Privacy Policy for Qertas

1. General Overview

1.1.
Qertas is an online-based digital subscription service that provides access to the Qertas website, e-books, and other literary content on your mobile phone, tablet, or other devices according to the terms of use and this privacy policy ("Policy"). This service is provided by Qertas-Turkey, an electronic application operating under license:
QERTAS YAYINCILIK KİTAP MATBAA SANAYİ VE PAZARLAMA LİMİTED ŞİRKETİ VERGİ DAİRESİ : KÜÇÜKKÖY VERGİ NUMARASI : 6311696792

1.2.
This privacy policy explains Qertas's practices regarding the collection, storage, and use of certain specific information, and the disclosure of that specific information, including your personal data, when providing the service to you. This policy also applies to individuals who visit our website or download and use our application. It informs you about how we process your personal data, ensuring respectful treatment and compliance with data protection regulations when using the service.

1.3.
You should always feel secure when sharing your personal data with Qertas. Qertas has implemented appropriate technical and organizational security measures to ensure the protection of your personal data, especially from unauthorized access, disclosure, use, modification, destruction, or loss. If you are not satisfied with the content of this privacy policy, you can always choose to refrain from using the service at any time.

2. Data Controller

2.1.
Qertas is the data controller responsible for monitoring and processing your personal data. You can contact Qertas regarding various matters, such as integrity and privacy. Information on how to contact us can be found in section 13.

3. When and how does Qertas collect personal data?

3.1.
Qertas collects personal data about you at the following times:
When you create your account with Qertas and/or use the service.
When you request additional services or additional products from Qertas.
When you install and/or use any app included in the service with or without a subscription plan.
When you visit the website.
When you register as a subscriber to Qertas's newsletter.
When you report errors, violations, inappropriate materials, or when you contact Qertas customer service for any other reason.
When you link the service to your Facebook account or any similar external service, in which case we receive data from the external service site.
When you respond to surveys, including but not limited to customer satisfaction surveys or marketing survey questionnaires, or when you respond to correspondence sent by Qertas.
When it is necessary to manage the relationship between you and Qertas.

3.2.
Qertas also collects information through our own or third-party cookies and similar tracking technologies (including, but not limited to, beacons, tags, or pixels) that may track your activities and choices, such as when you download our app, use the service, or visit our website. This includes purposes like facilitating login, remembering your preferred settings, sending targeted marketing ads, and measuring the success level of advertisements. More information about Qertas's use of cookies can be found in Qertas's Cookie Policy on the Qertas website.

4. What personal data does Qertas collect?

4.1.
When you create or set up an account with Qertas, or when you contact Qertas customer service, Qertas collects personal data about you. This includes basic user data collected by Qertas, your contact information, such as your name and/or username, email address and/or phone number, and your payment details, such as your credit card type and expiration date. Qertas may also collect data about your date of birth, gender, and additional contact details like your address. Qertas may collect personal data you provide about your family members (including names, email addresses, birthdays, and interests) and, if you choose to provide this personal data about your family members, you are responsible for obtaining their consent and notifying them of our processing activities related to that data.

4.2.
When you use the service or any additional services or products from Qertas, and visit the website and Qertas app, Qertas may also collect usage-related data (such as address selections or search queries), display information (such as displayed content), and technical data (such as unique platform identifiers, phone or platform versions, IP address, Qertas app version, language settings, user location information, encrypted passwords, cookie data, or internet browser type). If you register as a paying subscriber when initially subscribing to Qertas, Qertas may need to collect and process some information you provide to the payment service provider to facilitate the billing process.

4.3.
If you choose to link the service to your Facebook account or similar external third-party service that monitors personal data, Qertas may collect and process the personal data you provided to Facebook or any other external party, in addition to obtaining permission to share it with Qertas. Qertas encourages you to review the privacy practices of these external parties.

4.4.
Furthermore, Qertas may collect and process personal data you provide in public forums on the Qertas website or to Qertas when using the Qertas website or Qertas's websites on external platforms, such as app stores or social media sites. Qertas may link your profile on external sites or platforms to your personal account.

4.5.
Qertas may also collect and process specific personal data related to your eligibility and suitability to use the service and the payment method you chose. However, as Qertas collaborates with third-party payment service providers, and these providers operate independently through systems separate from Qertas, Qertas does not store complete payment data, such as full credit card numbers. Qertas encourages you to review the privacy practices of these external parties providing payment services.

5. How long is the data retained?

5.1.
Qertas retains your personal data only as necessary for relevant processing activities.

5.2.
This means that personal data collected and processed for marketing purposes will be stored and retained as long as you are a subscriber and for twelve (12) months after the end of your subscription unless you agree to continue Qertas's processing of this data after the mentioned period.

5.3.
For contractual obligations, monitoring and documenting the use of gift cards, trial period extensions, and other additional services, Qertas will store and retain the personal data you provided during registration and account creation (such as your name and/or username, email address, and/or phone number) as long as you are a subscriber or for twenty-four (24) months after your subscription ends or after the expiration of the gift card or after the trial period ends, whichever comes last.

5.4.
Qertas will retain and keep your personal library information for e-books on Qertas during your subscription and for twenty-four (24) months afterward to facilitate and enhance your experience and facilitate your return to subscription if you choose to return within the aforementioned time frame.

5.5.
When you contact Qertas for support or for any other purposes, we will retain your personal data for twenty-four (24) months after the completion of your last support ticket (such as issues and requests).

5.6.
Your personal data will be processed for analytical purposes during your subscription and for twenty-four (24) months afterward.

5.7.
Qertas may retain your personal data for longer periods than those mentioned if required by the law or to establish, exercise, or defend legal rights in legal proceedings.

6. Where is personal data stored?

6.1.
Your personal data is stored on servers located in the country where the contracting party is established (as specified in the terms of use). Personal data is also stored in Turkey, where Qertas's headquarters is located. Regarding international transfers, Qertas applies the security measures specified in section 10.5 below.

7. Why does Qertas process your personal data?

7.1.
Qertas processes your personal data for various purposes. Primarily, Qertas processes your personal data to manage the relationship between you and Qertas and to fulfill Qertas's legal obligations. Additionally, Qertas may process your personal data for market analysis, customer segment analysis, marketing research, statistics, business monitoring, and business methodology development to enhance and customize the service and its features.

7.2.
Qertas also processes your personal data to provide better and more suitable offers and services. Qertas processes your data to reduce the risks of sending irrelevant advertisements or other unrelated marketing campaigns. For example, personal data may be processed, linked, aggregated, and analyzed through targeted marketing channels such as email, in-app notifications, and advertisements on external advertising channels. This is done to provide information, offers, or recommendations about Qertas's products, services, or its partners, tailored to your preferences, behavior, needs, style, and lifestyle. Qertas may also use personal data as a basis for marketing campaigns targeting an audience similar to the current Qertas audience. This may include, for example, processing personal data to establish an audience of customers on external platforms such as Facebook and Google. Additionally, Qertas may analyze and integrate your information obtained through the service, including your online visits or other records (such as records from similar social media companies like Facebook) for the purposes outlined in this section.

7.3.
In addition to the above, Qertas processes your personal data to prevent, detect, investigate, and address prohibited or potentially illegal activities, including forgery or fraud, and to enforce and implement its terms (e.g., determining eligibility for free trial versions, other offers, or marketing campaigns, as applicable).

8. What is the legal basis for processing?

8.1.
Qertas processes most of your personal data because it is necessary to fulfill the terms, enabling Qertas to provide and manage the service and its features. This includes processing your contact information, such as email address or phone number, or information obtained from your payment service provider.

8.2.
Qertas processes some data based on the balance of interests; that is, the legal interest of Qertas in processing the data outweighs the impact or risks that may result from the processing on your data privacy. This includes processing your personal data for support purposes (i.e., general support requests) or for specific marketing purposes, excluding direct marketing. Additionally, Qertas retains information about your audiobooks or e-books library (including literary content) after your subscription ends.

8.3.
Moreover, some personal data is processed based on your consent. This applies to the processing of personal data obtained from your Facebook account for direct marketing purposes of Qertas's products or services or those of its partners. If you provide personal data about other natural persons, such as your family members, you are responsible for ensuring their consent to the processing of their personal data.

8.4.
When processing data based on legal consent, you have the right to grant or refuse this consent at any time, either in whole or in part.

9. Data Security and Integrity

9.1.
The security, integrity, and confidentiality of personal data are important to us. We have implemented technical, administrative, and physical security measures designed to protect your personal data from unauthorized access, disclosure, use, modification, destruction, or loss. Periodically, we review our security measures to assess the need for additional measures or to implement technical updates to current procedures. Please note that, despite our best efforts, some security measures are susceptible to breaches. Therefore, we request you to promptly inform us of any suspicious activities noticed within the service.

10. Who does Qertas disclose your personal data to?

10.1.
Qertas may disclose your personal data to Qertas branches, meaning companies within the Qertas group, business partners, suppliers, or other entities, to fulfill agreements with you, comply with agreements with Qertas's suppliers and business partners, or for other purposes as specified in this privacy policy. This may include providing information to your bank, for example, to demonstrate compliance, resolve disputes, clarify misunderstandings, etc.

10.2.
Qertas may also disclose your personal data to external parties for sending personalized marketing or advertising materials to you, avoiding the sending of irrelevant marketing materials, measuring the success and reach of our digital marketing, and for other promotional purposes. This occurs when Qertas uses retargeting features, renews marketing activities, uses reports on impressions, interests, and geographic reports in Google Analytics, uploads custom audiences on platforms like Facebook and Google, and informs business partners such as Facebook and Google of specific marketing actions resulting in acquiring new customers.

10.3.
Qertas may also disclose personal data to companies processing data on behalf of you, such as our IT system providers, customer service companies, or our subsidiaries. In cases of disclosing personal data to data processing companies on behalf of Qertas, Qertas enters into data processing agreements with those parties to ensure a high level of security for your personal data.

10.4.
Personal data may also be disclosed, when necessary, to comply with legal requirements or requirements imposed by law enforcement agencies or authorities, to protect Qertas's legal interests, or to detect, prevent, or disclose fraud, forgery, or other security or technical issues.

11. Links to External Websites

11.1.
Information provided by Qertas may contain links to websites operated or owned by individuals or entities other than Qertas. Qertas is not responsible for the processing of personal data carried out on these external websites. Qertas encourages you to review the privacy practices of entities monitoring these external websites.

12. Changes to the Privacy Policy

12.1.
This privacy policy may be reviewed from time to time. If Qertas makes any material changes to the privacy policy, Qertas will notify you of these changes via email, SMS, or through the service before the changes take effect. The latest version of our privacy policy will also be published on the Qertas website. If your consent is required for any changes, Qertas will request this new consent from you. We encourage you to regularly review this privacy policy to stay informed about our data processing practices.

12.2.
Please note that some of the rights mentioned above may be exercisable only in specific situations, such as the right to data portability, which applies only when processing is based on contractual necessity or contractual consent, or when processing is carried out through automated means. The right to delete or erase data applies only when processing data based on the balance of interests or when consent is given. If you have any questions regarding how Qertas processes your personal data or if you wish to exercise any of your rights or learn more about your rights, you can contact us at the email address Qertasllc@gmail.com.

12.3.
If you do not want Qertas to process your personal data for direct marketing purposes, you can notify Qertas. Additionally, for each newsletter sent to you, you will be notified of the option to not receive more newsletters if you wish. Regarding advertising notifications, you can choose not to receive these notifications (on most mobile or tablet devices) by going to your device's "Settings," then clicking on "Notifications," and changing those notifications for some or all applications on your device. As for cookies, Qertas's cookie policy outlines your options for not storing cookies.

12.4.
You have the right to lodge a complaint with the supervisory authority if you believe that your personal data has been processed in a manner inconsistent with data protection regulations. If you are a resident in Turkey or if your workplace is in Turkey, or if the alleged breach of data protection law occurred in Turkey, you have the right to lodge a complaint with the Turkish Data Protection Authority.

Last reviewed on December 16, 2021.

QERTAS YAYINCILIK KİTAP MATBAA SANAYİ VE PAZARLAMA LİMİTED ŞİRKETİ

VERGİ DAİRESİ : KÜÇÜKKÖY

VERGİ NUMARASI : 6311696792