Privacy policy

• Introduction

Digital Pals Teknoloji ve Danışmanlık Anonim Şirketi (“Digital Pals”, “we”, “us”) cares about the privacy of your personal data. This document is to inform you about how we collect and protect any personal information you provide to us and how you can control what personal information we collect from you and what we do with it. It sets out how we intend to use your information, who we will share it with and what rights you have about use of your information. 

As a data controller we process personal data of all people related to us including but not limited to the people provided with the goods and services.

This notice applies to all our activities under the above brand and however you provide personal information to us, whether you visit us online at any of our websites or visit our stores or contact us via social media or whether you telephone, email, write to or text us.

In this scope, this Privacy Policy (the “Policy”) describes how and for what purposes the personal data of the following persons is collected, processed and shared with third parties by Digital Pals:

• Natural person customers/service recipient and/or natural person prospective customers/ service recipient and contact persons of the corporate customers/service recipient and/or prospective customers/ service recipient 
• Natural person suppliers or the contact persons of the corporate suppliers which provides goods or services to Digital Pals;
• Website (“https://digitalpals.com/”) users of Digital Pals;
• Any other individuals about whom Digital Pals obtains personal data.

• Definitions

Specifically, we use the following terms in this Privacy Policy: 

Personal Data: All kinds of information and data related to an identified or identifiable natural person. (For example, your name, surname, date of birth, identity number, electronic mail address, phone number etc. shared with us are named and termed as Personal Data for the purposes hereof)

Data Subject: Any identified or identifiable natural person whose Personal Data are processed by the Controller.

Processing: Any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, limiting, erasure or destruction.

Data Controller: The natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing operation.

• The Data Controller’s Identity

The Data Controller is Digital Pals Teknoloji ve Danışmanlık Anonim Şirketi, registered before Istanbul Trade Registry under registration number 238236-5, with tax number 2951007094 with the registered address “Barbaros Mah. Begonya Sok. No:1 Nida Kule Ataşehir, Istanbul, Türkiye.

• Personal Data Processed by The Data Controller 

We do not collect or transfer your personal data other than the ones you share with us directly with your explicit consent.

• Methods for Collecting of Personal Data

The above-mentioned Personal Data are collected in physical or electronic platforms directly from sources depending on the manner in which they are shared with Digital Pals and processed and transferred within the scope of the purposes mentioned below. Automatic data processing systems are used.

• The Purposes of and Legal Grounds for Processing Personal Data

We collect and process your personal data for the purposes below:

• For the purpose of establishing a business partnership and carrying out the commercial activities subject to this business partnership, and only for this purpose only.
• In order to carry out recruitment processes.
• In cases where it is necessary to provide the service most suitable to the preferences, tastes, interests and usage habits of the real persons receiving the service.
• In cases where it is necessary to record personal data in order to fulfil the obligations arising from the legislation to archive and share information with the competent authorities and to fully fulfil the legislation compliance procedures.
• In cases where it is necessary to identify the needs of real persons receiving the service and to develop the Services accordingly.
• In cases where it is necessary to contact you to answer your complaints and questions.
• In order to prevent data loss; to make copies/backups and to carry out system and/or physical security processes.

If you are a EU, Switzerland, UK or Turkish resident, according to relevant act personal data of an individual can be processed if there are lawful basis. According to relevant law processing personal data lawful only if and to the extent that at least one of the following applies:

• the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
• processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
• processing is necessary for compliance with a legal obligation to which the controller is subject;
• processing is necessary in order to protect the vital interests of the data subject or of another natural person;
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

For the abovementioned purposes and in scope of the above, we process your personal data based on your explicit consent; or without your consent where the processing is necessary for the establishment or performance of our agreement with you, or when it is requested by the legal or government authorities in scope of a legal proceeding or to the extent our legitimate interests require, provided that it does not harm your fundamental rights and freedoms. 

If you are not a resident of a Country not mentioned above, the laws of your country of residence shall apply. Your data will be processed and transferred on your explicit consent in any case. 

• Storage of the Personal Data

Your personal data shared with Digital Pals is being kept and stored in Digital Pals’ local/foreign secure servers in strict compliance with the applicable laws and regulations, the provisions of the Law. Digital Pals takes the necessary technical and administrative security measures specified under the legislation to protect the security of your personal data.

• Retention Period of Personal Data

Once the purposes for processing the data no longer exist and/or upon expiration of the legal retention periods during which we are obliged to retain your personal data (e.g. for the legal purposes, security or financial recording purposes), your personal data will be deleted, destroyed or anonymized.

• Transfer of Personal Data

Your Personal Data may be shared with competent courts and other governmental bodies and public entities for the performance of our legal duties and obligations. We may also share your personal data and traffic information in connection with your visit our website to ensure your security and to fulfil our obligations under the applicable legislation with the authorities and institutions.

We transfer personal data;

• To our local business partner and services providers in order to receive services on information technologies, payment security or consultancy services requiring expertise and/or to its business partner and services providers abroad,
• To administrative and legal authorities in order to fulfil our legal duties to provide information and documents and to use our legal rights,
• To our business partners in order to provide our services or our providers from which we receive products or services,
• To our business partners for educational and compliance purposes; to our lawyers, financial advisors, occupational safety specialists etc. in order to fulfil our legal duties; to our partners abroad in order to build connections, conclude, execute and fulfil agreements.

The list of our service providers and business partners and their privacy policies are as follows:

• Adjust https://www.adjust.com/terms/privacy-policy
• Apple https://www.apple.com/privacy/
• Facebook https://www.facebook.com/privacy/policy
• Google LLC (Firebase) https://policies.google.com/privacy?hl=en-US
• Google LLC (Google Ads) https://policies.google.com/privacy?hl=en-US
• Instagram https://privacycenter.instagram.com/policy 
• LinkedIn https://www.linkedin.com/legal/privacy-policy
• Microsoft https://www.microsoft.com/en-us/privacy/privacystatement
• Shopify https://www.shopify.com/legal/privacy 

• What are your rights arising out of the Law?

If you are an EU, Switzerland, UK, USA or Turkish resident, you have the following rights related to your personal data:

• learn whether any of your personal data is subject to processing;
• request information regarding the processing activities;
• learn the purposes for processing;
• know local and foreign third persons if, and to whom, personal data are transferred;
• request correction of personal data if processed incompletely or inaccurately;
• request deletion or destruction of personal data if the purposes for processing no longer exist;
• request notification of deletion or correction to third parties to whom personal data is transferred;
• object to negative consequences which arise as a result of processing of personal data by automatic means; and
• request indemnification if you suffer damage as a result of illegal processing of your personal data.

If you request to use your rights above, contact us [email protected]. 

Additionally, if you are a European resident, we note that we are processing your information in order to fulfil contracts we might have with you, or otherwise to pursue our legitimate business interests listed above.

If you are not a resident of a country not mentioned above, the laws of your country of residence shall apply and Digital Pals will evaluate your requests accordingly. 

This version of our Privacy Policy was last updated on June 15, 2025.