Tradepot Privacy Policy

1. DEFINITIONS

Definitions

For the purposes of this Privacy Policy:

You means the individual accessing or using our Services through our website, or the company, or other legal entity on behalf of which such individual is accessing or using our Services through our website, as applicable.

Under Turkish Data Protection Law no 6698 (KVKK) and the EU General Data Protection Regulation (GDPR), You can be referred to as the Data Subject or as the User as you are the individual using our Services.

Company (referred to as either "the Company", “Tradepot”, "We", "Us" or "Our" in this Policy) refers to Tradepot Limited Sirketi, Büyükdere Cad. Nurol Plaza No:255 D:21/A, Maslak 34450 Istanbul, Turkey.

For the purpose of KVKK and the GDPR, the Company is the Data Controller.

Account means a unique account created for You to access our Service or parts of our Service.

Website refers to Tradepot, accessible from Tradepot.com

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

For the purpose of KVKK and the GDPR, Service Providers are considered Data Processors.

Personal Data is any information that relates to an identified or identifiable individual.

For the purposes for KVKK and the GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Usage Data refers to data collected automatically, either generated by the use of our Services or from the Services infrastructure itself through our website.

Data Controller, for the purposes of KVKK and the GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

2. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when registering and creating an account on our website expressing an interest in obtaining information about us or our products and services, when participating in activities on our website or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and our Services, the choices you make and the products and features you use. The personal information we collect can include the following:

Publicly Available Personal Information. We collect first name, last name, nickname, ID, address, email addresses, phone numbers, phone number, business entity filings, corporate affiliations, business associates, and other similar data.

Personal Information Provided by You. We collect your purchase history, and other similar data related to your preferences on our website.

Credentials. We collect passwords and similar security information used for authentication and account access.

Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our third party online payment services provider PAYLAX, based in Germany. You may find their privacy policy link(s) here: https://paylax.de/.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

Online Identifiers. We collect tools and protocols, such as IP (Internet Protocol) addresses, cookie identifiers, or others such as the ones used for analytics and marketing, and other similar data.

For more information about the types of cookies we use and how we use them please visit our Cookie Policy.

3. HOW DO WE USE YOUR INFORMATION?

We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

Account creation and logon process. We use the information you provide us to facilitate account creation and logon process for the performance of our services and give you access to different functionalities of the Service that are available to you as a registered user.

To send you marketing and promotional communications. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (please see Section 9. WHAT ARE YOUR PRIVACY RIGHTS below)

To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.

Deliver targeted marketing to you. We may use your information to develop and display content and marketing (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

Request Feedback. We may use your information to request feedback and to contact you about your use of our Services.

To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent under the Tradepot Terms and Conditions of Use.

To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).

To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual.

To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

To manage user accounts. We may use your information for the purposes of managing your account and keeping it in working order.

To deliver services to the user. We may use your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

4. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share data based on the following legal basis:

Consent: We may process or share your data if you have given us explicit consent to use your personal information for a specific purpose.

Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

Performance of a Contract: Following the creation of your account on pour website, we may process your personal information to fulfill our contractual obligations under our Terms and Conditions.

Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Third-Party Advertisers. We may use third-party advertising companies to serve ads when you use our Services. These companies may use information about your visits to our Website and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.

Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Business Partners. We may share your information with our business partners to offer you certain products, services or promotions in line with your user preferences and privacy settings.

Please note that our website may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy . We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Services . You should review the policies of such third parties and contact them directly to respond to your questions.

5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

Our web servers are located in the United States. If you are accessing our Services from outside Turkey, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information in other countries. We currently only make international transfers to Germany, Ireland and United States, all of which are deemed to provide adequate protection under the GDPR.

We will take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible then we will securely store your personal information and isolate it from any further processing until deletion is possible.

We also retain usage data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our services, or we are legally obligated to retain this data for longer time periods under applicable laws.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at privacy@tradepot.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

We take full responsibility to respect the confidentiality of your Personal Data and to guarantee that you can exercise your rights.

You have the right under this Privacy Policy, and by law, to:

Request access to Your Personal Data. The right to access, update or delete your personal data and related information on its processing, including transfer to third parties and international transfers. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the personal data we hold about you.

Request correction of the Personal Data that we hold about you. You have the right to to have any incomplete or inaccurate information we hold about you corrected.

Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.

Request erasure of your Personal Data. You have the right to ask us to delete or remove Personal Data when there is no good reason for us to continue processing it.

Request the transfer of your Personal Data. We will provide to you, or to a third-party you have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw Your consent. You have the right to withdraw your consent on using your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of our services on our website.

You may exercise your rights by contacting us by filling in the request form on our website, and sending it via secure e-mail to privacy@tradepot.com or by post to Büyükdere Cad. Nurol Plaza No:255 D:21/A, Maslak 34450 Istanbul, Turkey. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible and within maximum 30 days.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data.

If you have questions or comments about your privacy rights, you may email us at privacy@tradepot.com.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log into your account settings and update your user account.
• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For detailed information please visit our Cookie Policy.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:

• Note your preferences when you register an account with the site.
• Access your account settings and update preferences.
• Contact us using the contact information provided.

10. OUR DATA BREACH POLICY

A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when Tradepot believes you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that Tradepot becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information Tradepot will promptly investigate the matter and notify the applicable Data Protection Supervisory Authority not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we will notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.