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This Policy describes the information we process to support Posterly and other products and features offered by Logaritma Internet ve BT. Tic Ltd. Şti. (Logaritma Products or Products). You can find additional tools and information in the Posterly settings.
WHAT KINDS OF INFORMATION DO WE COLLECT?
To provide the Logaritma Products, we must process information about you. The type of information that we collect depends on how you use our Products. You can learn how to access and delete information we collect by this document in detail.
Things that you and others do and provide:
Information and content you provide: We collect the content, communications and other information you provide when you use our Products, including when you sign up for an account, create or share content as posts and message or communicate with others. This can include information in or about the content that you provide (e.g. metadata), such as the location of a photo or the date a file was created. It can also include what you see through features that we provide, such as our camera, so we can do things such as suggest masks and filters that you might like, or give you tips on using camera formats. Our systems automatically process content and communications that you and others provide to analyse context and what's in them for the purposes described below.
Data with special protections: You can choose to provide information in Posterly about your religious views, political views, who you are "interested in" or your health. This and other information (such as racial or ethnic origin, philosophical beliefs or trade union membership) could be subject to special protections under the laws of your country.
Networks and connections. We collect information about the people, Pages, accounts, hashtags and groups that you are connected to and how you interact with them across our Products, such as accounts you communicate with the most or posts you like . We may also collect contact information if you choose to upload, sync or import it from a device (such as an address book or call log or SMS log history), which we may use for things such as helping you and others find people you may know and for the other purposes listed below.
Your usage: We collect information about how you use our Products, such as the types of content that you view or engage with, the features you use, the search terms you looked up and selected, the actions you take, the people or accounts you interact with and the time, frequency and duration of your activities. For example, we log when you're using and have last used our Products, and what posts and content you view on our Products. We also collect information about how you use features such as our camera.
Information about transactions made on our Products: If you use our Products for financial transactions such as when you purchase coins, we collect its information via the mobile app stores (App Store for – Apple, Google Play for Android devices) that you use.
Things others do and information that they provide about you. We also receive and analyse content, communications and information that other people provide when they use our Products. This can include information about you, such as when others share or comment on a photo of you, send a message to you or upload, sync or import your contact information.
Device information
As described below, we collect information from and about the computers, phones, connected TVs and other web-connected devices you use that integrate with our Products, and we combine this information across different devices that you use. For example, we may use information collected about your use of our Products on your phone to better personalise the content, ads or features that you see when you use our Products on another device, such as your laptop or tablet, or to measure whether you took an action in response to a post that we showed you on your phone on a different device.
Information that we obtain from these devices includes:
Device attributes: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins.
Device operations: information about operations and behaviours performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).
Location information: We collect real-time information about the GPS or IP based location of your device, as permitted by you.
Identifiers: unique identifiers, device IDs and other identifiers, such as from apps or accounts that you use, and other identifiers unique to Logaritma Products associated with the same device or account.
Device signals: Bluetooth signals, information about nearby Wi-Fi access points, beacons and cell towers.
Data from device settings: information that you allow us to receive through device settings that you turn on, such as access to your GPS location, camera or photos.
Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed and, in some cases information about other devices that are nearby or on your network, so we can do things like providing you the service of synchronizing your devices and reach Posterly seamlessly.
Cookie data: data from cookies stored on your device, including cookie IDs and settings.
PRECISE LOCATION INFORMATION AND HOW TO OPT OUT
When you use one of our location-enabled services (for example, when you access Services from a mobile device), we may collect and process information about your mobile device's GPS location (including the latitude, longitude or altitude of your mobile device) and the time the location information is recorded to customize the Services with location-based information and features (for example, to inform you about posts in your area or applicable promotions). Some of these services require your personal data for the feature to work and we may associate location data with your device ID and other information we hold about you. We keep this data for no longer than is reasonably necessary for providing services to you. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer's instructions for further details.
INFORMATION FROM PARTNERS
Advertisers can send us information through Posterly accounts that they use, including our potential social plugins, our APIs and SDKs. These partners provide information about your activities off Posterly – including information about your device, websites you visit, purchases you make, the ads you see and how you use their services – whether or not you have a Posterly account or are logged in to Posterly. For example a business could tell us about a purchase you made in its shop. We also receive information about your online and offline actions and purchases from third-party data providers who have the rights to provide us with your information.
Partners receive your data when you visit or use their services, or through third parties that they work with. We require each of these partners to have lawful rights to collect, use and share your data before providing us with any data.
HOW DO WE USE THIS INFORMATION?
We use the information that we have (subject to choices you make) as described below, and to provide and support the Logaritma Products and related services described in the Posterly Terms. Here's how:
Provide, personalise and improve our Products.
We use the information we have to deliver our Products, including to personalise features and content (including your Posterly Feed, and promoted content) and make suggestions for you (such as accounts or posts you may be interested in or topics you may want to follow) on and off our Products. To create personalised Products that are unique and relevant to you, we may use your connections, preferences, interests and activities based on the data that we collect and learn from you and others (including any data with special protections you choose to provide); how you use and interact with our Products; and the people, places or things that you're connected to and interested in on and off our Products.
Information across Posterly and devices: We connect information about your activities on Posterly and devices to provide a more tailored and consistent experience on all Logaritma Products you use, wherever you use them.
Location-related information: We may use location-related information – such as your current location, where you live, the locations of the posters that you liked and saved, and the businesses and people you're near – to provide, personalise and improve our Products, including posts, promoted content, for you and others. Location-related information can be based on things such as precise device location (if you've allowed us to collect it), IP addresses and information from your and others' use of Logaritma Products.
Product research and development: We may use the information we have to develop, test and improve our Products, including by conducting surveys and research, and testing and troubleshooting new products and features.
Ads and other sponsored content: We may use the information we have about you – including information about your interests, actions and connections – to select and personalise ads, offers and other paid content that we show you.
Provide measurement, analytics and other business services.
We use the information that we have to help advertisers and other partners measure the effectiveness and distribution of their ads and services, and understand the types of people who use their services and how people interact with their websites, apps and services.
Promote safety, integrity and security.
We use the information that we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Products, and promote safety and security on and off Logaritma Products. For example, we may use data that we have to investigate suspicious activity or violations of our Terms or Policies, or to detect when someone needs help.
Communicate with you.
We use the information that we have to send you marketing communications, communicate with you about our Products and let you know about our Policies and Terms. We also use your information to respond to you when you contact us.
HOW IS THIS INFORMATION SHARED?
Your information is shared with others in the following ways:
Sharing on Posterly
People and accounts that you share and communicate with
When you share posts using our Products, your content shall be shared publicly based on the geographical location of your post.
Public information can be seen by anyone, on or off our Products, including if they don't have an account. This includes your Posterly username, any information you share with a public audience, information in your public profile on Posterly, and content you share on your posts including the locations. You, other people using Posterly, and we can provide access to or send public information to anyone on or off our Products, including in other Logaritma Products, in search results or through tools and APIs. Public information can also be seen, accessed, reshared or downloaded through third-party services such as search engines, APIs and offline media such as TV, and by apps, websites and other services that integrate with our Products.
Content others share or reshare about you
You should consider the content you share, because people who can see your activity on our Products can choose to share it with others on and off our Products, including people and businesses. For example, when you share a post, perople can download, screenshot, or reshare that content to others across or off our Products, in person or in virtual reality experiences.
People can also use our Products to create and share content about you. For example, people can share a photo of you in a Post, mention or tag you at a location in a post, or share information about you in their posts . If you are uncomfortable with what others have shared about you on our Products, please communicate with us.
New owner
If the ownership or control of all or part of our Products or their assets changes, we may transfer your information to the new owner.
Sharing with third-party partners
We work with third-party partners who help us provide and improve our Products to grow their businesses, which makes it possible to operate our companies and provide free services to people around the world. We don't sell any of your information to anyone and we never will. We also impose strict restrictions on how our partners can use and disclose the data we provide. Here are the types of third parties that we share information with:
Partners who use our analytics services
We provide aggregated statistics and insights that help people and businesses understand how people are engaging with their posts, and other content on and off the Posterly. For example, Posterly profiles may receive information about the number of people or accounts who viewed, reacted to or commented on their posts, who came to their stores after viewing the posts as well as aggregate demographic and other information that helps them understand interactions with their account.
Advertisers.
We provide advertisers with reports about the kinds of people seeing their promoted content and how their promoted content are performing, but we don't share information that personally identifies you (information such as your name or email address that by itself can be used to contact you or identifies who you are) unless you give us permission. For example, we provide general information to advertisers (for example, that an ad was seen by a person who is in Dam Square, Amsterdam - Netherlands) to help them better understand their audience. We also confirm which Posterly posts led you to make a purchase or take an action with an advertiser.
Measurement partners.
We share information about you with companies that aggregate it to provide analytics and measurement reports to our partners.
Vendors and service providers.
We provide information and content to vendors and service providers who support our business, such as by providing technical infrastructure services, analysing how our Products are used, providing customer service, facilitating payments or conducting surveys.
Law enforcement or legal requests.
We share information with law enforcement or in response to legal requests in the circumstances outlined below.
HOW CAN I MANAGE OR DELETE INFORMATION ABOUT ME?
We provide you with the ability to access, rectify, port and delete your data. Learn more below.
We store data until it is no longer necessary to provide our services and Posterly products or until your account is deleted – whichever comes first. This is a case-by-case determination that depends on things such as the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. When you delete your account, we delete things that you have posted, and you won't be able to recover this information later. Information that others have shared about you isn't part of your account and won't be deleted.
HOW DO WE RESPOND TO LEGAL REQUESTS OR PREVENT HARM?
We access, preserve and share your information with regulators, law enforcement or others:
In response to a legal request (e.g. a search warrant, court order or subpoena) if we have a good-faith belief that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of the Turkey when we have a good-faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction and is consistent with internationally recognised standards.
When we have a good-faith belief that it is necessary to: detect, prevent and address fraud, unauthorised use of the Products, violations of our Terms or Policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or Products), you or others, including as part of investigations or regulatory enquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account to prevent fraud, abuse and other harmful activity on and off our Products.
Information we receive about you can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation or investigations of possible violations of our terms or policies, or otherwise to prevent harm. We also retain information from accounts disabled for term violations for at least a year to prevent repeat abuse or other term violations.
EU PRIVACY/DATA PROTECTION RIGHTS
EU General Data Protection Regulation (GDPR) has provided the below rights to the EU residents:
Right to information - including contact details to the DPO, the purposes for processing Personal Information and the rights of the individual.
Right to access the Personal Information that are processed
Right to erasure (”Right to be forgotten”)
Right to rectification
Right to restriction of processing
Right to data portability of the Personal Information supplied to Posterly by the EU resident
Right to object (opt-out) to processing (unless Posterly otherwise has compelling legitimate grounds)
EU residents can exercise these rights by raising a request directly at the information provided in CONTACT section.
INFORMATION ON PROTECTION OF PERSONAL DATA IN TURKEY
We would like to inform you regarding your personal data pursuant to Law numbered 6698 on the Protection of Personal Data in Republic of Turkey.
As data controller, Posterly processes your personal data by collecting them in the course of registration to the application since they are directly related to the conclusion and the fulfillment of the subscription agreement.
Posterly’s purposes in processing your personal data are explained above.
Apart from the above mentioned purposes, Posterly does not transfer your personal data and/or traffic data or communication content to third parties without your explicit consent unless it is legally required or compulsory.
In addition to the cases that do not require consent under the Law on Protection of Personal Data, Posterly may notify you of its campaigns and announcements about its services and can contact you for customer satisfaction, through your approval obtained through application.
Your rights with respect to the protection of your personal data are stated below:
To learn whether your personal data is processed,
To request related information if your personal data is processed,
To find out for which purposes your personal data is processed and whether they are used in accordance with these purposes,
To know third parties to which your personal data is transferred domestically or abroad,
To request correction if your personal data is incompletely or incorrectly processed,
To request deletion or destruction of your personal data,
To request the transmission of your correction, deletion and destruction requests to third parties to whom your personal data has been transferred, to object to any consequence occurred against you by analyzing your processed data through automated systems,
To request compensation of damages, if incurred due to unlawful process of your personal data.
The abovementioned information regarding the protection of your personal data can always be reached through the Application.
HOW DO WE OPERATE AND TRANSFER DATA AS PART OF OUR GLOBAL SERVICES?
We share information globally, both internally, and externally with our partners and with those you connect and share with around the world in accordance with this Policy. Your information may, for example, be transferred or transmitted to, or stored and processed in Turkey or other countries outside of where you live for the purposes as described in this Policy. These data transfers are necessary to provide the services set forth in the Posterly Terms, and to globally operate and provide our Products to you. We utilise standard contract clauses, rely on the European Commission's adequacy decisions about certain countries, as applicable, and obtain your consent for these data transfers to the Turkey and other countries.
HOW WILL WE NOTIFY YOU OF CHANGES TO THIS POLICY?
We'll notify you before we make changes to this Policy and give you the opportunity to review the revised Policy before you choose to continue using our Products.
HOW TO CONTACT POSTERLY WITH QUESTIONS
If you have questions about this Policy, you can contact us as described below. We may resolve disputes that you have with us in connection with our Privacy Policies.
You can always contact us: info@posterly.com
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