SUMMARY
Below is a summary of
some key terms of this Privacy Policy. This summary is for your reference only
and does not form part of the Privacy Policy.
We at Ngr Reklam Insaat
Elektrik Nakliyat Harfiyat Sanayi Ve Ticaret Limited Sirketi listen to our users and we are committed to
protecting the principles of privacy and fair use that underpin our values to
offer a transparent and secure service. We want you to be confident that your
personal data is safe and secure with us.
This Privacy Policy explains
the following:
o
how we collect your personal data;
o
what personal data we collect;
o
how we use your personal data;
o
who we share your personal data with; and
o
the rights and choices you have when it comes
to your personal data.
Privacy Policy
Last modified: December 25th,2019
1. Who are we?
When we say “F CIRCLE” “our,” “we,”
or “us,” we’re talking about Ngr Reklam Insaat Elektrik
Nakliyat Harfiyat Sanayi Ve Ticaret Limited Sirketi. This Privacy Policy (“Privacy Policy”) applies
to all of our apps, services, games, features, software, and website (together,
“Services”) unless specified otherwise.
This Privacy Policy
explains how we will use personal data about you and the steps we take to
ensure your personal data is kept secure and confidential. It should be
read together with our Terms of Service.
2. How do we collect personal data?
We may obtain personal data from you
through the websites, mobile applications or other similar devices, channels or
applications operated by or on behalf of F Circle.
3. What personal data do we collect?
We collect personal data about you when
you give this to us in the course of registering for and/or using our Services
for example we may collect your name, address, e-mail address or telephone
number.
Note that it is your
responsibility to check and ensure that all data, content, material or data you
provide us is correct, complete, accurate and not misleading.
Data that you may provide
voluntarily
Certain
parts of our Services may ask you to provide personal data voluntarily. For
example, we will ask for certain data in order for you to register for an
account with us, to begin using our Services, to subscribe to marketing
communications from us, and/or to submit enquiries to us, such as:
·
Contact and correspondence data (such as name and email address);
·
User name and password;
·
Profile data (such as profile photo and biography); and
·
Other data you choose to give us (such as data to identify a
lost account).
The
personal data that you are asked to provide, and the reasons why you are asked
to provide it, we will try to explain to you at the point we ask you to provide
your personal data.
When you
use our Services, we may also collect data automatically from you and/or your
device which may be considered personal data under applicable data protection
laws, such as:
· Data and
analytics about your use of our Services;
· Your IP
address and mobile device identifiers (such as your device ID, advertising ID,
MAC address, IMEI);
· Data about
your device, such as device name and operating system, browser type and
language;
· Data we
collect with cookies and similar technologies;
· Broad
geographic location based on your IP address;
· Precise
geo-location data (GPS, with your consent); and
· Data about
your use of our Services, such as in application interaction and usage metrics.
Advertising ID means
Apple Identifier for Advertisers (“IDFA”) on Apple and Google Advertising
Identity (“GAID”). These are unique identifiers for mobile device that
advertisers use for interest based advertising. They
are consistent across all apps and thus allow cross-app tracking. On Apple you
can opt-out this by choosing “limit ad tracking” option from privacy settings.
On Google Android you can opt-out by choosing “Opt-out of interest
based ads”.
Advertising IDs are non-permanent, non-personal identifiers,
which are uniquely associated with your device. Similar technologies include
tracking pixels within ads. These technologies allow companies (including
marketers and advertisers) to recognise your device when you use websites and
applications.
Data about your device refers to data
about your device type, device model, device maker, device operating
system and its language or other technical data like screen size or processor,
or combination of this data available from a device for a developer for
checking the device compatibility with a particular application.
Some of this data may be collected using cookies and/or similar
technologies (such as "SDKs" or software development kits), as
explained further below.
Data that
we may obtain from third party sources
We may receive personal data about you from third party sources.
For example, if you clicked on an advertisement to direct you to one of our
Services we may be provided with data from which ad-network and advertising
campaign the install originated from.
You may choose to connect to our Services via your social media
account. Exactly what data we receive from your social media will depend on
your social media privacy settings, but it would typically include your basic
public profile data such as:
· your
username;
· profile
picture;
· age range;
and
· gender
The data that we may
collect from our partners could include;
· Data we
receive if you link a third-party tool with our Services (such as Facebook,
Apple or Google);
· Demographic
data (such as to determine the location of your IP address);
· Data to
fight fraud (such as click fraud in advertising);
· Data from
platforms that our Services run on (such as to verify payment); and
· Data for
advertising and analytics purposes, so we can optimise the Services we deliver
to you.
We do not request or intend to collect any special or sensitive
categories of data such as any data on health, race, religion, political
opinions, sexual preferences or orientation.
4. How do we use your
personal data?
We
may use your personal data:
1.
to enable you to access and use the Services.
For example;
· To create
user accounts and profiles;
· To provide
you with the correct versions of our applications and/or games; and
· To send you
service related communications including confirmations, technical notices,
updates, security alerts, and support or administrative messages
2.
to personalise and improve aspects of our
Services. For example;
· To respond
to your customer support requests;
· To receive
error messages about any issues you / your device encounters with our Services
to enable us to fix bugs and interoperability issues;
· To detecting
and preventing illegal activities;
· To track
application installs, for purposes of measuring the effect of our marketing
campaigns;
· To conduct
optional user feedback surveys;
· To remember
you next time you visit one of our Services; and
· Communicate
with you about promotions, rewards, upcoming events, and other news about
products and services offered by us.
3.
to communicate with you, including some or all
of the following:
· To provide
you with in-app offers and rewards based on your interaction with our Services;
· To serve you
with relevant targeted advertisements;
· To make you
offers to purchase in-app items on discount based on your activity with our
application and your purchase history; and
· To send you
marketing communications and/or newsletters if you have subscribed for them
about rewards and promotions.
4.
for research, such as analysing market
trends and customer demographics;
5.
To comply
with legal obligations, including to prevent and/or detect fraud or provide
disclosure to the authorities when required by applicable law.
6.
To create application ads with the
use of photos that were provided
to our application
by you
5. Why do we process your
personal data?
We
will only collect and use your personal data (as described in section 4) in
accordance with data protection laws. Our grounds for processing your
personal data are as follows:
1.
Consent – Where necessary we will
only collect and process your personal data if you have given your clear and
affirmative consent for us to do so.
2.
Legitimate Interests – We may use and
process some of your personal data where we have sensible and legitimate
business grounds for doing so. Under European privacy laws there is a concept
of “legitimate interests” as a justification for processing your personal data.
Our legitimate interests for processing your personal data are for us to enable
you access and use of our Services, to communicate with you about our Services
and to improve our Services.
6.
Who do we share your personal data with?
When you use any of our
Services, we may disclose your personal data to the following parties:
a)
To our group companies, third party
services providers and partners who provide data processing services to
us. For example, to support the delivery of, provide functionality on, or help
to enhance the security of our Services, or who otherwise process personal data
for purposes that are described in this Privacy Policy or notified to you when
we collect your personal data.
b)
to any competent law enforcement body,
regulatory, government agency, court or other third party where we believe
disclosure is necessary.
c)
to any other person with your
consent to the disclosure.
7. What cookies do we use?
A cookie is a very small text file placed on your computer or device. We
and our partners use cookies and similar technologies to provide and
personalise our Services, analyse use, target advertisements and prevent fraud.
You can disable cookies in your browser settings, but some parts of our
Services may then not function properly.
8. What advertisements do
we show on our Services?
The
advertisements that you see displayed on our Services are delivered on our
behalf by certain third-party advertising companies. No data which identifies
you, for example your name, address, email address or telephone number, is used
to provide this advertising. In order to display advertising most likely to be
relevant to you, these third-party advertisers may place or recognise a unique
cookie on your browser. This cookie does not collect personal data about you
nor is it linked to any identifiable data about you. By using our Services, you
are consenting to the use of these third-party cookies for these purposes.
If you would like more
data about online advertisements and your choices about how this data may be used
by these companies, please find more data here http://www.youronlinechoices.com/uk/your-ad-choices.
9.
What steps do we take to keep your personal data safe?
Your personal data’s
security is very important to us. This is why, where it’s appropriate, we use
HTTPS to help keep data about you secure. However, no data transmission over
the internet can be guaranteed to be totally secure.
We do our best to keep
the data you disclose to us secure. However, we can't guarantee or warrant the security of any data which you
send to us, and you do so at your own risk. By using our Services, you accept
the inherent risks of providing data online and will not hold us responsible
for any breach of security.
10. How long do we keep
your personal data?
Unless a longer retention
period is required or permitted by law, we will only retain your personal data only for as long as reasonably
necessary to fulfil the purposes outlined in this Privacy Policy and for our
legitimate business interests, such as to comply with our legal obligations,
resolve disputes, and enforce our agreements. We will for example periodically
de-identify unused user accounts and regularly review our data sets.
11. Do we transfer your personal data outside
of the country you are resident?
Our Services are global
by nature and your personal data may be transferred to, and processed in,
countries other than the country in which you are resident. These countries may
have data protection laws that are different to the laws of your country. We take
steps to ensure adequate safeguards are in place to protect your data as
explained in our Privacy Policy. Adequate safeguards that our partners may use
include standard contractual clauses approved by EU Commission and the Privacy
Shield certification in case of transfers to the USA.
12.
Age Limits
We do not knowingly
collect or solicit personal data about or direct or target interest
based advertising to anyone under the age of 13 or knowingly allow such
persons to use our Services. If you are under 13, please do not send any
data about yourself to us, including your name, address, telephone number, or
email address. No one under the age of 13 should provide us any personal
data. If we learn that we have collected personal data about a child under age 13, we will delete that data
as soon as it is practicably possible.
13. Your personal data rights and how to
contact us
You
have certain rights under existing data protection legislation including the
right to request a copy of the personal data we hold about you, if you request
it from us in writing.
i.
Right to access: the right to request
copies of your personal data from us;
ii.
Right to correct: the right to have your
personal data rectified if it is inaccurate or incomplete;
iii.
Right to erase: the right to request
that we delete or remove your personal data from our systems;
iv.
Right to restrict our use of your data: the right to ‘block’ us
from using your personal data or limit the way in which we can use it;
v.
Right to data portability: the right to request that
we move, copy or transfer your personal data;
vi.
Right to object: the right to object to
our use of your personal data including where we use it for our legitimate
interests.
To make enquiries, exercise any of your rights set out in this Privacy Policy and/or make a complaint please contact us at support@fcircle.desk360.com
Changes to this Privacy
Policy
We reserve the right to
amend or modify this Privacy Policy at any time and any changes will be
published on our Services. The date of the most recent revision will
appear on this page. If we make significant changes to this policy, we
may also notify you by other means such as sending an email. Where
required by law we will obtain your consent to make these changes. If you
do not agree with any changes, please do not continue to use our Services.