Papel Individual Customer Clarification Text
PAPEL WALLET CUSTOMER CLARIFICATION TEXT ON THE PROTECTION AND PROCESSING OF PERSONAL DATA
Papel Elektronik Para ve Ödeme Hizmetleri Anonim Şirketi ("Our Company" or "Papel"), as the data controller residing at Maslak Mah. Eski Büyükdere Cad. Link Plaza Sitesi Link Plaza Blok No: 3-5 Interior Door No: 33 Sarıyer/İstanbul, may process, transfer, and store your general or special categories of personal data within the framework of the following purposes and conditions in accordance with the Personal Data Protection Law No. 6698 ("KVKK"). This Papel Wallet Customer Clarification Text on the Protection and Processing of Personal Data ("Clarification Text") has been prepared to inform Papel Wallet ("Wallet") users about how and why we collect, process, store, and transfer your personal data and to whom and for what reason.
1. Methods of Collection of Personal Data
We may collect your personal data in the following cases:
- When you create a Wallet account.
- When you verify your Wallet account.
- When you contact us via our customer service, social media accounts, or other communication channels.
- When you log in to your account or make any payment transactions such as top-up, withdrawal, or transfer of funds.
- From other payment service providers to make open banking services available to you.
We may collect your personal data from the information and documents you have submitted to Papel, through the mobile application and website, from the devices you use, from public platforms and social media accounts, or through other persons and institutions we have contracted with or authorized public institutions and organizations.
2. Processed Personal Data
Papel will process your personal data for the purposes specified in this Clarification Text. The categories of personal data collected and used are as follows:
| Data Category | Personal Data |
|---|---|
| Identity Data | Name-surname, Turkish ID number, parents' names, gender, place and date of birth, address details, signature, etc. |
| Contact Data | Telephone number, email, residence address, workplace address, proof of residence. |
| Location Data | Geolocation information of the device where the Wallet is used. |
| Financial Data | Monthly net income, bank account information, invoice amount, balance, limit information, transactions, etc. |
| Audio and Visual Data | Photo, video, audio recording data. |
| Occupational Data | Job and occupational data. |
| Customer Transaction Data | Call center records, past transaction records, invoice information, campaign information, etc. |
| Transaction Security | IP address, Wallet login-logout information, successful and unsuccessful login attempts, security questions, etc. |
| Marketing Data | Shopping history, segment information, information obtained through campaigns. |
| Legal Proceedings Data | Documents and contracts provided by individual customers or received from courts and administrative authorities. |
| Biometric Data | Face recognition data. |
3. Purposes of Processing Personal Data
Your personal data may be processed for the following purposes:
- Legal Obligations: To comply with the Law No. 6493 on Payment Services and Electronic Money Institutions, Law No. 5651 on Internet Regulation, and MASAK Legislation.
- Contractual Obligations: To ensure the establishment and performance of the contract you are a party to by accepting the framework agreement regarding the payment service offered by Papel.
- Account and Identity Verification: Completing registration, creating users and accounts, and ensuring secure access to the application.
- Service Delivery: To benefit from the products and services offered by Papel, manage permissions, and provide information on transactions.
- Finance and Accounting: Carrying out financial transactions, keeping current accounts, ensuring financial reconciliation, etc.
- Data Security: Ensuring information and operational security, assessing risks, and performing suspicious transaction controls.
- Complaint Handling: Receiving and addressing complaints, suggestions, and user requests.
- Compliance: Sharing information with regulatory and supervisory authorities as required by legal regulations.
- Improvements: Enhancing website and applications, improving user experience, internal quality control, etc.
- Open Banking Services: Providing open banking services.
Your personal data may also be processed for other purposes with your explicit consent, such as sending instant campaign notifications, conducting marketing analyses, participation in lotteries, and processing biometric data.
4. Legal Grounds for Processing Personal Data
We process your personal data only if there is a valid legal reason in accordance with the KVKK:
- Explicitly Stipulated in the Laws: When processing is required under Law No. 6493 and related regulations.
- Establishment and Performance of the Contract: When you accept the framework agreement, we process your data to fulfill contractual obligations.
- Legal Obligations: To comply with requests from courts, administrative authorities, and regulatory bodies.
- Legitimate Interests: Provided that it does not harm your fundamental rights and freedoms, for purposes such as ensuring application security and functionality.
- Necessity for Establishment, Exercise, or Protection of a Right: For example, to file or respond to a lawsuit.
- Publicized by the Relevant Person: Processing data made public by you for purposes such as addressing your complaints.
- Open Consent: For sending promotional messages, marketing activities, and processing biometric data.
5. Transfer of Personal Data to Third Parties
Your personal data may be disclosed to group companies, shareholders, authorized institutions, suppliers, external service providers, other payment service providers, the Central Bank of the Republic of Turkey, and others for the purposes specified in Article 3, provided necessary security measures are taken. Third parties may only process your personal data for the purpose of the transfer.
6. Your Rights as a Personal Data Owner
Pursuant to Article 11 of the KVKK, you have the following rights:
- To learn whether your personal data is being processed.
- Request information if your personal data has been processed.
- Learn the purpose of processing and whether it is used in accordance with its purpose.
- Know third parties to whom your personal data is transferred.
- Request correction in case of incomplete or incorrect processing.
- Request deletion or destruction of personal data when the reasons for processing disappear.
- Request notification of correction and deletion to third parties to whom data was transferred.
- Object to results based on automated processing.
- Request compensation for damages in case of unlawful processing.
To exercise any of these rights, you may submit your request in person, through a notary public, or by email as specified on our website.
Sincerely,
Papel Elektronik Para ve Ödeme Hizmetleri Anonim Şirketi
