are being processed in compliance with such purpose;

In order to exert any of your rights stated above in relation to your Personal Data or exert your right of data portability (if applicable), 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:

(i) Once you download Personal Data Application Form (https://bip.com/form/kisisel-veri-basvuru.pdf) to your device, by filling it digitally and e-mailing to bipiletisim@hs03.kep.tr address from your registered electronic mail (KEP).

(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 kisiselverilerikoruma@bip.com using your application that you have prepared in accordance with Comminuque on the Principles and Producers for the Request to Data Controller, by using your e-mail address which is previously notified to the company applied and registered in the company’s system.

Age Restriction

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

BiP shall retain Personal Data during the period necessary for the purpose(s) for which it has been collected and/or is being processed for up to 2 (two) years unless a longer retention period is established by applicable laws. This includes the retention of Personal Data during a limited period determined as per the relevant legislation in case any dispute might arise from the Terms of Use. Please note that messages sent while a user is offline will be kept for a maximum of three weeks and will be deleted after the expiration of the aforementioned period. BiP will securely delete Personal Data and ensure all recipients of Personal Data comply with the same obligation as soon as Personal Data is no longer necessary in relation to the purpose for which it was processed unless BiP is required to retain Personal Data for a longer period by law.

Measures for Data Security

BiP takes the security of your Personal Data seriously and it has appropriate technical and organizational measures in place in order to prevent unauthorized access and unlawful processing of Personal Data. Your Personal Data is protected by our strong security features, which we strictly enforce and periodically review.

BiP shall not disclose any Personal Data of users to any third party in defiance of this Notice and/or applicable Data Protection Legislation. BiP shall only use Personal Data for secondary processing insofar such processing is compatible and lawful. In case Personal Data of the users are shared with outsource service providers in accordance with the provisions of this Notice, BiP shall take necessary measures so that such third-party providers shall provide at least a similar level of security for the personal data.

However, BiP does not bear any responsibilities for third party applications to which a link is provided via the Application and for transactions conducted with other users and/or third parties under the “Discover” feature of the Application, where the Application has channels related to different subjects, with the aim of providing different content to users, to the extent these applications are not under the control of BiP.

Automated Decision Making We do not use Personal Data to make automated decisions about users.

About This Policy

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

Contact us

Questions, comments and requests regarding this Notice can be addressed via email at info@bip.com or in writing to the below e-mail or postal addresses:

Data Protection Officer

dpo@bip.com

Aydınevler Mahallesi İnönü Caddesi No:20/36 Küçükyalı Ofispark Maltepe/ İstanbul Turkey

This cookie policy explains what cookies are and how BiP uses them.

What are cookies?

BiP uses cookies. Cookies are small text files which are stored on the browser, computer or mobile device when you visit a website or application. There are different kinds of cookies considering their purposes and lifespan. Two broad categories of cookies used by BiP are functional and analytical cookies.Cookies are used to store information about your visit to the website in order to improve the user experience. For example, if you use the same device and browser as before, cookies remember your preferences and settings. The content is loaded more quickly and the content is optimized.

There are different types of cookies used for Bip.com:

Who places cookies?

Some cookies come directly from our website while others are placed by third parties.

When you first visit our website, the cookies will be downloaded by your internet browser. The next time you visit our website by using the same device, the cookies and the information it contains will either be sent back to the website where it was created (“First Party Cookies”) or forwarded to another website (“Third Party Cookies”). The website recognizes that it has already been opened with the specific browser and can adjust the content.

Why do we use cookies?

We use cookies because they ensure that certain parts of the website work properly. By the use of cookies user preferences remain known, our website users are recognized and statistical information is collected.

What types of cookies do we use?

To place certain cookies, you need to give your consent. Consent is not required for technically necessary cookies. You are allowed to withdraw your consent to non-essential cookies at any time. Please see the further explanation on cookie preferences under “How can you control or delete cookies?”.

The types of cookies used on our website fall into the following categories:

Functional and analytical cookies

Functional and analytical cookies are used to collect statistics from the users. Functional cookies ensure that the website adapts to the internet connection that is being used. These cookies guarantee that data transmission is secure. Analytical cookies allow us to recognize, count the number of visitors and provide anonymous data about how our visitors use our website. An overview of our functional and analytical cookies is provided in Annex-1

The personal data we process

Cookies may involve the collection of personal data. Personal data is any information that relates to an identified or identifiable individual as further defined by applicable law.

Which rules apply to the personal data?

If personal data is being processed by BiP, our Privacy Notice is applicable. You can find our Privacy Notice here: Privacy Policy

How long will the information be retained?

Cookies can be stored for varying lengths of time on your browser or device. We use two different types of cookies in terms of duration. Session cookies are temporary cookies that remain on your device until you close your web-browser. Persistent cookies remain on your device until thespecific retention period for the specific cookie ends. Please find the specific retention periods per cookie in the overview in Annex-1 Any personal data capatured by cookies shall be retained in accordance with our Privacy Notice.

How can you control or delete cookies?

You can withdraw your consent to cookies which are not strictly necessary by changing your browser settings. Generally, your browser will offer you the choice to accept, refuse or delete cookies at all times. Each browser provides instructions on how to this. If you block cookies on our website, you may be unable to access certain areas of our website and certain functions will not work in the best way.

Updates to this policy

BiP reserves the right to make changes to this cookie policy. Changes to the policy will be published on the website. Old versions of the policy will remain available. We recommend you to re-visit this policy regularly to stay informed about updates to the policy.

Questions and requests

If you have any questions or comments about this policy, or our privacy policy in general, please contact us via e-mail at info@bip.com or via phone at +90 212 313 10 00.

Upon written request, you have the right to access your personal data, to have it corrected or deleted or you can exercise your other rights as mentioned in the Personal Data Protection Law numbered 6698 and General Data Protection Regulation. You can send your request via e-mail to “info@bip.com”. You can send your request via post to “Aydınevler Mahallesi İsmet İnönü Cad. Küçükyalı Ofis Park B Blok Apt. No:20 Maltepe/İstanbul”.

Annex-1

Name: _gid

Purpose: Google Analytics is a web analysis service provided by Google Inc. We use this service on our website to collect standard internet log information and details of visitor behavior patterns. Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on. This information is only processed in a way which does not identify users as an individual.

Retention period: 24 hours

Ownership 3rd party/Google

Name: _ga

Purpose: Google Analytics is a web analysis service provided by Google Inc. We use this service on our website to collect standard internet log information and details of visitor behavior patterns. Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on. This information is only processed in a way which does not identify users as an individual.

Retention period: 2 years

Ownership: 3rd party/Google

Name: _gat_gtag_UA_57598401_10

Purpose: Google Analytics is a web analysis service provided by Google Inc. We use this service on our website to collect standard internet log information and details of visitor behavior patterns. Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on. This information is only processed in a way which does not identify users as an individual.

Retention period: 60 seconds

Ownership: 3rd party/Google

Name: pll_language

Purpose: We use this only to remember browser language of users.

Retention period: One year

Ownership: Bip.com