MOBILE APPLICATION CONFIDENTIALITY STATEMENT

Version, November 20, 2022

Confidentiality of all our users is very important to us. We, JAM Broadcasting, process your Personal Data when you use our Service, as an Application User. This Confidentiality Statement explains how we protect and process your Personal Data. We recommend you to read it carefully.

1. What is specified in this Confidentiality Statement?

Sections in this Confidentiality Statement provide information regarding the followings:

●     Type of the Personal Data that is processed,

●     Personal Data Processing Purposes,

●     Places where Personal Data is processed,

●     Safety measures applied to protect Personal Data,

●     Limitations of liability concerning third parties,

●     Imaging, changing and deleting your Personal Data,

●     Changes made in this Confidentiality Statement;

●     What can you do if you have any question or remarks?

2. Type of the Personal Data that is processed

A. Personal Data used by our Service

We use Anonymous Data to improve our Service. This information shall not be disclosed to the public through the Service.

B. Automatically created Information

Like most of the other websites and online services, we collect and process the automatically produced information as to how you use the application. Collected information includes your IP address and / or unique device identity.

If you want to participate especially, the Application may collect your geographical location information. In any case, you can avoid your geographical location information to be obtained through your mobile device settings.

If you want to prefer giving the permission of access and collecting of information from your social network account, your basic personal information (name and e-mail address, etc.) in your social network account, also your social network user identity (not your password) and parameters related to the posts you share through the Application. For more information concerning how to set your account’s confidentiality preferences to check the information that is accessible and acquirable, please refer to the confidentiality policy of the subject social network.

This also applies to the information that is formed automatically with respect to how you use the Application. This kind of information assists us in better understanding how the Application is used and in producing services more appropriate to your needs as a user.

If you activate user authorization features in the Application, following additional information is stored:

●     Name,

●     E-mail,

●     Telephone number(Optional);

●     Additional profile information sent by an external provider such as Facebook, Twitter, Google+ or Linkedln.

We also collect the following (unknown) information to provide information on the usage of the application to the application owner:

• The moment you open the Application,

• The screens you open within the Application and the time you spend on these screens,

• The moment you leave the Application.

Note: If the features of user authorization have not been activated, we may associate anonymous information with your information when you log in.

If push notification ads are active in the app, information about BleshSDK, which works integrated with the app, is presented below.

Through BleshSDK, users’ notification status, bluetooth status information, device information, ad identifier (IDFA), location, operator, installed app list information are accessed and necessary security measures are taken for the confidentiality of this information.

If the user wishes to save the campaign image to the photo album, the user’s photo album and camera is accessed and the screen image is saved in the photo album.

The information is used only safely and only for the period of time required to send push notifications via the app to the extent permitted by the User. The information is shared with third parties only for the purpose of carrying out the said objectives and it is not allowed to publish and disclose the information outside this scope.

C. Specific Information

You may be asked to apply with some activities such as loyalty card, newsletters, advertising; in this case, some personal information is required. This information is stored on the database of our service (including third parties) and shall be shared with us.

When you upload any Data including the photos in the Application, they shall be shared and shall be able to be seen by all other users of the application.

3. Personal Data Processing Purposes

A. Purposes

The Parties process Personal Data for the purposes specified below:

●     To ensure you can use the Service,

●     To keep the information about our Services up to date,

●     To improve and / or customize the Service,

●     To identify you / or to customize the Service,

●     To get to know you and to avoid fraud,

●     To provide support,

●     To transmit Your Personal Data to third parties if you request such an action from us or in cases we are legally obliged to do so.

B. Transmitting your Personal Data to third parties

We do not sell or lease your Personal Data to third parties without receiving prior permission from you. However, we may provide your Personal Data to third parties in cases where it is essential for you in terms of being provided with your Personal Data so as to fulfill the instructions such as making payments with respect to Paid Services, through payment providers.

We can provide “collective anonymous data” on the use of the Service to third parties for such purposes in a way that we consider appropriate. “Total anonymous data” are data that cannot be returned to you and therefore, is not deemed to be as Personal Data. For example, we may use collective anonymous data for a better understanding of how Users use the Service.

In case we connect to or are merged with a third party or are subject to restructuring, your Personal Data may also be disclosed to a third party and / or transferred to this third party. This third party shall have the right to continue to use the Personal Data and any other information you provide to us.

We may disclose your Personal Data in good faith where we believe that you must comply with a court decision, pending judicial transaction, summon of criminal or civil court or other legal procedure and request issued by law enforcement defending so as for you to be able to exercise your legal rights and to defend yourself against legal claims.

4. Places where Personal Data is processed

The data centers where the data are processed within the scope of the service are located in different regions. They are provided over hosting services in Turkey, Ireland, the Netherlands and the United States of America. However, the Personal Data processed may be transmitted to and stored in the hosting servers in a country other than these countries and regions. We shall take all reasonable steps to ensure that your Personal Data are used securely and in accordance with this confidentiality policy.

5. Which security measures are applied to protect Personal Data?

The security of your data and the safety of other Users are very important to us. We have taken technical and organizational measures to protect your Personal Data against loss or any illegal processing. We have implemented the following measures: protection of our servers through firewalls, SSL connections, and encryption of sensitive data. This list is not detailed.

6. Limitations of liability concerning third parties

Our service may contain hyperlinks to the services and products provided by third parties and / or to the websites or services of partners, advertisers, and other third parties.

The parties do not have any control or influence on the content, websites, or services of these third parties. Different confidentiality policies may be applied for the use of third-party websites and services. This Confidentiality Statement only relates to the Personal Data obtained by the parties through using the Service in line with its own purposes. The parties do not accept any liability for the content, applications or operation of third party websites and services.

7. Imaging and Deleting Personal Data

You can send a request to contact us via email or to delete personal information collected by using the application. You may be asked to provide additional information to verify your identity.

8. Children’s confidentiality

Personal information about children is not intentionally or prepensely collected.

9. Security

Measures are taken to ensure the security of your personal information, to minimize the risk of damage, loss of information and unauthorized access or use of information. However, these measures cannot provide strict information security. Thus, efforts are made to ensure the security of your personal information, but this is not guaranteed, and you cannot reasonably expect that the application and its related databases will be free of any unfair behavior, malfunction, unauthorized barriers or access, or other abuse / misuse.

10. Changes made in this Confidentiality Statement

This Statement can be updated at any time. The Parties shall publish an updated version of the Confidentiality Statement through the Service. The parties recommend you to check this page from time to time to be aware of any changes in this Confidentiality Statement and to be knowledgeable about how the parties protect your Personal Data. It is your responsibility to review this Confidentiality Statement periodically and to be knowledgeable about the updates, and you are deemed to accept and undertake the updated versions.

You agree to abide by all the changes in this Statement. Your continued use of the Application after the change has entered into force shall indicate that you accept the changed Statement. If you do not agree with the Changed Statement, you must remove the Application and avoid any further use of it.

11. What can you do if you have any questions or remarks?

If you have any questions or remarks regarding this Confidentiality Statement, please contact us by sending an email.

This Confidentiality Statement was last updated on 10 April 2019.