Piri Privacy Policy
Last Updated: 31.10.2023
Hello and Welcome to our Privacy Policy!
This Privacy Policy of Piri Yazılım Mühendislik ve Ticaret A.Ş. (We will call it “Piri”, “We” or
“Us” in the text from now on) a company incorporated under Turkish Laws with its
registered address at Maslak Mh. Maslak Meydan Sk. Veko Giz Plaza No: 3/85 Sariyer /
İstanbul, Turkey aims to inform you on the processing of and the choices you have with
respect to the information you share with us via Piri Guide Mobile App or any other ways
(e.g. visiting our webpage or contacting us through e-mail). Therefore, we advise you to
read it thoroughly.
You need to approve the Piri Terms of Use and Piri Privacy Policy before you can start using
the Piri Guide Mobile App. If you do not agree to the terms in this Privacy Policy, you should
not use any services provided by us, including the Mobile App and our website. If you want
to contact Piri, but on the condition that your information is not used for the purposes
explained below, you need to state that in your communication with us.
1. Introduction and Basics
This Privacy Policy includes information on the principles we adhere to and our practices
regarding privacy of your personal information that we collect and process. Information
that is not considered personal data, falls outside the scope of this Privacy Policy.
We may update this Privacy Policy from time to time, for instance when we start providing
new services or when changes in regulations oblige us to provide you with new information.
Updates are binding from the update date onwards. Therefore, we recommend you to visit
this page regularly and get most up-to-date information on the policy applied to your
personal information.
Data Controller for the information you provide to Piri is Piri Yazılım Mühendislik ve Ticaret
A.Ş. So you should direct your requests to our e-mail address (hello@piriguide.com) or
our physical address which can be found at the bottom end of this Privacy Policy.
As stated in our Terms of Use, Piri Guide Mobile App and all other services we provide are
directed at persons older than 18 years. If you are younger, you may use our services only
via your parent or legal guardian and under their supervision. If you provide us with any
information about children, you guarantee that you have the permission of their parent or
legal guardian to do so.
Purpose of this privacy policy is:
• To explain, in the most transparent and readable way possible, our ways and
purposes of using the data we collect for creating a better mobile app and
providing a better experience for you;
• To clarify the types of information we collect upon your permission and the
purposes and methods for processing of them;
• To inform you on the third parties we transfer this information to as well as our
purpose and method in doing so
;
• To let you know your legal rights with respect to your personal data;
• To describe the extent of our responsibility for protection of your rights
and
privacy.
2. General Principles
We will always act in compliance with applicable regulations and respect your personal
rights to the greatest extent.
We want you to know that we will always adhere to the following principles as a result of
the caution and respect we have for your personal information:
• We will act lawfully and fairly and we will be transparent about our processing
activities.
• We will take necessary steps to ensure that your information is accurate, and when
necessary, up to date.
• We will process your information for specified, explicit and legitimate purposes and
only as long as we need to process them. We will not use your information for any
purpose incompatible with those original purposes.
• We will only process information that is adequate, relevant and limited with our
purposes. Which means we will not request from you any information we do not
need and we will dispose of any information that becomes irrelevant.
• We will ensure safety of your personal information and take necessary measures to
protect it against unlawful access, damage, and destruction.
In the following parts of this Policy, you may find detailed information on how we will apply
these principles in practice.
3. What Information We Collect
We collect following information through the Piri Guide Mobile App and other ways you
share information with us:
• Information you give to us by yourself while registering to our Mobile App or while
using or contacting Piri, such as your name, birthdate, telephone number and e-
mail address, some of which may identify you personally.
• Information we generate or obtain during your use of Piri Guide Mobile App, our
website or other services we provide. Examples to this include your IP Address
and location, the advertisement ID assigned to your device by our partnered
advertisement service providers, audial tours that you purchase and use;
information relating to the browser and device you are using, other information
necessary to identify your device, account information for the platform you use
(e.g. IOS App Store or Google Play Store) to download the App and to purchase
the in-app content; technical information of the device you use, your language
preferences, information collected from your device’s sensors and receptors such
as your momentum, direction etc. and your interactions with our services such as
the tours and webpages you have viewed.
• We may also match the information gathered from our third-party business
partners with your user profile. An example of this is the information transmitted
by Facebook to us when you register with Facebook. When you use apps or
websites that we have partnerships (direct or indirect) with, information related
to your use of such webpages may be transmitted to us.
If you fail to give information to us, or in case you mislead us with the information you
give, you may be unable to use our services.
When your information changes, you can update most fields through the settings section
of our App. If you want to change information that cannot be accessed this way, you may
always contact us on hell[email protected] .
4. Why We Use Your Information
We use the collected information for following purposes, each with some examples in
following paragraph, but our use is not limited to those examples and may include similar
other uses:
• To facilitate your use of our App and listening of the audial tours.
For instance, when you download a tour, we understand which point in the tour’s
route you are at and give you the information about that part of the tour, thanks to
your location information.
• To let you utilize your user account.
We match your purchased tours with your user account so that when you change
your device, you can listen to them in your new device by logging in to your account.
• To recognize and help you with our customer support.
When you contact us for a problem you are facing in the app, we may use the
technical information we have about your device to understand the underlying
reason and to find a possible solution.
• To provide better services.
By following your interactions with our app, we can keep track of which tours are
most used and ensure that the new tours we provide are interesting for all of our
users.
• To contact you when needed.
When there is an issue related to a payment you make, we may contact you to
resolve it. Or when you contact us through different channels, we record those
communications so we can look into the issue and respond to you.
• Advertisement and Marketing.
Thanks to the information we have, we can create exclusive promotions for you and
let you know. Besides we can show you personalized advertisements based on
information that we and/or our partnered advertisement service providers have
obtained. Additionally, we can offer benefits for recommending us to your friends
and then we use the information of you and your friend to validate such benefits.
We do not send marketing material unless we have your prior approval. If you have
given approval, we can send you promotional bulletins related to Piri and other
services that we think may be of interest to you. If you do not wish to receive those
bulletins anymore, you can follow the instructions within them or you may send a
message to hello@piriguide.com explaining your request. Please include your e-
mail address and/or phone number in your message so that we can know to which
contact details we should not send promotions any more.
• To ensure the safety and security of our services.
We may need to make various controls and examinations on your personal
information to prevent unlawful and fraudulent transactions. These procedures may
include automatic algorithms as well as human effort under set rules. If you learn
that a transaction you make has been rejected as a result of those procedures, you
may contact us via e-mail on hello@piriguide.com to object that result.
• Other instances based on your request.
When we allow you to interact with other users or review our tours, we need to use
your information to facilitate your interactions and to publish your reviews.
• To meet our legal obligations and to resolve disputes.
Some legal regulations bring rules governing our use of your information. For
instance, the Law No. 5651 on Regulation of Publications on The Internet and
Combating Crimes Committed by Means of Such Publication requires us to keep
logs for your access to our app and website. Other regulations in various fields such
as tax and commerce may also require us to retain information relating to our
operations (which may include your information).
Also when there is a legal dispute, we may review the information we hold and
serve it to courts and other authorities.
5. Our Legal Basis for Processing Your Information
• We may need to process your personal data for performance of the contracts
executed between you and us when you start using our App or other services and
then when you download audial tours.
• We may use your personal data for our legitimate interests unless such use is
against your interests in a way overriding our legitimate interest. For instance, we
may use the information about your past transactions for giving you the means to
review your activity log as well as to make statistical research which help us improve
our services.
• We may rely on your consent for purposes such as sending you marketing material
and obtaining your opinion in voluntary surveys. In those cases, you can always
withdraw your consent by sending a notification by e-mail to [email protected]
or to our physical address at the end of this Policy. You should include information
that enable us to recognize you in that notification. Your notification of withdrawal
of your consent will be effective in the future and therefore will not make our prior
processing unlawful but it will make us cease to process those information from the
receipt of your notification onwards.
6. Cookies and Tracking Mechanisms
When you use our App or website, we or our business partners may place cookies (small
text files) to gather information on your use and to utilize the information for providing our
functions, managing our infrastructure and marketing. If your wish is not to accept those
cookies, you may change the settings of your browser to reflect that. Cookies stored on
your local drive are expired after a certain period of time and you can delete them any
time through respective settings of your browser. But your refusal of cookies may hinder
with your use of our website and other services.
This website uses a web analytics tool named Google Analytics developed by Google Inc.
(“Google”) Google Analytics utilizes cookies and other identifiers to help website owners
analyze the use of their website by their visitors and for rendering of the services
provided by Google. Information related to your use of the website may be transferred to
Google’s servers located in various countries and be processed by Google at those
locations. Google shall use this information for analyzing your use of web, drafting
reports on the use of website for website owners and providing other services related to
internet use (e.g. creating user segmentations). Google may transfer this information to
third persons upon legal obligations and/ when third persons process this information on
behalf of Google. If you do not want your information to be used for Google Analytics,
you may use the following link to opt-out: https://tools.google.com/dlpage/gaoptout/
7. Transfer of Information to Third Parties
We make use of third party service providers that help us with providing better services.
Our use of those third-party service providers sometimes requires us to share some
information with them. But in any case, we will keep being responsible for safety of your
personal data and inform you on those transfers, whenever it is feasible to do so. Besides,
we will never sell your information to any third party that uses them for purposes
incompatible with those we state here.
We utilize some third-party services and software such as Fabric, Mapbox, Google,
Amplitude, Branch, Admob, Adjust and Netmera to provide some features (such as maps
and advertisements) within our App. We may transmit some information about your
registration as well as your device model, software, viewed area, location, user behavior
and habits to these providers for them to help with developing and providing our services.
We take necessary guarantees from them to protect your information and to use it for
specified purposes only. They may transfer your information when they are using another
third party service provider (subject to the same guarantees) or in other lawful cases.
You may purchase the digital content within the Piri Guide Mobile App via App Store or
Google Play Store, depending on the device you are using. In those cases, you give your
payment details including credit card and billing information to the respective store and we
have no access to those. Yet Piri may transfer to the respective store a limited portion of
information such as the name of the content you purchase to facilitate the payments and
those platforms may match this information with the user account you use there which
enables you to use your content on any device you use with the same store account.
Responsibility for the information held by the respective store belongs to you and the
operators of those stores only. We recommend you to view their privacy policies for more
guidance on these subjects.
We can charge you through your mobile carrier for the digital content within our app if you
use the carrier(s) we are associated with. In those cases, we may transfer your phone
number, name and surname as well as other information related to your account and
purchase to the respective carrier for facilitation of the payments to our associated mobile
carrier.
When we accept credit card payments or other methods that may be of use to you, we
transfer your payment information as well as some account information to our payment
service providers for realizing the payments and prevention of fraudulent transactions.
We often collaborate with third-party business partners to provide discounts and free
content to you. In those cases we may transfer the information that you need to provide
in order to utilize the promotion as well as some of your account information to those third
parties for enabling you to benefit from the promotion and to prevent fraudulent
participations and misuse.
Law enforcement agents and other authorities may request information from us. We will
share your information only when there is a legal obligation to do so; or when it is
necessary to prevent and/or prosecute a crime and all those transfers will be lawful at all
times.
8. Transfers to Third Countries
By approving this Privacy Policy, you agree to international transfer of your personal data.
Our Information Technology infrastructure and servers are located within different
countries including Turkey and those within the European Union. You should know that
these countries where we transfer your personal data may include those not designated as
providing adequate legal safeguards for protection of personal data by European
Commission, e.g. Turkey. Also, some of the third parties stipulated above may be located
in various countries. We guarantee that your personal data is only transferred to countries
regarded to be providing adequate safeguards or to parties that guarantee to ensure the
safety of your personal information.
In case you do not approve those international transfers, you should stop using our App
as well as other services we provide and you should request erasure of your information
by sending an e-mail to hello@piriguide.com .
9. Data Retention
We keep your personal data only for a reasonable amount of time that allows us to provide
our services and meet legal requirements. Some information including your e-mail address,
name and purchase history are retained for the time period your user account remains
active. After your account has been deactivated, we keep retaining those information to
meet legal requirements and to keep statistics which help us improve our services. The
period we keep the information such as usage statistics and interactions with the App may
be shorter. These periods always overlap with the amount of time that the information
remains relevant and reasonably up-to-date and may vary from one category of
information to another. After those retention periods, we delete or anonymize your
personal information so that they can no longer be associated with you. To request erasure
of your information before the retention periods end and to request more information about
10. Information Security
In line with the personal data protection rules of both European Union and Turkey, we take
reasonable measures to prevent unauthorized access to and unlawful use of personal data.
We give priority to privacy and protection of personal data from the beginning until the
end of our business processes and we provide you privacy-enhancing options as default.
The measures we take for protecting the personal information you give us includes both
technical and physical restrictions. Only authorized and duly trained personnel can access
your personal information and even their access is limited to the extent that they need it
to do their job.
In case a data breach occurs despite all our efforts to prevent it, we will fulfil our obligation
to inform you and relevant supervisory authorities about any breached information.
11. Your Rights
We want you to know that in line with regulations governing personal data you have
following rights :
(a) To learn: if we process your personal data, the types of data we process, sources
we get your personal data from, third parties we transfer your personal data to
within the country or internationally, the period for which we keep the personal data
or how we determine that period;
(b) To access your personal data and to request the data provided by you to be given
to you or another data controller in a structured, commonly used and machine
readable format,
(c) To learn the purposes for which your personal data is processed and to query if they
are used in a compatible manner with those purposes,
(d) To object to and request restriction of processing of your personal data,
(e) To request rectification of inaccurate and incomplete personal data about you,
(f) To request erasure of your personal data when there is no legal basis for further
processing,
(g) To request notification of procedures such as erasure and rectification to other third
parties to whom your personal data has been transferred,
(h) To object to any negative consequences arising from automatic analysis of your
personal data,
(i) To request indemnification for any damages arising from unlawful processing of
your personal data.
You can these rights by sending an e-mail to [email protected] or by sending a letter to
our physical address at the end of this Policy. Your application should include the
information you have given to us while registering or making use of our services.
12. Your Right to Complain - Applicable Law and Competent Courts
You can send your requests to our physical address below or e-mail us at
[email protected] for issues related to this Privacy Policy. We will notify you of the result
of your request within a reasonable period and at the latest within 30 days. Unless your
request has been caused by our unlawful act and when it creates an extra burden for us,
we may ask for a reasonable fee to be paid for completion of your request. If you are not
satisfied with the result of your application, you can lodge a complaint before the Personal
Data Protection Board of Turkey.
Additionally, you can use your right to request indemnification as stated in the article 12/I
above, in Istanbul Central Courts of The Republic of Turkey.
Laws of The Republic of Turkey shall apply, to the greatest extent permitted by law, to
your relationship with Piri and the issues included in this Privacy Policy.
* * *
Information About The Data Controller
Trade Name : Piri Yazılım Mühendislik ve Ticaret A.Ş.
Address : Maslak Mh. Maslak Meydan Sk. Veko Giz Plaza No: 3/85
Sarıyer / İstanbul - Türkiye
Trade Registry/
Registration # : İstanbul Trade Registry / 127721-5
MERSIS #
(Central Registry) : 0730056948000001
Tax Office : Maslak Tax Office
Tax ID # : 730 056 9480
Website : http://www.piriguide.com
