Effective Starting Date: December 14, 2021
General Information
Köstebek Teknoloji, (“Köstebek”, “we”, “us” or “our”) is committed to preserving the privacy of people with who we come into contact, (collectively “You” or “Your”) and applies to the information we obtain through use of our websites, services/products subscription (free and paid), marketing campaigns (e.g., events and webinars or any other similar communications) or whenever you interact with Köstebek, you consent to the collection, use and transfer of your information under the terms of this policy.
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This Policy describes how personal information is collected, for what purposes it is collected, how we share it, how we handle the content you place in our products and services, and the steps we take to secure this information.
Contents
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What information do we collect
We can collect the following information about you:
Contact information such as name, email address, phone number, country, city
Profile information such as job title, company or other business information
Pictures: photos
Billing information such as tax ID
Software preferences, including software use and interests
User web behavior
IP addresses, URLs visited, and related information
Cookies (see our Cookies policy)
Education and work experience
Usage data and information about the systems running our products.
We may collect these types of personal information directly from you or from third parties.
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We collect data, including Personal Data, from a variety of sources depending on the nature of the Services you use or Interaction you have. Sources may include:
Your direct submission: You may provide information to us via one of our Services or via Interactions. This may unstructured information (such as that in an email) or a response to a survey, web-form, or other data gathering mechanism.
Indirectly via your use: We may collect information from you in the course of your using Services or our providing services to you. For example, we may observe your actions on one of our websites.
From Third Parties: We may be provided, or collect, information from various third parties with whom we may contract, or share an integrated service, in connection with our Services.
(a) third party vendors that help us build or supplement contact lists or information, for example webinar platforms or market intelligence providers; and
(b) third parties that help us verify records or enrich information we capture about you; and
(c) third party providers of services (such as online recruiting services) whereby information is sent to us automatically or via request; and
(d) transactional information from third parties, including information regarding your purchases or evaluations of any of our Services. This may include data from companies such as Atlassian (via Atlassian Marketplace or other means).
Please note that we use the following third parties to process your personal information:
Atlassian
Google
Hubspot
Digital Ocean
Amazon Web Services (AWS)
By providing us with personal information, you consent to the disclosure of your personal information to third parties who reside outside EU.
Information Sharing and Disclosure
We will not share or disclose any of your Personal Data with third-parties except as described in this policy.
We do not sell your Personal Data. We will never provide your Personal Data to any third-party, without your previous consent, that does not, at least, the same level of for your Personal Data similar to the one we have. We ensure that the necessary procedures are in place to preserve your legal rights over your Personal Data.
Social Media Features: Our websites include social media features, such as the “Facebook” Like button and widgets, the “share this” button and/or other interactive mini-programs that run on our sites. Social Media Features and Widgets are either hosted by a third-party or hosted directly on our Websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.
Links to third party sites: Our websites may include links to other websites whose privacy practices may differ from ours. If you submit Personal Data to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.
Testimonials: We may display personal testimonials of satisfied customers. With your previous consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at anytime.
With your previous consent: We will share your Personal Data with third-parties only when we have your consent to do so.
We reserve the right to use or disclose your Personal Data if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights or to comply with a law, court order, or legal process, but as far as is legally possible, we will inform you about such disclosure terms.
How do we use the information collected
When we use your personal information, it will be (a) with your consent, or (b) for one of two basic purposes: (1) to operate our business and provide (including improving and personalizing) the products we offer, and (2) to send communications, including promotional communications.
Operating our Business. We use your information to provide and improve the products we offer and perform essential business operations. This includes operating the products, maintaining and improving the performance of the products, developing new features, conducting research, evaluating your suitability for employment opportunities, and providing customer support. Examples of such uses include the following:
Providing the Products. We use your information to carry out your transactions with us and to provide our products to you.
Customer support. We use your information to diagnose product problems, and provide other customer care and support services.
Product Improvement. We use your information to continually improve our products, including adding new features or capabilities.
If you provide payment information, we use such information solely to collect payment from you. We use a third-party service provider to manage credit card processing.
Security, Safety and Dispute Resolution. We use your information to protect the security and safety of our products and our customers, to detect and prevent fraud, to confirm the validity of software licenses, to resolve disputes and enforce our agreements.
Employment Opportunities. We use your information to evaluate your suitability for employment or recruitment opportunities.
Business Operations. We use your information to develop aggregate analysis and business intelligence that enables us to operate, protect, make informed decisions, and report on the performance of our business.
Legal Obligations. We use your information as required by law.
We use your information to communicate with you and personalize our communications with you.
If your consent is the basis for our use of your personal information, then you have the right to withdraw your consent at any time. If you wish to withdraw consent, please email us in accordance with the “Contacting Us” section.
Personal Data of minors
Köstebek Teknoloji products and services are not directed to individuals under 16 years old.
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How we protect your information
At Köstebek, we are committed both to ensuring the privacy of the personal information that we may hold and also to complying with any applicable legislation regarding the privacy of data. Therefore, we maintain a set of physical, technical and organizational safeguards to protect any personal data collected or processed against its accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to, as well as against any other form of illicit treatment:
· We protect the security and privacy of your information while in transit and at rest, by using appropriate encryption protocols and software;
· We periodically review our information security and privacy practices, procedures and technologies, to guarantee that these remain adequate and appropriate to the purposes described in this notice;
· We maintain a thorough information security and privacy awareness program, to ensure that all personnel are knowledgeable of the importance of the confidentiality, integrity, availability and privacy of your information;
· Access to personal information is restricted to only those employees and third-party service providers who require such information to perform their job duties. Nonetheless, anyone working in or with Köstebek is subject to strict contractual confidentiality obligations and to administrative disciplinary actions if they fail to meet these obligations.
Despite all these precautions, failures may occur as no security measure is 100% reliable. In case of failure, we will make the necessary provisions to notify you and guide you through the steps to remain protected, in accordance with the applicable legislations and the conditions established by the competent data supervisory authority.
Data subject rights
Within the limits established by applicable laws or regulations, data subjects are wholly entitled to exercise their rights regarding the personal information that Köstebek may hold about them. Data subject rights include the right to be informed, the right of access, the right to rectification, the right to erasure, the right to restrict processing, the right to data portability and the right to object, as described in the European Union's General Data Protection Regulation (EU GDPR).
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Data regarding any orders / purchases for use of our Services is referred to as Transactional and Commerce Data. This includes (but is not limited to) orders / purchases of:
licenses to use our software (including products) in whatever form,
licenses to use 3rd party software, or services, sold through Köstebek.
Transactional and Commerce Data may be provided to us via your placing an order on the phone, via 3rd party marketplace facilities such as the Atlassian Marketplace, our website, officially authorized 3rd party partners or representatives, or other sources.
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