CLARIFICATION TEXT ON THE PROTECTION OF PERSONAL DATA
Pursuant to the General Data Protection Regulation (“GDPR”), which aims to protect fundamental rights and
freedoms of individuals, and particularly the right to privacy, when processing personal data, this
Clarification Text was issued. TT Mobil İletişim Hizmetleri AŞ. (“TT Mobil”) as the data controller and TTI
Hungary (TTI HU) as the EU Data Protection Representative take necessary technical and administrative measures
within the scope of GDPR by using its technological and infrastructure facilities in order to ensure that
personal data is kept securely and processed in accordance with the law.
Personal data is processed by TT Mobil in accordance with GDPR under this Clarification Text. Natural persons,
whose personal data are processed within the scope of GDPR, can learn about the personal data that can be
processed by TT Mobil, purposes of processing such data, recipient groups to which it can be transferred, the
method of collection and the legal reason for data processing as well as their rights under GDPR regarding this
personal data by reading the text below.
1. PROCESSED PERSONAL DATA
Personal Data means any and all information related to an identified or identifiable natural person. The
following personal data may differ from person to person within the framework of the requests of the related
people and/or the products/services they use, and your personal data that can be processed by TT Mobil are as
follows:
ID Information: Name, surname, place and date of birth, gender, nationality, country code, passport
type, passport serial number, passport validity date, passport issuance date, passport issuing authority, maiden
name, date of entry and exit to the country, photograph obtained through our corporate applications and passport
sample
Contact Information: Phone number, e-mail address
Traffic Information: Traffic data used for the transmission of communication and billing purposes (date,
time, duration and parties of calls made / messages sent or received / Internet roaming), IP address
Usage Information: Traffic information, behavior and trend information and cookies on TT Mobil websites
and mobile applications, content usage such as movies/music etc., information on value-added
service/product/line subscriptions and their usage, limit excess information, billing information, social media
id and order/shopping history
Location Information: Approximate location data at the time of entry into the country, approximate
location data at the time of communication and the country of residence abroad
Customer Processing Data: Order information, request information, usage information, subscription
information
Financial Information and Risk Information: Invoice preference, invoice and the information included in
it, receipt information, debt information, credit card and bank information, tax identification number
Process Security Details: IP address information, Internet site log in and log out information
Marketing Information: Cookie records, information obtained through campaign work, shopping history
Visual/Audio Recordings: Liveness check, voice verification and video recording, biometric data-facial
recognition, call center recordings
Special Personal Data: Racial and ethnic origin information in the passport
2. PURPOSES OF PROCESSING PERSONAL DATA
Your personal data may be processed for following purposes in accordance with the processing conditions set out
in the GDPR articles and secondary regulations:
- Establishment and presentation of our company’s services, and ensuring the continuity of such services,
- Establishment of subscription and implementation of billing/pricing/refund/collection transactions made
during the subscription period, termination of the subscription,
- Checking the accuracy of your passport information and documents you have declared, keeping your passport
copy and other information that must be kept in addition to your subscription contract in accordance with
the relevant legislation,
- Providing customer services, handling customer complaints/requests,
- Measuring customer satisfaction, making survey/analysis/statistical studies focusing on researching
customer trends and increasing service quality,
- Offering award/drawing/contest/gift/acknowledgment/celebration/reminder applications in order to ensure
customer satisfaction,
- Preparing, providing, promoting, monitoring, and reporting product and services campaigns and offers
according to our customers’ usage, and informing about the campaign content,
- Informing our customers about new products/services, campaigns/tariffs, and other innovations, information
and customer recovery activities, creating sales opportunities,
- Compliance with the information storage, reporting and information obligations stipulated by the
legislation and official authorities within the scope of the national and international principles regarding
the recognition of customers,
- Developing products, services and works in traditional and digital channels within the scope of network and
technological advances/improvements for a better and innovative service delivery,
- Establishing brand collaborations with brands that touch different sectors within the scope of increasing
the diversity of products and services, and allowing customers to benefit from various opportunities,
- Carrying out network improvement/optimization operations,
- Proactively/reactively detecting possible malfunctions which can occur while providing services, finding
and resolving the root cause of the problem and trying to prevent its recurrence,
- Sharing information/documents requested by regulatory and supervisory institutions and official
authorities, fulfilling legal obligations in the relevant legislation, and conducting auditing activities,
legal pursuits and legal processes.
- Identification of your location in case of an emergency call as per the relevant regulation,
3. PLACE TO PROCESS PERSONAL DATA
Your personal data will be processed in the European Union countries where it is obtained to the extent
necessary within the scope of the service provided (GDPR Article 49, Paragraph 1b), or as prescribed by law
(GDPR Article 6, Paragraph 1c), and the service will be maintained in Türkiye as it will be used in Türkiye as
well.
4. TRANSFER OF PERSONAL DATA
Your personal data may be transferred at home or abroad for the purposes listed below and through our data
processors within the scope of GDPR:
- If you give your express consent, your subscription, location and usage data may be shared for the purpose
of providing services of Türk Telekomünikasyon AŞ., TTNET AŞ., TT Ödeme Hizmetleri AŞ., TT Finansman AŞ. in
order to provide you with appropriate offers. (GDPR Article 49, Paragraph 1).
- In order to carry out your pre and post-subscription transactions, your personal data may be shared with
the companies, representatives and dealers that we have authorized, operating on behalf of our Company.
- For the purpose of meeting the demands of regulatory and supervisory institutions, regulatory and
supervisory institutions, and competent authorities which can detect your location in case of emergency
calls may share your personal data with the public institutions or organizations which are authorized to
explicitly request information as per the law that they are subject to.
- In order to carry out your financial transactions and ensure the security of your mobile finance
transactions, your subscription, financial and device information may be shared with payment and e-money
organizations, and banks.
- For the purpose of managing the collection risk and preventing the usage with malicious intent, your
information about bills and payment may be shared with other companies within the scope of Electronic
Communication Law.
- In order to carry out legal proceedings, your necessary personal data may be shared with law offices,
courts, and consumer arbitration committees.
- TT Mobil will remain to be responsible for the protection of your data during the data processing carried
out by our data processors assigned within the scope of GDPR Article 28. We assign our data processors
particularly in the areas below: technical support, sales, marketing, consulting, customer services.
5. METHODS OF COLLECTING PERSONAL DATA AND THE LEGAL REASONS
Your personal data might be obtained and processed via our website, call center and mobile applications.
When establishing your legal relationship with TT Mobil or during the continuance of the relationship in
question, your personal information is collected:
through written, verbal and electronic mediums
- for the purposes mentioned above, and
- fully/partially and automatically or otherwise. Your personal data is processed for the following legal
reasons:
- You have given your express consent,
- In particular the European Union Data Protection Regulation;
- the Electronic Communications Law no. 5809, and other legislation to which our Company is subject,
- Regulation on the Processing of Personal Data and Protection of Confidentiality in the Electronic
Communications Industry,
- Regulation on Consumer Rights Regarding the Electronic Communications Sector
- Law no. 4054 on the Protection of Competition
- Law no. 6563 on the Regulation of Electronic Trade
- Regulation on Commercial Communication and Commercial Electronic Messages
- Law no. 6502 on the Protection of Consumers
- Turkish Code of Obligations no. 6098
- Turkish Code of Commerce no. 6102
- Law no. 6493 on Payment and Securities Clearance Systems, Payment Services and Electronic Money
Institutions
- The requirement for processing of the personal data of the parties to an agreement provided that it is
directly relevant to establishment and fulfillment of the agreement, to be able to supply the products and
services demanded and to fulfill the requirements of the agreements we concluded,
- It is compulsory to fulfill our legal obligations,
- It has already been made public by the concerned person him/herself,
- It is necessary to process data to establish, use or protect a right,
- It is necessary to process data for the legitimate interests of our Group Companies without prejudice to
the fundamental rights and freedoms of the concerned person.
Your sensitive personal data:
- In cases where you give your express consent,
- Your sensitive personal data except for health data might be processed without requiring your express
consent in cases stipulated in law.
6. PROCESSING THE TRAFFIC AND LOCATION INFORMATION
Your traffic and location information mentioned in the first chapter might be processed for the purposes given
below and they will be disposed of after being stored for a maximum of 2 years as per the related regulations in
the Law on Protection of Personal Data and the Storage and Disposal Policy of our Company:
- Establishing, presenting and ensuring the continuity of our company’s services,
- Establishment of subscription and implementation of billing/pricing/refund/collection transactions made
during the subscription period, termination of the subscription,
- Providing customer services, handling customer complaints/requests,
- Proactively/reactively detecting possible malfunctions which can occur while providing services, finding
and resolving the root cause of the problem and trying to prevent its recurrence,
- Sharing the information and documents requested by the regulatory and supervisory institutions and official
authorities, fulfilling the legal obligations set out in the relevant regulation, carrying out audit
activities, legal proceedings and legal processes,
- Identification of your location in case of an emergency call as per the relevant regulation,
- Communicating the opportunities suitable for you according to your express consent.
7. PROCESSING PERSONAL DATA OF CHILDREN
Certain age classifications apply to TT Mobil's applications. TT Mobil is committed to the regulations on
protection of children within the scope of national and international legal requirements.
8. YOUR RIGHTS REGARDING THE PROTECTION OF YOUR PERSONAL DATA
- Requesting information about the categories of the processed data, processing purposes, possible recipients
of the data, and the planned storage period (GDPR Article 15),
- Requesting correction or addition of inaccurate or incomplete data (GDPR Article 16),
- Cancelling the given permission at any time in a way to be applicable in the future (GDPR Article 7,
Paragraph 3),
- Objecting the data processing to be carried out on the basis of legitimate interest for reasons arising
from your special situation (GDPR Article 21, Paragraph 1)
- Within the scope of GDPR Article 17, requesting the deletion of the data - particularly if the data are not
required for the intended purpose anymore, are processed illegally, or in cases where your permission was
cancelled,
- In cases where deletion is not possible or there is an objection to the obligation of deletion, requesting
the limitation of data under certain circumstances (GDPR Article 18),
- About the data portability, requesting the receipt and transmission to others of the data you provide to us
in a readable format (GDPR Article 20),
- Complaining to the responsible supervisory authority regarding data processing,
- To know third parties to whom your personal data are transferred internally and abroad,
- To request compensation for damages in the event that you incur damages as a result of unlawful processing
of your personal data.
If you wish to exercise your rights set out above, you may submit your application within the scope of Article
77 of the GDPR in order to determine whether the application belongs to you and thus to protect your rights;
- via mail to our addresses given below (ID verification required) or via notary public, or
- or send it to our email/REM addresses given below by using your verified email address, a registered email
(REM) address, a secure electronic signature, or a mobile signature registered with our systems.
The applications to be made in this scope shall be accepted following to an identity authentication carried out
by us and your request shall be concluded as soon as possible and the latest within 30 days according to the
nature of the request.
9. OUR COMMUNICATION CHANNELS