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Privacy Policy

CLARIFICATION TEXT ON THE PROCESSING OF PERSONAL DATA

This Clarification Text has been prepared by Arasana İnternet İletişim ve Telekomünikasyon Limited Şirketi (the “Company”) in order to clarify the Company's customers regarding the processing of their personal data by the Company under the Law No. 6698 on the Protection of Personal Data (the “Law”).

Within the scope of this Clarification Text, it is aimed to inform you in detail about which personal data is collected over https://www.boholive.app (the “Website”) and Boho Live application (the “Application”), methods of obtaining personal data and legal reasons for the collection of personal data, purposes of processing personal data, parties to which the personal data will be transferred and means of transmission, rights of the personal data owners and exercise of the rights by the personal data owners.

1. DATA CONTROLLER

In accordance with the Personal Data Protection Law No. 6698, your personal data can be processed by Arasana İnternet İletişim ve Telekomünikasyon Limited Şirketi, as the data controller, within the scope specified below.

2. PERSONAL DATA PROCESSED

IDENTITY: Name, last name, date of birth, age, gender

MEMBERSHIP: User (member) names, membership password(s), profile picture, information you share in your profile, content you create and broadcast while using the Website/Application (comment, text, message, picture, image, video, audio, code), your correspondence with the Website/Application management, employees, information you submit to in-Website/Application surveys and activities

CONTANCT: Telephone, e-mail address

OTHERS: All information about you, such as preferred language, your transaction and voting information and comments on the Website/Application, your application behavior, habits and preference information that we detect due to to the cookie applications in the website browser, information we collect about the device you use, call and sms data, information you provide from a third-party social media such as YouTube, Facebook, Instagram, Google, etc. when you create a Boho Live account by connecting with that third-party social media or when you connect a Boho Live account to a third-party social media account.

3) METHODS AND LEGAL REASONS FOR OBTAINING PERSONAL DATA

Your personal data is collected electronically or physically in written form when you log in to our Website or Application via computer/tablet and/or phone and/or become a member, in accordance with the data processing purposes in the Personal Data Protection Law No. 6698.

The personal data collected can be processed, shared and transferred through automatic or non-automatic ways within the framework of the personal data processing conditions specified in Articles 5 and 6 of the Personal Data Protection Law based on the legal reasons as it is directly related to the establishment or performance of an agreement, processing of personal data belonging to the parties of the agreement is necessary, it is mandatory for the data controller to fulfill its legal obligation, data processing is mandatory for the establishment, use or protection of a right,

4) PURPOSES OF PROCESSING PERSONAL DATA

Within the framework of the personal data processing condition specified in Article 5 and 6 of the Law, your personal data is processed by the Company to verify your identity, provide, maintain and improve our services, provide service support to users and Third Party Providers, develop security features, authenticate users and send product updates and administrative messages, identify software vulnerability issues and operating problems, analyze data, test and research, follow and analyze usage and activity trends, ensure communication and connection between you and the Third Party Provider, fulfill the requirements of the Membership Agreement, plan and carry out the activities necessary for the recommendation and promotion of the products and services offered by the Company by customizing according to the liking, usage habits and needs of the people concerned, perform the activities necessary through the business units in order for the people concerned to benefit from the products and services offered by the Company and carry out the related business processes, perform the activities necessary through the business units for the realization of the commercial activities carried out by the Company and carry out the related business processes, plan and carry out the Company's commercial and/or business strategies and provide legal, technical and commercial-occupational security of the Company and people in business relationship with the Company and fulfill the court decision or legal procedures.

5) PARTIES AND PURPOSES OF PERSONAL DATA TRANSFER

Within the framework of the personal data processing conditions and purposes specified in Article 8 and 9 of the Law, your personal data can be shared by the Company with the employees, shareholders, business partners, subsidiaries and suppliers of the Company and Interbank Card Center and contracted banks and agencies and advertising and survey companies of the Company and legally authorized institutions and organizations and legally authorized private law legal entities within the scope of the purposes to verify your identity, provide, maintain and improve our services, provide service support to users and Third Party Providers, develop security features, authenticate users and send product updates and administrative messages, identify software vulnerability issues and operating problems, analyze data, test and research, follow and analyze usage and activity trends, ensure communication and connection between you and the Third Party Provider, fulfill the requirements of the Membership Agreement, plan and carry out the activities necessary for the recommendation and promotion of the products and services offered by the Company by customizing according to the liking, usage habits and needs of the people concerned, perform the activities necessary through the business units in order for the people concerned to benefit from the products and services offered by the Company and carry out the related business processes, perform the activities necessary through the business units for the realization of the commercial activities carried out by the Company and carry out the related business processes, plan and carry out the Company's commercial and/or business strategies and provide legal, technical and commercial-occupational security of the Company and people in business relationship with the Company and fulfill the court decision or legal procedures.

6) DATA OWNERS' RIGHTS

In case you submit your requests regarding your rights as personal data owners to the Company by the methods specified under the title of Exercise of Rights by Data Owners, your requests will be assessed and finalized by our Company within the shortest time and within 30 (thirty) days in any case.

In accordance with Article 11 of the Law, you have the following rights as owner of personal data:

  • To learn whether his/her personal data are processed or not,
  • To demand for information as to if his/her personal data have been processed,
  • To learn the purpose of the processing of his/her personal data ad whether these personal data are used in compliance with the purpose,
  • To know the third parties to whom his/her personal data are transferred in country or abroad,
  • To request the rectification of the incomplete or inaccurate data if any and to request the notification of the transaction carried out within this framework to the third parties to which the personal data has been transferred,
  • Despite the fact that it has been processed in accordance with the provisions of the law and other relevant laws, to request the erasure or destruction of your personal data in the case of elimination of the reasons requiring its processing and to request the notification of the transaction carried out within this framework to the third parties to which the personal data has been transferred,
  • To object to the occurrence of a result against the person himself/herself by analyzing the data processed solely through automated systems and
  • To claim compensation for the damage arising from the unlawful processing of his/her personal data.

The cases in which the data owners do not have the right to claim are listed in the second paragraph of Article 28 of the Law and within this framework, the above mentioned rights shall not be exercised in the following cases where the personal data processing:

  • Is necessary for the prevention of committing of a crime or for crime investigation,
  • Is carried out on the data which are made public by the data subject himself/herself,
  • Is necessary for performance of supervision or regulatory duties and disciplinary investigation and prosecution to be carried out by the assigned and authorized public institutions and organizations and by public professional organizations in accordance with the power conferred on them by the law and
  • Is necessary for the protection of economic and financial interests of the State related to budget, tax and financial matters.

And in accordance with the first paragraph of Article 28 of the Law, since the data will be outside the scope of the Law, the requests of the data owners shall not be processed in terms of these data:

  • The personal data are processed by natural persons within the scope of purely personal activities of the data subject or of family members living together with him/her in the same dwelling provided that it is not to be disclosed to third parties and the obligations about data security is to be complied with.
  • The personal data are processed for official statistics and provided that they are being anonymized for the purposes for such as research, planning and statistics.
  • The personal data are processed with artistic, historical, literary or scientific purposes or within the scope of freedom of expression provided that the national defense, national security, public security, public order, economic security, right to privacy or personal rights are not violated or the process does not constitute a crime.
  • The personal data are processed within the scope of preventive, protective and intelligence activities carried out by the public institutions and organizations duly authorized and assigned by law to maintain national defense, national security, public security, public order or economic security.
  • The personal data are processed by the judicial authorities or execution authorities with regard to the investigation, prosecution, judicial or execution proceedings.

7) EXERCISE OF THE RIGHTS BY THE DATA OWNERS

The data owners will be able to use the “Form for the Applications by Personal Data Owner to the Data Controller” at https://boholive.app/contact link to exercise the above mentioned rights.

The applications will be made by one of the following methods, together with the documents that will identify the relevant data owner:

  • By filling out the form, sending the original signed copy by means of a notary or by registered and reply paid letter to [Dikilitaş Mah. Hakkı Yelen cad. Selenium Plaza No:10 34349 Beşiktaş-Turkey] address,
  • Following a method stipulated by the Personal Data Protection Board.

The Company responds to the data owners requesting to exercise such rights within the limits stipulated in the Law within a maximum of thirty (30) days as stipulated in the Law. In order for the third parties to make application requests on behalf of the personal data owners, there should be a special power of attorney issued by the data owner through a notary on behalf of the applicant.

As a principle, the applications of data owners are processed free of charge; but remuneration can be made over the fee tariff stipulated by the Personal Data Protection Board.

The Company can request information from the relevant person in order to determine whether the applicant is the personal data owner and in order to clarify the issues specified in the application, can ask questions about the application to the personal data owner.

8) STORAGE PERIOD OF PERSONAL DATA

Your Personal Data will be stored by the Website and Application within the framework of the conditions specified in this Clarification Text and for the period necessary for the purpose for which they are processed (limited to the periods specified in the relevant laws) in order to fulfill the obligations arising from the nature of the Website and Application.

In addition, in case of any dispute that may arise, the Website and Application will be able to store personal data for the limited period of time specified in accordance with the relevant legislation in order to provide the necessary defenses within the scope of the dispute.