Social Media Privacy Notice
TURKISH PRESS AND PUBLISHERS COPYRIGHT AND LICENCING SOCIETY
PRIVACY STATEMENT ON THE PROCESSING OF PERSONAL DATA
ON SOCIAL MEDIA PLATFORMS
As TURKISH PRESS AND PUBLISHERS COPYRIGHT AND LICENCING SOCIETY (hereinafter TBYM) is the data controller of your processed personal data, we respect and protect the privacy of our users. We are committed to being as transparent as possible about the use of your personal data.
This privacy statement ("Privacy Statement") explains how TBYM uses your personal data in connection with your interaction on different social media platforms such as Facebook and Instagram. In this Privacy Statement, the terms "we", "us" and "our" are TBYM.
We may update the Privacy Statement from time to time. Please check back when you use our products and services to make sure you see the updated notification.
2. WHO WE ARE?
If you have any questions regarding this Privacy Statement or want to exercise your rights, you can contact us using the contact details below.
TURKISH PRESS AND PUBLISHERS COPYRIGHT AND LICENCING SOCIETY
Küçük Çamlıca Mah, Şekerkaya Sokak, No: 9/A Üsküdar/İstanbul
Tel: +90 216 327 0773
Registered electronic e-mail address: email@example.com
3. PERSONAL DATA WE COLLECT AND USE
We may process the following types of personal data:
▪ Information about you and other publicly available information such as your name, e-mail, age, gender, country, job title, current and previous employer, education history, profile picture, interests, friends list, connections, followers, if you post on your social media profile you use or on one of the TBYM social pages,
▪ Other information you provide to us by posting on the TBYM social media page, including your comments and/or likes on our posts and pictures, or your direct messages through TBYM social media platforms,
In some cases, for example on our Facebook page, TBYM acts as a joint data controller with Facebook regarding the processing of your personal data. Therefore, we recommend that you read Facebook's privacy statement to understand how Facebook processes your personal data.
For more information on the processing of your personal data, we usually refer to the privacy statements of different social media platforms.
▪ Link for Facebook data policy (Turkish): https://www.facebook.com/policy.php
4.WHY WE COLLECT AND USE YOUR PERSONAL DATA? WHAT ARE OUR LEGAL BASIS FOR DOING THIS?
Based on and limited to at least one of the personal data processing conditions specified in Articles 5 and 6 of the Law on the Protection of Personal Data No. 6698 (PPDL Law), especially the principles specified in Article 4 of the Law on the processing of personal data. We process your personal data in accordance with the general principles set forth. In accordance with Article 10 of the Law and secondary legislation, the company informs the relevant persons about the categories and purposes of data processing in the clarification texts. Pursuant to the EU General Data Protection Regulation ("GDPR"), our legal basis for the collection and processing of your personal data via different social media pages is our legitimate interest in article 6 (1) (f). Our legitimate interests override your interests for the purposes of Article 3.
We process your personal data for the following purposes:
▪ Understanding the audience of our social media channels by recognizing their demographics, preferences and interests and presenting information accordingly
▪ Analyzing trends and profiles to develop, modify, personalize and improve our services and communications for the benefit of our audience
▪ Processing and responding to requests and questions from you
▪ Recommending products and services that we think will interest you. We do this for direct marketing purposes to our customers and/or potential customers.
▪ Also, if we use electronic means to send you direct marketing, for example via our social media pages such as Facebook and/or Instagram, in the form of email or direct message, we will only do so if permitted under the applicable rules on direct marketing.
5. HOW DO WE SHARE YOUR PERSONAL DATA?
We will not give, sell, or otherwise share or disclose your personal data except as described herein or otherwise specified at the time the personal data was collected.
As mentioned in clause 3, we may act as joint data controllers with specific social media providers such as Facebook Inc or Facebook IrelandLtd in relation to the processing of your personal data via our social media pages. This means that we are jointly responsible for the processing of your personal data. A link to Facebook's privacy statement has been added in clause 3.
We may share your personal data with our service providers for the following purposes:
▪ To help us administer or troubleshoot our website,
▪ To assist us in the sourcing or design of our products and services or in the conduct of our business,
▪ To get help with our marketing campaigns with tools such as Facebook CustomAudiences and Facebook Lookalikes etc.
▪ To provide us electronic or physical storage services or systems.
We will only share your information under these circumstances if it is necessary for our service providers to perform a particular service for us. These service providers are not authorized to store or use your personal data for any other purpose and will always be under the obligation to keep your personal data secure and confidential.
6. TRANSFERRING DATA TO THIRD COUNTRIES
If deemed necessary regarding a particular data processing activity or service performance, we may share your personal data with affiliated companies located outside the EU / EEA and unaffiliated companies such as service providers or business partners located outside the EU / EEA in order to deliver our products and services to you.
If your personal data is transferred outside of the EU/EEA, we will take appropriate technical and organizational measures to ensure that personal data use meets the requirements of applicable data protection laws, including ensuring that the rights of the data subject are protected. When necessary, we will put into effect the standard contractual articles of the EU Commission and the articles of the PPDL Law with the recipient of the personal data. The European Commission considers that these provisions provide sufficient guarantees for the protection of privacy, fundamental rights and freedoms and the enjoyment of related rights.
7. HOW LONG WE KEEP YOUR PERSONAL DATA
Within the scope of PPDL Law and GDPR, your personal data is kept for the period required by the relevant legislation or for the purpose for which they are processed. These periods have been determined, and after this period, the relevant personal data is deleted, destroyed or anonymized so that it can be used for analytical purposes at the end of the periodic destruction periods determined in our relevant Storage and Disposal Policy in accordance with the Regulation on the Deletion, Destruction or Anonymization of Personal Data.
If you have commented on any of our posts on social media platforms, such comments will be deleted when that post is deleted. However, we may choose to delete certain comments earlier. You can also delete your own comment at any time.
Information collected for a specific purpose, such as a targeted marketing campaign via social media platforms, will be deleted 1 year after the specific processing activity is carried out. For documentation purposes, certain data may be retained for up to 2 years after certain campaigns.
If you would like more detailed information about our Retention and Disposal Policy, please contact us using the contact information in item 2 above.
8. YOUR PRIVACY RIGHTS
According to the Constitution of the Republic of Turkey, everyone has the right to demand the protection of their personal data. In this context, the rights of the person concerned over their personal data are listed below in Article 11 of the PPDL Law:
▪ Learning whether personal data is processed or not,
▪ If personal data has been processed, requesting information about it,
▪ Learning the purpose of processing personal data and whether they are used in accordance with their purpose,
▪ Knowing the third parties whose personal data are transferred in the country or abroad,
▪ Requesting correction of personal data in case of incomplete or incorrect processing,
▪ Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the PPDL Law,
▪ Requesting notification of this deletion, destruction or correction to third parties to whom personal data has been transferred,
▪ Objecting to the emergence of a result against the data owner by analyzing the processed data exclusively through automated systems,
▪ Requesting the compensation of the damage in case of loss due to the processing of personal data in violation of the PPDL Law.
Under GDPR, you can exercise your rights as a result of our processing of your personal data. These rights are:
▪ ▪ Right of access to your personal data
▪ ▪ The right to have us correct your personal data
▪ ▪ The right to ask us to delete your personal data
▪ ▪ The right to restrict our processing of your personal data
▪ ▪ Right to data portability
▪ ▪ Right to object to our processing
▪ However, these rights may be subject to conditions and/or exemptions, such as to guarantee the privacy, trade secrets, intellectual property rights of others, or to comply with a legal obligation.
▪ If you want to exercise one or more of your rights, please contact us using the contact information in item 2 above.
9. RIGHT TO MAKE A COMPLAINT
If you have a concern about how we use your data, please let us know and we will answer your questions and, if necessary, take steps to ensure that our practices are consistent with our obligations. If you submit your requests regarding your rights listed above to us in accordance with the application procedures stipulated in the Communiqué on Application Procedures and Principles to the Data Controller, we will conclude your request free of charge as soon as possible, depending on its nature, and within 30 (thirty) days at the latest. You can find our contact information in item 2.
10. CHILDREN'S PRIVACY
We offer solutions for children, but our social media pages on Facebook are not designed to collect personal data about children under the age of 16. We do not knowingly collect personal data from anyone we know to be under the age of 16.
11. THIRD PARTY LINKS
TBYM social media pages on Facebook may contain links to the websites of other companies and organizations. This Privacy Statement does not apply to such third-party sites and we suggest you to contact those third-party sites directly for information on their data collection and distribution policies.
12. CHANGES TO THE PRIVACY STATEMENT
We may update the matters in this Privacy Statement on our websites and Facebook by posting a new version.
This Privacy Statement was updated on .