• Introduction

Digital Pals Teknoloji ve Danışmanlık Anonim Şirketi (“Digital Pals”, “we”, “us”) cares about the privacy of your personal data. In this context, this Information Sheet has been written to provide information about the Personal Data processed by Digital Pals within the scope of the services (“Service”) provided through the website “www.digitalpals.com”.

If you would like detailed information about the type of data collected in our services, how it is collected, for what purposes it is processed, with whom it is shared, how long it is stored and what measures are taken to protect it, you can visit www.digitalpals.com/privacypolicy.

For any questions and requests regarding the protection and processing of your personal data, you can contact us at [email protected]. We will get back to you within 30 days from the date of your request.

• 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 

Digital Pals processes your Personal Data listed below within the scope of the Services it offers:

• Identity Data; refers to all data that provides information about your identity and belongs to the relevant person.
• Contact Data; refers to all data required to contact the relevant person.
• Financial Data; refers to all kinds of information regarding the payments to be made within the scope of the service agreement to be established with the relevant person.
• Transaction Security Data; refers to the data group containing digital traces resulting from the processing of information belonging to the relevant person.
• Device Data; refers to all information about the relevant person and the device on which the service is provided.
• Sensitive Personal Data; refers to data that is considered sensitive data in accordance with the relevant legislation and Google policies.

Digital Pals processes your personal data regarding your preferences, likes, interests and usage habits in order for users to get the maximum efficiency from the Service it offers, and processes the information obtained as a result of processing this data in order to provide services in accordance with your tastes and needs.

• The Purposes of and Legal Grounds for Processing Personal Data

Digital Pals processes the Personal Data listed above, except for sensitive personal data, obtained as a data controller, if one of the legal reasons regulated under the relevant Legislation and listed below is present, and if these reasons are not present, it seeks the explicit consent of the relevant persons:

1. Personal data processing is clearly regulated by law.
2. Personal Data processing is necessary for the establishment or performance of a contract between Digital Pals and the relevant persons. 
3. Processing of Personal Data to fulfil Digital Pals’ legal obligations.
4. Processing of Personal Data for the establishment, exercise or protection of a right.
5. Personal Data processing is mandatory for our legitimate interests.

Personal Data processed by Digital Pals is processed within the scope of the purposes listed 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 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.

Sensitive Personal Data will be processed in limited cases, based on the explicit consent of the relevant person, to the extent that it is necessary for the Services provided by Digital Pals or to fulfil obligations. In cases where explicit consent is required, the relevant person has the right to withdraw their explicit consent at any time.

• Methods for Collecting of Personal Data

Digital Pals collects and processes the Personal Data it obtains from you through websites or other similar devices or channels operated by or on behalf of Digital Pals, in physical or electronic form, depending on the method you use to transmit it.

• Storage and Retention Period 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.

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

Personal Data processed by Digital Pals may be transferred to competent courts, lawyers and other employees employed by Digital Pals for the performance of our legal duties and obligations, and to third parties such as authorized institutions and organizations and other state bodies and public legal entities with whom Personal Data must be shared for the performance of the Service.

Within the scope of the Service provided by Digital Pals, your Personal Data may be transferred to and processed in countries other than your country of residence. In this context, Personal Data processed by Digital Pals will be transferred to our servers located outside the borders of your country of residence, our Group Companies, third party service providers and partners for the purpose of providing the Services.

• Rights of the Relevant Persons

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.

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. 

In order to exercise their rights specified above, the relevant persons may submit their requests in writing to the e-mail address [email protected] or to the registered e-mail address [email protected]. If the completion of such requests requires an additional cost, Digital Pals may request the applicant to pay the fee in the tariff determined by the Personal Data Protection Authority (“Authority”).

If the applicant is the relevant person, the application must include the relevant person’s name, surname, Turkish Republic identity number (passport number for foreign nationals), address information for the response to be sent, and documents proving his/her identity.

If the applicant is acting on behalf of someone else, he/she must be specifically authorized in this regard and the authority must be documented. In this case, the application must include the name, surname, Turkish Republic identity number (passport number for foreign nationals) of the applicant and the relevant person, address information for the response to be sent, and documents proving his/her identity.

In addition, the relevant persons may make a request to the Institution using the contact information below in order to exercise their right to complain:

PERSONAL DATA PROTECTION AUTHORITY

Address : Nasuh Akar Mah. Ziyabey Cad. 1407. Sok. No: 4 06520 Balgat, Çankaya, Ankara

Phone Number: +90312-216-5000

Website : http://www.kvkk.gov.tr/

• Changes on this Information Sheet

Digital Pals reserves the right to change and modify this disclosure text at any time. Changes made to the disclosure text will be published in the services provided or the relevant persons will be informed by other means deemed appropriate by Digital Pals. In cases required by the relevant legislation, the approval of the relevant persons will be obtained.

Last updated on: June 15, 2025.