Last updated: 13 November 2022

1. Introduction

1.1 Arsus Technologies Ltd (“ReklamUp”, “we”, “us” or “our”) is a Google MCM (Multiple Customer Management) partner operating under the brand ReklamUp that provides monetization services to websites and mobile apps. We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

2. What personal data do we collect?

2.1 In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data. The definition of personal data depends on the laws where you are located and can be broadly defined in the European Economic Area, the United Kingdom and Brazil. In these regions, personal data would include pseudonymous identifiers such as your IP address, Google Advertising ID or Apple Identifier for Advertisers.

2.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. Please see the privacy policy of your social media account provider for more information about how your personal data is processed in such cases. The source of the contact data is you and/or your employer.

2.3 We may process your website user account data ("account data"). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings, bank account details and marketing preferences. The primary source of the account data is you and/or your employer, although some elements of the account data may be generated by our website.

2.4 When we provide Google MCM services, we may process your Google account data (“Google account data”), namely your Google Ad Manager Network ID and Google Ad Manager email address. In such case, Google acts as the data controller. Please see Google’s privacy policy (https://policies.google.com/privacy) for more information about how your personal data is processed in such case. The source of the contact data is you and/or your employer.

2.5 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The source of the contact data is you and/or your employer.

2.6 We may process data about your use of our website and services ("usage data"). The usage data may include your Internet Protocol (IP) address, traffic routing data, system configuration information, and other information about traffic to and from our websites and/or platform. The source of the usage data is our website security system, CloudFlare (https://www.cloudflare.com).

2.7 We do not knowingly process personal data of children under the age of 13. If we are made aware that we have received personal data from someone under the age of 13, we will use our reasonable efforts to remove that information from our records. Where applicable law raises the age of children higher than 13, we will do the same.

2.8 We do not knowingly collect and process sensitive data, that is, personal data related to racial or ethnic origin, politic opinions, religious or philosophical belief, trade union membership as well as genetic data, biometric data, data concerning health, sex life or sexual orientation. If we are made aware that we have received sensitive personal data from someone, we will use our reasonable efforts to remove that information from our records.

3. How do we use the collected personal data?

3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.

3.2 Operations - We may process your personal data for the purposes of operating our website, the processing and fulfillment of orders, providing our services, supplying our services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.3 Access to our services - We may process your account data to enable you to access our extended services on our website/platform. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.4 Relationships and communications - We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, social media direct messages, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.

3.5 Direct marketing - We may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, social media direct messages, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent OR if you are already a customer, our legitimate interests, namely promoting our business and communicating marketing messages and offers to you. You can opt-out at any moment from our direct marketing messages.

3.6 Research and analysis - We may process usage data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is consent OR our legitimate interests when it comes to monitoring, supporting, improving the security of our website, services and business generally.

3.7 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

3.8 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

3.8 Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.10 Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.9 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another natural person.

4. How and when do we share your personal data?

4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.

4.2 Your personal data held in our website database will be stored on the servers of our hosting services provider, namely Hertzner Online GmbH (https://www.hetzner.com/legal/legal-notice), which are located in Germany.

4.3 To ensure the security of our website we use a website security system named CloudFlare. In accordance with section 3.8 of this policy, we may disclose log files including traffic routing data, system configuration information, and other information about traffic to and from our website to Cloudflare, Inc. identified at https://www.cloudflare.com/privacypolicy/ insofar as reasonably necessary for the security of our website. The servers used to process your personal data will depend on your location. The complete list of the servers’ locations can be obtained from https://www.cloudflare.com/network/.

4.4. We use Google Workspace (https://workspace.google.com/intl/en_uk/business/) for the operation of our administration, in particular Google Forms, Google Sheets, Gmail and Google Calendar. As such, your personal data will processed by Google and will be stored on Google servers primarily in Europe and possibly in countries outside of the European Economic Area. For more information about Google’s data centers for Google Workspace, please visit https://www.google.com/about/datacenters/locations/. You can also find information about Google’s privacy policy and practices at https://policies.google.com/privacy.

4.5 Financial transactions relating to our services will be handled by our bank, Türkiye İş Bankası. We will share transaction data with our banks only to the extent necessary for the purposes of processing your payments, invoices, and credit notes, refunding any payments, and dealing with complaints and queries relating to such payments and refunds. You can find information about the banks' privacy policies and practices at https://www.isbank.com.tr/en/privacy-policy.

4.6 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to a country different from the country where you are located.

5.2 We may process your personal data from any country where we operate and may permit our suppliers and subcontractors to do so from the countries where they operate. Please see the following sections for more details. Except if you are located in the European Economic Area or in the UK, by providing us with your personal data, you consent to the transfer of your personal data to the countries where we and our suppliers and subcontractors operate, in accordance with this Privacy Policy.

5.3 The hosting facilities for our website and platform are situated in Germany. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of Germany.

5.4 The hosting of our Cloudflare, Inc. website security services is situated in the United States of America. Transfers to this country is protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities and incorporated in the Data Processing Addendum that we have entered into with Cloudflare, Inc., a copy of which can be obtained from https://www.cloudflare.com/en-gb/cloudflare-customer-dpa.

5.5 The hosting of Google Workspace is situated in Europe and in the United States of America (see https://www.google.com/about/datacenters/locations/). Transfers to countries outside of the European Economic Area and the UK is protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities and incorporated in the Data Processing Addendum that we have entered into with Google, a copy of which can be obtained from https://cloud.google.com/terms/data-processing-addendum.

5.6 The hosting of your personal data processed by our banks is primarily in Turkey. Since the banks act as data controllers, you can find more information on the way your personal data is processed by our banks on the following links: https://www.isbank.com.tr/en/privacy-policy

5.7 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as follows:

(a) contact data will be retained for a minimum period of 1 year following the date of the most recent contact between you and us and for a maximum period of 3 years following that date;

(b) account data will be retained for a minimum period of 1 year following the date of closure of the relevant account and for a maximum period of 1 year following that date;

(c) communication data will be retained for a minimum period of 3 years following the date of the communication in question and for a maximum period of 3 years following that date;

(d) usage data will be retained for a maximum period of 2 years following the date of collection.

6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, for the establishment, exercise or defence of legal claims or in order to protect your vital interests or the vital interests of another natural person.

7. Your rights

7.1 In this Section 7, we have listed the rights that you have under data protection laws and specifically under European Economic Area, Switzerland, UK and Brazil data protection laws. If you are a data subject from California, please see section 7.6.

7.2 Your principal rights under data protection laws are:

(a) the right to access - you can ask for copies of your personal data;

(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;

(e) the right to object to processing - you can object to the processing of your personal data;

(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;

(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and

(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

7.3 These rights are subject to certain limitations and exceptions.

7.4 You may exercise any of your rights in relation to your personal data by emailing us on [email protected]. Depending on the type of request and in accordance with applicable law, we may take up to 30 days to respond to you. Please also note that, in accordance with applicable law, we may proceed to a verification of your identity before fulfilling your request, this, as a measure of security.

7.5 If you are a publisher or a customer with an account, you can access your personal data at any time, update, rectify, delete it as well as change your communication preferences by logging into your account or by emailing support@reklamup.com.

7.6 If you are located in California, you have the following rights:

(a) The right to access the personal data we hold about you;

(b) The right to know what personal data we collect from you before the point of collection

(d) The right to equal services without discrimination;

(d) The right to request deletion of personal data.

8. Our details

8.1 This website is owned and operated by Arsus Technologies Ltd.

8.2 We are registered in Turkey under registration number SL.610 - 085001851 and our registered offices are respectively at Serbest Liman ve Bolge PK 598 Gazimagusa Kktc Mersin 10 Turkey

8.3 Our principal place of business is at Serbest Liman ve Bolge PK 588 Gazimagusa Kktc Mersin 10 Turkey.

8.4 You can contact us:

(a) by post, to the postal address given above;

(b) using our website contact form;

(d) by email, using support@reklamup.com.

9. Amendments

9.1 We may update this policy from time to time by publishing a new version on our website.

9.2 You should check this page occasionally to ensure you are happy with any changes to this policy.