Web Site Data Protection Privacy Notice

Information Obligation in Accordance with Articles 13 and 14 of GDPR (No: 2016/679) and the Article 10 of Personal Data Protection Law, (PDPL, No: 6698)

The following information is intended to give you an overview of the personal data processed by us during your visit to our web site and to inform you about your data protection rights. 

1. Data Controller responsible for data processing and Contact Person

Data Controller:

İninal Elektronik Para Ve Ödeme Hizmetleri A.Ş.

2. Method and Legal Reason of Collecting your personal data

We collect information about you from different places including:

• directly from you
• from a third party acting on your  behalf
• from publicly available sources
• when we generate it ourselves
• from other organisations.

We’ll only use your information in accordance with Articles (4, 5) and (6) of the PDPL, where we have your consent or we have another lawful reason for using it. Unless we say otherwise below, we’ll use your personal information on the basis that it’s within our legitimate interests in operating and maintaining the site, and providing you with site functionality and related services. We also use information to meet our compliance obligations, to comply with other laws (such as the one no. 6493 on payment service providers) and regulations and to share with regulators and other authorities  that Ininal is subject to. This may include using it to help detect or prevent crime including terrorism financing, money laundering and other financial crimes. We collect and process your personal data electronically, and obtain your personal data in order to be able to present the products and/or services we offer within the legal framework and our legitimate interest.

Here we give you a general overview of some of the ways this website processes your personal data including the use of cookies and making an inquiry.

3. Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our website, we may collect information from you automatically through cookies or similar technology. For further information about cookies we use, please visit our for the policy and for all information about cookies visit allaboutcookies.org.

4. Making Contact

If you wish to send a message via our web site, you can click on the Contact button on the web site and submit your message through our info e-mail address by using your name- surname and e-mail address.

5. For what purposes and on what legal basis is your personal data processed?

The company use the collected personal data according to the provisions laid down in GDPR and PDPL to:

• Manage our legal business processes such as KYC (Know Your Customer), AML (Anti-Money Laundering), anti-fraud (Fraud Prevention) and combat other illegal transactions, especially financial security processes, 

• Respond to your queries and feedback (for example, if you’ve asked a question or submitted feedback via the site) 

• Provide you with information about Ininal products or electronic payment services you have requested or which we feel may interest you, unless you tell us otherwise 

• Fulfil mandatory identification and verification procedures to ensure the highest level of personal, financial and commercial data security in electronic payment services,  

• Establish appropriate information infrastructure and databases, and taking administrative technical measures, 

• Carry out our obligations from any contracts entered into between you and us 

• Allow you to participate in any interactive features of the site 

• Notify you about changes to the site 

• Ensure site content is presented in the most effective manner for the device you’re accessing it from 

• undertake data analytics to learn more about how you and others interact with this site and with our advertising 

• Detect and prevent misuse or abuse of this site or our services 

• Improve our products and services  

• Promote payment services offered by Ininal by means of audio-visual and social media, by carrying out corporate and product based image studies, 

• ensure the highest level of data security and create databases, 

We’ll only use your information where we’re allowed to by law no. 6493 on payment service providers, carrying out an agreement we have with you, fulfilling a legal obligation, because we have a legitimate business interest or where you agree to it. For detailed information about the legal bases and purposes for processing personal data see our Privacy Policy.  

6. Is data disclosed to a part?

Under certain conditions outlined in laws; ● no. 6493 on payment service providers ● no. 5599 on Prevention of Laundering Proceeds of Crime Law ● no.5651 on Regulation of Publications on the Internet and Combating Crimes Committed by Means of Such Publication,) -known as “the Internet Law”), We may disclose your information;  

●in order to provide you with products or services you’ve requested (for example, if they’re not provided by the Ininal entity operating this site), ● if we have a legitimate interest in doing so (for example, to manage risk, verify your identity, to combat fraud, abuse of our site or services), ● or where you’ve agreed to us doing so. 

●We may share your information with the competent public authorities who we’re under an obligation to disclose information to prevent or detect fraud, abuse of our site or services, or where it’s in the public interest ( for example to The Central Bank of the Republic of Turkey, Ministry of Treasury and so),  ● and also to any of our service providers. 

●Providing publicity and awareness about Ininal products and services  in social media, video platforms, etc., establishing the necessary infrastructure and services for corporate electronic communication channels, providing data security with the required information systems ; Within the scope of using applications such as instant messages, video conferences, meetings etc., which are widely and inevitably used in daily life in order to carry out business activities quickly and effectively; We can share your data via Zoom, Whatsapp, Facebook, Instagram, Youtube and Twitter, 

●We also share your some data  with the representatives of   foreign / international organizations such as MasterCard and Visa or private institutions and organizations in order to carry out their activities as a representative of the company, 

Your personal data shared through these tools and channels are processed on the servers and systems of those companies located abroad. You can take a look at the Privacy Policies of the relevant organizations regarding the security measures taken by the suppliers providing these services to protect your personal data given below: 

• Zoom (https://zoom.us/privacy) 

• Whatsapp (https://www.whatsapp.com/legal/client) 

• Instagram (https://help.instagram.com/519522125107875) 

• Twitter (https://twitter.com/en/privacy) 

• YouTube ( https://www.youtube.com/t/terms)  

IP addresses

We may collect information about your computer (or mobile device), including where available your IP address, operating system and browser type, for system administration or for our own commercial purposes. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

7. Data retention

In accordance with the Art 7 in the Law, KVK no: 6698; We process and store your personal data as long as it is necessary for the fulfilment of our legal obligations and legitimate interests. If the storage of personal data is no longer necessary for the fulfilment of these obligations, it will be deleted, unless there are legal obligations to retain such data (i.e. the Internet Law No: 5651 mentioned above), or such as commercial and fiscal obligations of for the preservation of evidence within the framework of statutory limitation rules.

8. Rights of the data subject

You have the following rights with regard to your personal data:

• Right to information 

• Right to rectification or erasure 

• Right to restriction of processing 

• Right to object 

• Right to data portability 

• You also have the right to complain to a data protection supervisory authority about our processing of your personal data. 

However, firstly you also have the option of contacting to the Contact Person of Data Controller mentioned above at Ininal. If you have given us your consent (Art. 5/1 PDPL, Art. 6(1/a) GDPR), you can revoke it at any time with effect for the future. If we base the processing of your personal data on legitimate interests (Art. 6(1/f) GDPR), you may object to the processing. In the event of such an objection, we kindly ask you to explain why we should not process your personal data. In the event of a justified objection, we will examine the situation and either discontinue or adapt the data processing or point out legitimate reasons why we will continue the processing, likewise in the Law, PDPL no: 6698 You can object to the processing of your personal data for advertising purposes at any time.

9. Submission of the Application

Pursuant to paragraph 1 of Article 13 of the PDPL, you can send your request for exercising your rights specified in article 11 of the same Law, to the Contact Person [kvkbasvuru@ininal.com] by using the registered e-mail (REM) address or the e-mail address that you have previously notified to our company and registered in our system, or to our company's contact address in writing in person.

10. How to contact with the appropriate authority

Should you wish to report a complaint or if you feel that Our Company has not addressed your concern in a satisfactory manner, you may contact with the Personal Data Protection Authority (KVKK) in Turkey that contact details given below.

Kişisel Verileri Koruma Kurumu
Nasuh Akar Mahallesi,
Ziyabey Cad. 1407. Sok. No:4,
06520 Çankaya/Ankara
Tel : +90 312 216 50 00 Web: www.kvkk.gov.tr