Exxen - Privacy Policy

Privacy Policy

This Privacy Policy explains the procedures we follow for the protection of personal data by EXXEN Dijital Yayıncılık A.Ş. (“EXXEN”), which includes your rights as well as our obligations regarding the collection, use and transfer of various information, including your personal data. This Privacy Policy has been prepared in accordance with the provisions of the Law on Personal Data Protection No.6698 (“KVVK”) and the General Data Protection Regulation (“GDPR”).

The data controller of your personal data is EXXEN.

Your personal data, which you provided/will provide to EXXEN and/or obtained by EXXEN through any external means, will be processed as “Data Controller”,

In the context of the objective of processing your personal data and in connection with this purpose, in a limited and measured manner,

By maintaining the accuracy the most up-to-date version of the personal data as reported or notified to our Company,

May be recorded, stored, preserved, reorganized, and be transferred to the institutions authorized to request such personal data by law and shall be transferred, shared with and classified to third parties within the country or abroad under the conditions stipulated by KVKK, that they may be processed in other ways listed under KVKK and that they are subject to other procedures referred to in KVKK.

Collection of the Personal Data

We obtain, store and transfer some of your personal data from you in order to provide our services.

  • Information provided by you:

Name and surname, contact information (e-mail address, phone number), payment method (s) provided by you according to which package you will use.

  • Information we collect automatically:

We collect information about the computer, network, network devices or other EXXEN compatible devices you may use to access our service (game consoles, smart televisions, mobile devices, set-top boxes and other broadcast devices).

  • Information from partners:

The personal data which we shared with our third-party partners. These Partners might include (depending on what services you use): your TV or internet service provider, or other streaming media device providers who make our service available on their device; mobile phone carriers or other companies that provide services to you and collect payment for the EXXEN service for distribution to us or provide pre-paid promotions for the EXXEN service.

Use of the Personal Data

Your personal data will be processed with the automatic or non-automatic means for the aims stated below stern with the applicable legislation, in cases where your express consent is obtained, in the case when it is expressly permitted by any law, the establishment of the contract or the directly related with the execution or performance of the contract, in case it is necessary for EXXEN to fulfil its legal obligations, in case it is necessary for the institution, usage, or protection of a right and when it is necessary for the legitimate interests of EXXEN, provided that the fundamental rights and freedoms of the data subject are not harmed.

The purposes of processing personal data may be updated in line with our obligations arising from company policies and legislation; in particular,

  • Carrying out the information security, financial and accounting processes,

  • Preventing, detecting and investigating potentially prohibited or illegal activities, including fraud, and enforcing our terms,

  • Conducting e-invoice transactions,

  • Ensuring adequate support within the scope of customer service lines to be provided by EXXEN,

  • Presenting, analyzing, managing, developing and personalizing service and promotional initiatives,

  • Identifying the people who will use the service,

  • Developing services and customizing/personalizing of content,

  • Conducting marketing analysis studies and advertising/campaign/promotion processes (these processes can be carried out by various methods such as e-mail, push notifications, text message, online messaging channels and matching descriptive communications),

  • Providing after-sales support services,

  • Conducting contract processes,

  • Following-up the requests and complaints,

  • Has been processed for managing member referrals, processing your membership registration, orders and payments.

Transfer of the Personal Data

The procedures and principles to be applied transferring personal data is regulated by the legislation in force, and the personal data and special categories of data of the related person can be transferred to third parties in the country and/or abroad.

We transfer your personal data to third parties for the following purposes:

With the Revenue Administration to carry out the legal processes, business partners to carry out the financial and accounting processes, with third parties/companies to provide marketing, advertising, communication, security, infrastructure and IT services, to customize, personalize and optimize our service, to provide bank account or balance information, to process credit card transactions or other payment methods, to provide customer service.

Your personal data is transferred abroad since the servers and data centre is located abroad.

Your Rights

  • You can make the following requests regarding your personal data within the scope of applicable law;

Learn whether or not her/his personal data have been processed, request information as to processing if her/his data have been processed; learn the purpose of processing of the personal data and whether data are used in accordance with their purpose; know the third parties in the country or abroad to whom personal data have been transferred; request rectification in case personal data are processed incompletely or inaccurately and request notification under these rectifications to third parties whom personal data have been transferred; request deletion, destruction or anonymization of personal data within the framework when the objective purpose of processing data cease to exist and request notification under these rectifications to third parties whom personal data have been transferred; object to the occurrence of a result against the data owner by analyzing the processed personal data exclusively through automated systems, request compensation for the damages in case the person incurs damages due to unlawful processing of personal data.

  • Your applications and requests regarding your personal data,

EXXEN will fulfil requested claims through the “Data Subject Application Form”.

EXXEN will finalize your application requests free of charge within 30 (thirty) days at the latest according to the nature of the request. In case the request is rejected, the reason or reasons for the rejection will be notified written or electronically with its justification.

This Privacy Policy may be revised by EXXEN when deemed necessary.

In case of revision, amendments will be notified to your behalf. The most up-to-date version of this Privacy Policy can be found at [www.exxen.com].

Technical and Administrative Measures for Security

EXXEN undertakes to take all necessary technical and administrative measures and show due diligence to ensure the confidentiality, integrity and security of your personal data.

EXXEN takes the necessary measures to prevent unauthorized access to personal data, misuse of personal data, unlawful processing, disclosure, alteration or destruction. EXXEN uses well-known and generally accepted security technology standards such as firewalls and Secure Socket Layer (SSL) encryption when processing personal data. In addition, when sending your personal data to EXXEN through the website, mobile application, mobile website and smart TV application, these data are transferred using SSL.

EXXEN, regarding the prevention of unlawful access to the personal data it processes, preventing the unlawful processing of these data and ensuring the protection of personal data:

All areas in the website, mobile application, mobile website and smart TV application where personal data are taken are protected with SSL,

Creates and implements access authorization and control matrices for its employees in order to prevent unlawful processing of personal data collected from the website, mobile application, mobile website and smart TV application,

To ensure that personal data are not accessed illegally; periodically conducts penetration tests and tests the system’s resistance to unauthorized access,

It ensures that personal data in the physical environment are kept in lockers and accessed only by authorized persons,

Personal data processed through cookies belonging to third parties from which the service is obtained is also deleted from the systems of third parties if the membership terminates.

Even though EXXEN had taken the necessary IT measures, in the event that personal data is damaged or seized by unauthorized third parties as a result of attacks on EXXEN-operated platforms or EXXEN systems, EXXEN will immediately give notice to you and the Personal Data Protection Board and take the necessary measures.

Children

You must be 18 years of age or older to subscribe to the EXXEN. In certain jurisdictions, the age of majority may be older than 18; in which case, you must satisfy that age in order to become a member. While individuals under the age of 18 may utilize the service, they may do so only with the involvement, supervision, and approval of a parent or legal guardian.

We are aware of the sensitivity of your children’s personal data, including all our departments and the real and legal persons we cooperate with, and we take the utmost care to protect this data.

It is the responsibility of a parent or legal guardian to share your child’s personal data with us. You can contact us at [kvkkbasvuru@exxen.com] for your child’s personal data.

Changes to This Privacy Policy

We will update this Privacy Policy from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with the law. Your continued use of the EXXEN service after any such updates take effect will constitute acknowledgement and (as applicable) acceptance of those changes.