NYWHASH PRIVACY POLICY

Last Update Date: September 15, 2024

INTRODUCTION

This Privacy Policy explains how Nywhash Software Limited Company ("Nywhash" or the "Company") collects, for what purposes processes, with whom it may share, how we ensure data security regarding your personal data, and your rights regarding your personal data within the scope of all services we provide ("Services") to our users ("User" or "You"). Nywhash acts as the "Data Controller" in accordance with the Personal Data Protection Law No. 6698 ("KVKK") and attaches the utmost importance to the privacy and security of your personal data. This policy is an integral part of the Nywhash Services General Agreement.

ARTICLE 1: PROCESSED PERSONAL DATA AND COLLECTION METHODS

Nywhash collects and processes the data necessary for the provision of the Services, through the methods and in the categories specified below:

1.1. Data Provided Directly by You:

• Identity and Contact Information: Basic information such as name, surname, email address, phone number that you share when creating an account, editing your profile, or contacting us.
• Corporate and Billing Information: Commercial information such as company name, tax office, tax number, address that you share if you create a corporate account or use paid services.
• Payment Information: Credit card information (such as only a masked portion of the card number and expiration date) processed through licensed payment service providers we work with for payment transactions, although not stored directly by us.
• Support Request and Correspondence Information: Messages, documents, and other data you share with us to receive technical support or request information.

1.2. Data Collected Automatically During Use of Services:

• Device and Connection Information: Technical data such as IP address, device type and model, operating system, browser type and version, language preferences used when accessing our Services.
• Usage and Activity Data: Usage logs such as transactions you perform on our Services, login-logout times, pages visited, buttons clicked, your transaction history, and time spent on the system.
• Location Information: Approximate geographic location information (such as country, city) derived from your IP address or browser settings, although not your exact location.
• Cookie Data: Data collected through cookies used to ensure the proper functioning of our website and services, improve user experience, and perform analysis. (Details are specified in Article 4).

ARTICLE 2: PURPOSES AND LEGAL BASIS FOR PROCESSING PERSONAL DATA

Your personal data is processed for the following purposes based on the legal grounds specified in Articles 5 and 6 of the KVKK:

• Provision and Management of Services: To create your account, verify your identity, provide and manage the services you request. (Legal Basis: Being directly related to the establishment or performance of a contract).
• Execution of Financial and Operational Processes: For billing, performing payment transactions, and keeping accounting records. (Legal Basis: Data controller's fulfillment of its legal obligation).
• Communication and Support: To respond to your questions, provide technical support, communicate important notifications regarding the services (maintenance, updates, etc.). (Legal Basis: Establishment or performance of a contract; legitimate interest of the data controller).
• Ensuring Security and Preventing Misuse: To detect suspicious activities, prevent fraud, cyber attacks, and breaches of the Service Agreement. (Legal Basis: Legitimate interest of the data controller).
• Fulfillment of Legal Obligations: To respond to legal requests from authorized authorities and comply with relevant legislation. (Legal Basis: Explicitly provided for by laws; data controller's fulfillment of its legal obligation).
• Improvement of Services and Analysis: To analyze the performance of our Services, improve user experience, and develop new features by using data in anonymized or statistical form. (Legal Basis: Legitimate interest of the data controller).

ARTICLE 3: SHARING OF PERSONAL DATA WITH THIRD PARTIES

Your personal data is never shared with third parties for marketing purposes without your explicit consent. Data sharing is limited only to the following situations and purposes:

• Service Providers and Business Partners: May be shared with third-party service providers with whom we collaborate for the provision of services such as payment infrastructure, data hosting (data centers), email sending, only to the extent necessary and under confidentiality commitments.
• Legal Obligations: Data sharing may be carried out within the framework of legal limits for the purpose of fulfilling binding requests from legally authorized public institutions and organizations such as court orders, prosecutor's requests.
• Service Agreement Violations: In case of detection of fraud, spam, attacks on systems, or other illegal activities, relevant data may be shared with authorized institutions to protect service integrity and defend our legal rights.
• Limited Access for Support Purposes: For the resolution of a technical support request created by the User (e.g., "There is an error in my system"), limited and supervised access to relevant data may be provided for the purpose of identifying and resolving the issue. The User's creation of a support request is interpreted as consent to this limited access.

ARTICLE 4: COOKIES AND SIMILAR TECHNOLOGIES

Cookies are small text files saved to your browser when you visit our website. We use cookies for the following purposes:

• Essential Cookies: Necessary for basic functions of the services such as keeping your session open, operation of security features. Services may not function properly if these cookies are blocked.
• Performance and Analytics Cookies: Help us improve our services by anonymously analyzing site traffic, most visited pages, and user behaviors.
• Functional Cookies: Provide a more personalized experience by remembering your settings such as language preference.

You can manage or delete your cookie preferences as you wish through your browser settings.

ARTICLE 5: DATA SECURITY

Nywhash takes all necessary technical and administrative measures to ensure the security of your personal data. In this context:

• Data is transmitted and stored using strong encryption algorithms (such as SSL/TLS).
• Firewalls, access control systems, and other security technologies are used to prevent unauthorized access to our systems.
• Access to data is limited only to authorized personnel based on the "need-to-know" principle.
• Our systems are regularly audited and security updates are applied against cyber threats.

ARTICLE 6: YOUR RIGHTS AS THE DATA SUBJECT

As the owner of personal data, you have the following rights:

• Learn whether your personal data is being processed,
• Request information if it has been processed,
• Learn the purpose of processing and whether it is used in accordance with its purpose,
• Know the third parties to whom your data is transferred domestically or abroad,
• Request correction if it is incomplete or inaccurately processed,
• Request deletion or destruction within the framework of the conditions set forth in the KVKK,
• Request notification of the correction, deletion, or destruction processes to third parties to whom the data has been transferred,
• Object to the emergence of a result against you by analyzing the processed data exclusively through automated systems,
• Request compensation for damages in case you suffer damage due to unlawful processing of data.

You can contact us through the communication channels specified in Article 9 to exercise these rights.

ARTICLE 7: DATA RETENTION AND DESTRUCTION PERIOD

Your personal data is retained for the period stipulated by the relevant legislation or necessary for the purpose for which they are processed. Upon the expiration of legal retention periods or the cessation of the processing purpose, your personal data is deleted, destroyed, or anonymized in accordance with the Nywhash Data Retention and Destruction Policy.

ARTICLE 8: POLICY UPDATES

Nywhash may update this Privacy Policy from time to time in line with legal regulations or changes in services. The current version of the policy is always published on our website. Significant changes will be separately notified to you via email or through the control panel.

ARTICLE 9: DATA CONTROLLER AND CONTACT INFORMATION

You can contact the Data Controller with the information below for any questions, requests, and complaints regarding this Privacy Policy and your personal data:

• Title: Nywhash Software Limited Company
• Trade Registry No: 6098
• Email (For Privacy Matters): [email protected]
• Address: Silifke/Mersin, Turkey.