Privacy Policy

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.

When we collect, receive, store and use your personal information, we do so in accordance with the rules set down by the European Union General Data Protection Regulation (EU) 2016/679 (the GDPR) and Turkish laws.

We also apply these principles to the way we collect, store and use the personal information of our clients outside EU.

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

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.

Where do we collect information

We, and our service providers, collect personal information in a variety of ways. If you choose not to provide us with personal information when requested, we may not be able to provide you with the information and/or services you have requested or otherwise fulfill the purpose(s) for which we have asked for the personal information. Aside from this, your visit to our websites will remain unaffected. When we collect your personal information, we will let you know why we are collecting it and how we will use the information.

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.

If we become aware that a child under 16 years old has provided us Personal Information, we will delete that information. If you become aware a child has provided us with their Personal Information, please contact us immediately.

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).

If you would like to exercise any of your rights, you must make a request, in writing, either by email to the address compliance@kostebekteknoloji.com or by sending a registered letter to the postal address described in the contacts section of this Privacy Policy Statement. We will make reasonable attempts, at no cost, to promptly respond to your request as may be required by applicable law. If such request cannot be handled within a reasonable time frame or is, for any reason, denied, Köstebek will provide you with an explanation for such outcoming.

You may also unsubscribe from any Köstebek' mailing list for which you have subscribed or registered to, by following the instructions given along with each newsletter or other contact of the nature.

In situations where you have concerns about how Köstebek processes your personal information or disagree with Köstebek' privacy practices and procedures, your right to lodge a complaint with the appropriate data protection authority is also assured.

Transactional and Commerce Data

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.

When placing orders / making purchases, it is important to note and agree to any terms and conditions imposed by third parties, such as Service Providers with whom we may be working to facilitate the order or purchase.

Cookies

Cookies help us enhance your experience when using both our website and blog. The cookies used by Köstebek' Web platforms are to collect information about how visitors use our platforms (such as which pages are most popular, or the amount of time spent of each page), so that we can improve our platforms and better serve our visitors.

Some cookies we use are from third-party companies, such as Hubspot Analytics. These are set by an entity other than Köstebek, for the purpose of providing us with information on user behaviour (e.g. the pages you visit, the links or buttons you click, or the time spent on our platforms). Such cookies are only valid for as long as you remain on Köstebek' Web platforms.

To learn more about our analytics collection, please see our https://kostebekteknoloji.atlassian.net/wiki/spaces/MAR/pages/3078094849.

Changes to the Privacy Policy

When we update this Privacy Policy, we will revise the update date at the top of this page. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy. Your use of the services following these changes means that you accept the revised Privacy Policy.

Contact us

Köstebek Teknoloji is committed to working with you to ensure compliance with all applicable laws and regulations concerning the protection of Personal Data. Should you wish to exercise any of the rights outlined in this Policy, or have further queries with regards to this Policy, please note that you can contact us through:

Email – compliance@kostebekteknoloji.com

Phone Number: +90 505 451 34 47

Address – Yıldız Teknik Üniversitesi Teknopark B1 Blok 408 YTÜ-Davutpaşa Kampüsü, Esenler - İstanbul

We will answer to your request within 30 days and notify you of the action we have taken.