KUZEY KIBRIS CYPRUS TURKCELL PRIVACY POLICY
INFORMATION ON THE PROTECTION OF PERSONAL DATA


Cyprus Mobile Telecommunication Ltd. Personal data collected and processed by (“Kuzey Kıbrıs Turkcell) are under the protection of Kuzey Kıbrıs Turkcell. Kuzey Kıbrıs Turkcell takes the necessary technical and administrative measures, using its technological and infrastructural facilities, in order to ensure that personal data is kept securely and processed in accordance with the law, within the framework of the Personal Data Protection Law No. 89/2007 (“Law”) and related legislation.

Personal data is processed by Kuzey Kıbrıs Turkcell in accordance with the Law and relevant legislation within the scope of Kuzey Kıbrıs Turkcell Privacy Policy. Real persons whose personal data are processed within the scope of the law can obtain information about the personal data that can be processed by Kuzey Kıbrıs Turkcell as a controller, the purpose of their processing, the recipient categories to which they can be transferred, the collection method and their rights regarding the legal reason, by examining the text below.

 

I. WHAT ARE YOUR PERSONAL DATA?
Personal data means all information relating to an identified or identifiable person. Your personal data that may be processed by Kuzey Kıbrıs Turkcell, including but not limited to, are as follows:

Identity Information: This data category refers to data types such as identity or passport number, name, surname, place and date of birth, marital status, gender, identity document sample, photo.

Contact Information: This data category refers to data types such as address, telephone/fax number, e-mail address.

Subscription Information: This data category, customer number, subscription agreement number, subscription type and status, tariff and package information, value-added service subscriptions and your information about the use of products and services; refers to data types such as your information about invoices, debts and payments.

Network, Traffic and Location Information: This data category includes your traffic data and other connection information such as the date, time and duration of messages and calls, connection to the system and exit date and time information, source and destination information regarding accesses made in the internet environment; information about the device and SIM card used and the location of the device in question; It refers to the types of data such as your usage data generated in line with the use of products and services and the technical data required for the provision of services.

Information in Sales Channels: This data category is the information and documents you transmit in sales processes; data obtained when communicating via electronic or physical means; your voice call recordings kept in accordance with call center standards; your voice recording to be used as a means of identity confirmation upon your request; refers to data types such as your demand and transaction information in sales channels.

Information on Use of Products and Services: This data category includes your preferences, habits and other usage information regarding the use of products and services; Your behavioral information and cookies on websites and mobile applications created for the presentation, use or promotion of products and services, especially www.kktcell.com, in cooperation with Kuzey Kıbrıs Turkcell itself or with third parties; refers to the types of data such as device, network, network, application, location and usage information that can be collected through mobile applications.

Payment, Bank and Risk Information: This data category is used to make a preliminary assessment of financial adequacy in device campaigns and subscriptions to services; Payment performance including the previous period, bank information where the payment was made, subscription age, subscription information, location information, mobile payment usage information of the line, prepaid line usage data, if any, payment information in case of receiving services from financial institutions through Kuzey Kıbrıs Turkcell, and limit/ It refers to data types such as risk, issues affecting the limit, delay and withdrawal.

Sensitive Personal Information: This data category refers to data types such as (i) health data of people who need social support (such as disabled, disabled, veterans) and (ii) association, foundation or union membership information.


II. PURPOSE OF PROCESSING PERSONAL DATA

Offering, charging and invoicing products and services; Realization and follow-up of the transactions you request regarding the products and services ordered, purchased and/or used, promotion and marketing of the products and services, contacting you regarding these, being informed about the issues such as campaigns, discounts, benefits, conditions, pricing; providing opportunities such as membership, activities and benefiting from economic advantages and fulfilling the necessary procedures for their use, Presenting offers, gifts and promotions to you, making targeted promotions; Sending special congratulations, wishes, awards, sweepstakes and content that you like, that you may want to access again, that you may be pleased to be reminded of; If you participate in an award, raffle, contest or similar event, the information you provide in this context is used for the event, Confirming your identity information and documents when necessary; performing and reporting your credit check; Taking necessary actions to prevent abuses, loss and fraud, Management of network traffic, interconnection, invoicing, irregularity/fraud detection and similar transactions, and resolution of disputes, especially consumer complaints and interconnection and billing disputes, Developing and diversifying products and services and networks Carrying out studies such as measurement, audit and analysis, training of employees, financial reporting; evaluating your interest in products and services, researching customer satisfaction; providing call center service; Answering questions, complaints and notifications from you, Presenting and promoting the products and services we provide together with our business partners and their own products and services, and establishing a financial agreement with these people,Identifying your location and sharing it with authorized institutions in case of emergency calls, Preservation of your information that should be kept as per the relevant legislation; copying, backing up to prevent loss of information; ensuring the consistency of your information; taking necessary technical and administrative measures for the security of our networks and your information, fulfilling legal obligations with regulatory and supervisory institutions, required or mandated by legal regulations, and conducting legal proceedings and legal processes.
 

III. TRANSFERRING PERSONAL DATA

Kuzey Kıbrıs Turkcell will be able to transfer your personal data to the following domestic and foreign buyer categories within the scope of the Law and other legislation for the purposes set forth in this Policy:

Turkcell group companies and their business partners and authorized persons acting on behalf of Kuzey Kıbrıs Turkcell Suppliers and business partners we work with to supply or deliver the products and services you want to buy or use, Cooperate with for the presentation, promotion and similar purposes of products and services. and/or our business partners, suppliers and banks, financial institutions, the competent authorities that will determine your position in case of an emergency call, Lawyers, auditors, consultants and service providers,

Your attorneys, guardians and representatives authorized by you, Institutions or organizations authorized to request your personal data, such as regulatory and supervisory institutions, courts and enforcement offices, and persons designated by them, Invoice amount for electronic communication services in order to manage the risk of collection and prevent malicious use, and your payment information, other operators, your device information, your segment information in Kuzey Kıbrıs Turkcell, and information on your product and service usage, legal entities that have commercial relations with Kuzey Kıbrıs Turkcell and have your telephone number, For the purpose of ensuring your information security and identity verification, sim card change, information such as the phone number you are connected to the mobile internet, banks and financial institutions, if you are registered in the Kuzey Kıbrıs Turkcell directory, the person requesting your phone number heat.

IV. METHOD AND LEGAL REASON FOR PERSONAL DATA COLLECTION

Your personal data can be collected verbally, in writing, through subscription contracts, dealers and other face-to-face channels, physical or web sites such as call centers, mobile applications, short messages, e-mails, voice response systems and all kinds of voice recordings, written and verbal electronic media. In whole or in part, based on your consent for the processing of your data or as stipulated in Articles 6 and 7 of the Law or on the legal grounds specified in other legislation and listed below; It can be collected by automatic or non-automatic methods or tools, processed and transferred for the purposes specified in this Policy.

It is necessary to fulfill the legal obligation to which Kuzey Kıbrıs Turkcell is subject, it is necessary for the fulfillment of a contract to which you are a party, or it is done for the purpose of taking precautions before becoming a party to the contract upon your request, it is necessary for the protection of your vital interests, or if it is necessary for the performance of a public authority given to Kuzey Kıbrıs Turkcell or a third party to whom the data is transmitted.

Provided that it does not harm your fundamental rights and freedoms, it is mandatory to process the data for the legal interests of Kuzey Kıbrıs Turkcell or the third party to which the data is transmitted.

 

V. YOUR RIGHTS REGARDING THE PROTECTION OF PERSONAL DATA

Pursuant to Articles 14 and 15 of the Law or other legislation; By applying to Kuzey Kıbrıs Turkcell using the methods in the "Contact" section of this Policy,

Learning whether your personal data is being processed, All your personal data that have been processed and at the same time their source, the purpose of processing your personal data, the recipients or categories of data receiving this information and the categories of data being processed or being processed, About the progress made in processing since the information about your personal data To obtain information, To request correction, deletion or blocking of personal data in case of incomplete or incorrect processing of personal data in accordance with the rules of the legislation, Unless the actions taken pursuant to your rights in the form of correction, deletion and blocking mentioned above, are not impossible and do not require disproportionate effort, to third parties to whom personal data are transferred. You have the right, at any time, to object to the processing of your data that has been processed, is being processed or is planned to be processed, for legitimate reasons related to the particular situation.

VI. CONTACT

You can send your requests under the law and questions regarding your personal data to Şht with a petition that you have prepared properly and approved by the certification officer. You can send it to Arif Salih Sokak, No: 7, Nicosia.

VII. ABOUT POLICY

This Policy will be valid as of the date of its publication by Kuzey Kıbrıs Turkcell. Kuzey Kıbrıs Turkcell can make changes to this Policy at any time, if necessary. Changes to be made by Kuzey Kıbrıs Turkcell become effective immediately upon the publication of the Policy at www.kktcell.com. We recommend that you check our website periodically in order to follow the changes in the Policy. The information in the policy may differ from person to person due to issues such as the products and services that people benefit from or their requests and consent.

 

PRIVACY AND SECURITY

ARTICLE 1- DEFINITIONS:
SUBSCRIBER: KUZEY KIBRIS TURKCELL individual subscribers and corporate line users
KUZEY KIBRIS TURKCELL: Cyprus Mobile Telecommunication Ltd.

ARTICLE 2- SUBJECT OF THE AGREEMENT:
The subject of this contract is the determination and determination of the principles regarding the provision of subscription services to be provided by KUZEY KIBRIS TURKCELL to the SUBSCRIBER via Self-Service channels and the determination of the rights and obligations of the parties.

ARTICLE 3- OBLIGATIONS OF THE SUBSCRIBER
The SUBSCRIBER will be fully authorized to take action on his behalf due to this contract / during the performance of the contract, that every transaction he makes within the limits determined and determined by KUZEY KIBRIS TURKCELL will bind him, he will be responsible for all his transactions and behaviors, and that the transactions made using passwords are not made by him. has given up in advance, Cyprus Mobile Telecommunication Ltd. (From now on, KUZEY KIBRIS TURKCELL' does not have any obligation to investigate the identities of people who make transactions using passwords, the SUBSCRIBER will show the necessary care and attention to keep the password(s) confidential, and will not disclose this password(s) to any third party, and that these passwords will not be disclosed to any third party. He/she accepts and undertakes that he/she will not allow the use of passwords by anyone other than himself, that he will be personally responsible for the damages that may arise as a result of the use of passwords by people other than himself, that KUZEY KIBRIS TURKCELL cannot be held responsible under any circumstances, and that he acquits KUZEY KIBRIS TURKCELL in advance for any damages that may arise, and assumes all kinds of responsibility. .

ARTICLE 4- PROVISIONS REGARDING SUBSCRIPTION TRANSACTIONS TO BE MADE ON THE WEB
4.1. The fact that TURKCELL provides subscription services to the SUBSCRIBER via the Internet does not constitute a TURKCELL commitment to supply hardware and software to the SUBSCRIBER.
4.2. SUBSCRIBER states that KUZEY KIBRIS TURKCELL is not responsible for the defects in goods and services purchased from third parties by making use of the subscription services provided by TURKCELL over the Internet, and any liability that can be attributed to KUZEY KIBRIS TURKCELL within the provisions of the Consumer Protection Law and relevant legislation. accepts and declares that it has already released KUZEY KIBRIS TURKCELL.
4.3. KUZEY CYPRUS TURKCELL does not guarantee the continuity of the services to be provided through Self-Service channels, and reserves the right to make changes, decrease or reduce the transactions to be made through these channels.
4.4. Opinion that KUZEY KIBRIS TURKCELL, SUBSCRIBER's lines in KUZEY KIBRIS TURKCELL are closed, SUBSCRIBER's violation of its commitments in this Agreement, Super passwords are used in violation of the provisions of the Agreement, the service is used incorrectly, contrary to the law and the rules of honesty, security measures are violated In the event that the SUBSCRIBER arrives, but not limited to this situation, it may cancel the SUBSCRIBER's password and/or immediately terminate the SUBSCRIBER's use of this service without any notice and without giving any reason. SUBSCRIBER obligations arising during the period until the termination of the service continue after the termination of the service. The SUBSCRIBER accepts and undertakes that he/she accepts these issues and will not demand any compensation from KUZEY CYPRUS TURKCELL, under any name, due to the termination of the service in this way.
4.5. In line with the information conveyed to KUZEY KIBRIS TURKCELL by the SUBSCRIBER, KUZEY KIBRIS TURKCELL reserves the right to act or not, and the SUBSCRIBER cannot claim any rights or receivables from KUZEY KIBRIS TURKCELL due to the information submitted by him.
The SUBSCRIBER accepts and declares that he will immediately notify KUZEY CYPRUS TURKCELL if the passwords for the lines registered in his name are learned or suspected by third parties, otherwise he is responsible for the consequences that may arise.
4.6. TURKCELL shall not be liable in the event that the transactions cannot be completed or canceled due to any technical failure or problem that may be beyond TURKCELL's will regarding the services to be provided by KUZEY KIBRIS TURKCELL under this contract. TURKCELL may make application changes or suspend or completely stop the provision of the services subject to this Agreement, without giving any reason, regarding the provision of the services to the SUBSCRIBER.
4.7. TRNC Courts and Enforcement Offices are authorized to settle disputes that may arise between KUZEY KIBRIS TURKCELL and SUBSCRIBER.
4.8. In disputes arising from this Agreement between KUZEY KIBRIS TURKCELL and the SUBSCRIBER, the notebook, all kinds of documents, computer and sound recordings and microfilms of KUZEY KIBRIS TURKCELL will constitute conclusive evidence and be binding. The SUBSCRIBER accepts and declares that it can only prove its objections against these records with a written document and that this is a contract of evidence. SUBSCRIBER maintained by KUZEY KIBRIS TURKCELL
4.9. The SUBSCRIBER accepts and undertakes that it is obliged to provide TURKCELL with the documents and information requested by NORTH KIBRIS TURKCELL, when necessary, regarding this contract.
4.10. KUZEY KIBRIS TURKCELL reserves the right to make any changes and innovations in this contract.


COOKIE POLICY

Kuzey Kıbrıs Turkcell Cookie Policy, Cyprus Mobile Telecommunication Ltd. It has been prepared to provide information on cookies and similar technologies (collectively referred to as "cookies") that can be used on the websites and applications of the company. Since each Kuzey Kıbrıs Turkcell website and application has different purposes and features, the information below may vary for each website and application.

If you use Kuzey Kıbrıs Turkcell websites and applications, cookies and similar technologies can be used, saved on your device, and your personal data can be shared below and to Kıbrıs Mobile Telekomünikasyon Ltd. Şti. within the scope of Kuzey Kıbrıs Turkcell Cookie Policy. (North Cyprus Turkcell)

It can be processed in accordance with the purposes and methods specified in the Privacy Policy.


WHAT IS A COOKIE?
Cookies are files or pieces of information that may be stored on your computer (or other internet-enabled devices such as smartphones and tablets) when you visit a website. A cookie is usually; It contains the name of the website from which it was received, the "lifetime" of the cookie (eg how long it will be kept on your device) and a unique numerical value, usually generated randomly. Cookies record your actions and preferred settings during your browser session or for your next visit to our website. If you visit our websites again, this information will be sent back to the server. In this way, your computer or mobile device is automatically recognized and, for example, your preferred settings are automatically loaded for your convenience. Cookies offer the advantage of not having to set them each time you visit Kuzey Kıbrıs Turkcell websites or applications.

WHAT ARE THE USE PURPOSE OF COOKIES?
Cookies enable you to effectively switch between web pages; facilitate the use of websites; to follow your preferences to improve our offers, our online visibility and advertising according to your needs in terms of content, graphics and technology; to enrich and improve the overall user experience; It is used for purposes such as statistically evaluating usage data for our websites and helping us improve the structure and content of our websites.

In addition to these, cookies; It can also be used to better customize our services in line with your interests and needs and/or to accelerate your future activities and experiences on our websites.

 

WHAT ARE THE TYPES OF COOKIES?

In terms of cookie management:
First Party Cookies: Refers to the cookies created by us and placed on the website and under our control.
Third-Party Cookies: Cookies created and managed by third-party companies we cooperate with are called third-party cookies.

In terms of storage time:
Session Cookies:
A type of cookie that is only available when your browser is open and is deleted when your browser is closed.

Persistent Cookies:
These are the types of cookies that are permanent until a certain expiration date after your browser is closed. These can be used by websites to recognize your computer when you open your browser and browse the Internet again.

In terms of intended use:
Necessary Cookies:
Necessary to ensure the effective operation of websites, to provide various services for you through websites and to perform some functions such as accessing secure areas. Without these cookies, it is not possible for us to provide some services, such as a shopping cart.
Performance Cookies:
They aim to provide an improved and personalized experience to the user by saving user preferences such as language settings on the website.
Analytical Cookies: They are used by web analytics tools to collect statistical information such as time spent on the website, pages used, click information, time spent on a page, in order to analyze the use of websites and to perform more effective marketing activities.

HOW TO CHANGE COOKIE PREFERENCES?
Although many internet browsers accept cookies by default, you can refuse or delete cookies from the settings section of your browser. For detailed information on how to edit your browser settings, please refer to your browser's help screen.

Please note that if you choose to refuse or delete cookies, this may prevent some features or services of Kuzey Kıbrıs Turkcell websites from working properly and therefore affect your experience on Kuzey Kıbrıs Turkcell websites. Since your cookie preferences are managed through the browser you use, you will also need to renew your opt-out preferences when you use a different browser or purchase a new computer.

Kuzey Kıbrıs Turkcell uses cookies within the scope of its Privacy and Security Policies and reserves the right to change the terms of use regarding cookies and its Cookie Policy.


INFORMATION SECURITY POLICY


INFORMATION SECURITY MANAGEMENT SYSTEM AND POLICIES
Kuzey Kıbrıs Turkcell has an information security management system under the supervision of senior management in order to ensure the security of information in accordance with business needs, laws and regulations. Kuzey Kıbrıs Turkcell Management provides support for the implementation of the information security management system at Kuzey Kıbrıs Turkcell, and makes appointments and guidance when necessary. The information security management system is provided with a defined risk management approach and information security policies in which the basic rules are determined. These policies are shared within the company so that all Kuzey Kıbrıs Turkcell employees can access them. The purpose of information security policies is to manage Information Security risks and to ensure sufficient security of information. All Kuzey Kıbrıs Turkcell employees are responsible for the implementation of the rules written in these policies in the business processes and information assets they are responsible for.

An independent review of the suitability, adequacy and effectiveness of Kuzey Kıbrıs Turkcell's information security management system is provided. Independent review results are reported to the management and relevant records are kept.

PRIVACY AGREEMENTS
It is stated in the employment contract of each Kuzey Kıbrıs Turkcell employee that they are responsible for protecting the confidentiality of information. Before starting to work with suppliers, a confidentiality agreement is signed. According to the content and scope of the service/product purchased from the supplier providing continuous and/or temporary services to Kuzey Kıbrıs Turkcell, the risks that Kuzey Kıbrıs Turkcell will face are foreseen and appropriate security issues are added to the confidentiality agreement. The said confidentiality agreement reflects the requirements for ensuring the security of information and includes trade sanctions. Information to be protected and sanctions for violations are defined in the contract. Suppliers and supplier employees are authorized to access information assets for a minimum period of time and with minimum access rights to the extent necessary, limited to their field of duty and duties in the relevant job.

LEGAL COMPLIANCE
Kuzey Kıbrıs Turkcell determines and implements security requirements in line with legal regulations. All personal information of Kuzey Kıbrıs Turkcell subscribers is protected in accordance with the laws and regulations of the Turkish Republic of Northern Cyprus. In the recording, processing and sharing of personal information, applicable laws and regulations are complied with in order to comply with the data privacy principle. Northern Cyprus Turkcell's important records are protected against loss and corruption. While determining the retention periods of the records, the obligations in the legislation are taken into account.

MANAGEMENT OF INFORMATION SECURITY RISKS
Services and risks for these services are defined in order to effectively manage information security risks at Kuzey Kıbrıs Turkcell. It is ensured that the identified risks are evaluated and managed by prioritizing them. Information security risk management typically includes risk assessment, risk processing, risk acceptance and risk communication.

MANAGEMENT OF INFORMATION SECURITY INCIDENTS
In order to ensure the security of information assets at Kuzey Kıbrıs Turkcell, measures are taken at the level of technological solutions and processes, and regular controls, tests and monitoring are carried out. Employees are informed and trained in this regard. It has been determined how the incidents related to Kuzey Kıbrıs Turkcell information assets will be determined, to whom they will be communicated and how they will be handled. In addition, responsibilities regarding how the detected security vulnerabilities should be communicated to the relevant parties, the deficiencies that caused the occurrence of the incident and the evaluation of possible risks are defined.

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