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LIFEBOX PRIVACY NOTICE

Publication Date: 09.12.2021

If you live in European Region, you can read our Privacy Notice from here.

Who We Are

lifebox application (“Application”) and www.mylifebox.com (“Web site”) (the Application and Web site shall be collectively referred to as “Service”) is provided by Lifecell Bulut Çözümleri A.Ş. (“Lifecell”).

Lifecell is committed to protect and respect your Personal Data in accordance with Personal Data Protection Law no. 6698 (hereinafter referred to as the “PDPL”). Lifecell takes the necessary technical and administrative measures by using its technological and infrastructure facilities to ensure that personal data is kept securely and processed in accordance with PDPL.

This Privacy Notice (“Notice“) informs you about which information that makes your (“you”, “your” or “user”) identity specific or identifiable (“Personal Data“) is collected, used and shared. For the interpretation of undefined terms stated in this Notice, we refer to the definitions as used in the internal lifebox terms of use of Lifecell (“Terms of Use”). For information about cookies please also read our Cookie Policy on our Web Site.

I. WHICH PERSONAL DATA ARE COLLECTED ?

Although the information in this section may differ from user to user due to circumstances such as differences of products and services that you benefit from or your request and consent, the categories of Personal Data that are processed by Lifecell are as follows:

  • Identity Information:This data category refers to data types such as name, surname, date of birth.
  • Contact Information:This data category refers to data types such as GSM number, social media accounts, e-mail address, address.
  • Subcription Information:This data category refers to data types such as customer number package information and information about the usage of the services; invoice, debt and payment details.
  • Usage Information: Details regarding your usage of the Services such as the time you use the Application, your last log in information, errors and information relating to errors while using the Services, preferences, habits and other usage data and cookies.
  • Device Information:This data category refers to data types such as information regarding the device, location information of the device, technical data required to offer the services.
  • Information at the Sales Channels:This data category refers to data types such as information submitted by you during sales processes; data obtained as you are contacted via electronical or physical means, your audio call records kept due to call center standards; your voice record to be used as identity confirmation method upon your request; your requests and transactions at sales channels.
  • Visual and Audio Records: This data category refers to data types such as (i) photos and objects within photos, (ii) written or audio documents or videos on users’ telephones or computers.
  • Directory Information: This data category refers to data types such as names, surnames, telephone numbers of third persons recorded in contact list of the users.

II. 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 the Web Site, the Application, our mobile apps, SMS, e-mail, call center and interactive voice response (IVR) system, via wholly automated or partly automated means.

Where processing is expressly provided for by the laws

Lifecell processes your Personal Data when it is expressly provided for by the laws to which Lifecell is subjected.

We process; Identity information, contact information, subscription information, usage information, device information, information at the sales channels,

For the purposes of; fulfilling legal liabilities required by regulatory and supervisory authorities, making legal arrangements and conducting legal proceedings and legal processes.

Where processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract:

Lifecell processes your Personal Data for the provision of the Services in accordance with our Terms of Use and quality standards.

We process; Identity information, contact information, subscription information, usage information, device information, information at the sales channels, visual and audio records and directory information,

For the purposes of; offering, pricing and invoicing of products and services; fulfilling and tracking the transactions which you requested regarding the products and services purchased and/or used; storing of visual and/or audio recordings when you back up your content; in case you use the Contact Back Up feature, storing personal data of persons contained in the contacts for back up purposes.

Where processing personal data is necessary for being able to fulfill the legal obligations of Lifecell

Lifecell processes your Personal Data when we comply with a legal obligation as set out below.

We process; Identity information, contact information, subscription information, usage information, device information, information at the sales channels,

For the purposes of; detecting irregularities/fraud, fraudulent and unauthorized use and fulfilling similar detection activities and settling consumer complaints, storing and back-up of your information which is necessary in accordance with the relevant legislation; ensuring the accuracy of your information, taking the necessary technical and administrative measures for the security of your information.

Where personal data has already been made public by the data subject

The personal data which has been made public by you may be processed by Lifecell in compliance with the purpose of making the data public.

Where processing personal data is necessary for establishment, exercise or protection of a right

We process; identity information, contact information, subscription information, usage information, device information, information at the sales channels

For the purposes of; the use of the rights arising from the law, especially the fundamental rights and freedoms of the user and third parties, before all competent authorities, settling consumer complaints and execution of complaint management.

Where processing is necessary for the purposes of the legitimate interests pursued by Lifecell

Lifecell 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 information, contact information, subscription information, usage information, device information, information at the sales channels,

For the purposes of: offering proposals, gifts and promotions to you, celebration, sending wishes, awards and delivering contents which you may want to access again or be glad to be reminded; using your provided information within this scope in case you would like to attend drawings, awards, competitions or similar events, improving, varying, measuring, auditing and analyzing products and services and training of our employees, conducting financial analysis; assessing your interest in the products and services; investigating customer satisfaction; providing call center service; replying to your questions, complaints and notifications, risk management, prevention of unauthorized and fraudulent use, management of the customer survey process, measurement and development of the service quality.

Your Consent

Lifecell 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:

We process your personal data for the purposes of; promoting and marketing products and services, contacting you regarding them, informing you about campaigns, discounts, benefits, conditions, pricing, providing opportunities such as membership and enjoyment of economic advantages as well as carrying out the necessary procedures in order to be able to utilize these opportunities, performing targeted advertising.

If face and object recognition feature is used, users' photos are divided into groups by creating smart albums according to the processed face, object and location, creating contents that can be shared by creating customized stories with these processed photos. Face recognition feature is only activated based on user consent and users can deactivate it easily from the settings of the Service.

If PhotoPick (analyzing which photos will be liked more on Instagram among the photos within the Application, obtaining a customized analysis result specific to the user's own account by connecting his Instagram account to the Service optionally) feature is selected, the photo which will be liked most among the analyzed ones will be recommended for sharing on Instagram. PhotoPick is only activated based on user consent and users can deactivate it easily form the settings of the Service.

If you give your consent, your voice recording will be used as an identity verification method when you use our call center services.

If you use the services offered by third-party service providers, the content you upload to the Service may be processed by the third-party service provider. We would like to remind you that if you use these features, you will be subject to these service providers’ own terms and privacy policies.

III. WITH WHOM AND FOR WHAT PURPOSES ARE PERSONAL DATA SHARED ?

Lifecell may transfer your personal data to third parties in accordance with PDPL and relevant legislation to the following recipient groups for purposes contained in this Notice:

  • To the suppliers and business partners in Turkey and abroad with whom we cooperate in order to provide or deliver our products and services which you want to purchase or already use to be
  • To the institutions and organizations authorized to request your personal data such as regulatory and supervisory authorities and courts and execution offices as well as the persons designated by them.

If you use the services offered by third-party service providers, the content you upload to the Service may be processed by the third-party service provider. We would like to remind you that if you use these features, you will be subject to these service providers’ own terms and privacy policies.

IV. YOUR RIGHTS REGARDING YOUR PERSONAL DATA

As the Service user you are entitled to exercise the following rights pursuant to Article 11 of PDPL:

  • To learn whether your personal data are processed or not,
  • To demand for information as to if your personal data have been processed,
  • To learn the purpose of the processing of your personal data and whether these personal data are used in compliance with the purpose,
  • To know the third parties to whom your personal data are transferred in country or abroad,
  • To request the rectification of the incomplete or inaccurate data, if any,
  • To request the erasure or destruction of your personal data under the conditions referred to in Article 7 of PDPL,
  • To request reporting of the operations carried out pursuant to right to erasure and right to rectification to third parties to whom your personal data have been transferred,
  • To object to the occurrence of a result against you by analyzing the data processed solely through automated systems,
  • To claim compensation for the damage arising from the unlawful processing of your personal data.

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.

V. CONTACT US

You can forward your questions and requests regarding your personal data via one of the following methods:

  • by sending an e-mail prepared in accordance with the Communiqué on the Procedures and Principles for the Request to Data Controller to the e-mail address kisiselverilerikoruma@mylifebox.com using your electronic mail address which you have used to sign up to Services and is registered in Lifecell’s systems.
  • by sending your request in written form in accordance with the Communiqué on the Procedures and Principles for the Request to Data Controller to the address “Lifecell Bulut Çözümleri A.Ş., Aydınevler Mahallesi İnönü Caddesi No: 20 Küçükyalı Ofis Park B Blok - Maltepe/Istanbul” via notary public.

Lifecell has the right to ask for additional information to verify your identity for data security before responding to your request and disclosing any personal data.

VI. USE OF THE SERVICES

If you want to delete your account, you can deliver your request over \"Delete My Account\" button under the Settings / Profile tab inside the application and on Web Site.

VII. ABOUT THIS NOTICE

This Notice shall be valid as of the date on which it is published by Lifecell. Lifecell may make amendments in herein Notice at any time when necessary which shall be brought to your attention by publishing it via the Application. Amendment to be made by Lifecell shall immediately become effective as soon as it is issued at https://mylifebox.com/policy/?lang=en.

lifebox Contact Information

Company Title: Lifecell Bulut Çözümleri Anonim Şirketi
Central Registry Number: 608125676300001
Phone number: 0212 313 10 00
Fax Number: 0212 313 00 99
Customer Service: 0532 532 00 00
Central Registered Email Address:
lifecellbulutcozumleri@hs03.kep.tr
Web Address: https://mylifebox.com/
Email Address: info@mylifebox.com
Contact Address: AYDINEVLER MAH.İSMET İNÖNÜ CD.
KÜÇÜKYALI OFİS PARK B BLK.N:20 MALTEPE