PRIVACY POLICY

As Stablex Bilişim Teknoloji A.Ş. (“Stablex”), it is among our priorities to protect the personal data of our customers or third parties who use any of our web services and digital resources, and to create transparency and mutual trust in these matters.

In case that you use our web address www.stablex.net or its extensions, including but not limited to our social media pages and / or digital channels, using our services and products or using our support services, or visiting Stablex through our online and digital channels, your personal data that you electronically share with us, will be used to ensure fulfillment, and then to provide you with a better service. 

You can access your rights regarding the recording of your personal data, the purposes of processing, the legal basis of the processing of the data and your personal data from the Clarification Text and Cookie Policy prepared for this purpose.

When the storage periods stipulated in the relevant legislation or required by the processing purpose expire, Stablex deletes the personal data it processes by using one or more techniques that are most suitable for business processes and activities, within the 6-month period stipulated for periodic destruction; or continue to use it by anonymizing it, among the deletion and anonymization methods specified in the guide on Deletion, Destruction or Anonymization of Personal Data published by the Personal Data Protection Board. 

ARTICLE 1- PARTIES

This Personal Data Protection Policy is the annex and integral part of the currently in effect User Agreement (‘Agreement’) between Stablex Bilişim Teknoloji A.Ş. and you the User. This Policy is linked to and valid with the Agreement. 

Within the scope of this Policy, Stablex Bilişim Teknoloji A.Ş. and User; will be referred to as the parties.

ARTICLE 2- SUBJECT

In accordance with the provisions of the Law on the Protection of Personal Data No.6698 (‘KVKK’), all kinds of information that makes the user’s identity specific or identifiable, especially the identity information of the user, including the personal data of special nature, will be processed by Stablex as Personal Data, as Data Controller. 

Stablex pays the utmost attention to the security of personal data belonging to the User, taking all precautions for the protection of personal data belonging to the User, and prioritizes the protection and safe processing of personal data in all services offered to the User through the Site. In the same context, Stablex aims to protect the privacy, fundamental rights and freedoms of the User.

ARTICLE 3- DEFINITIONS

Explicit Consent: Consent about a specific subject based on information and expressed in free will.

Processing of Personal Data:  It refers to all kinds of transactions performed on the data such as obtaining, saving, storing, preserving, changing, rearranging, disclosure, transfer, taking over, making available, classifying or preventing the use of such data by Stablex through the Site. 

Personal Data Owner: Real person whose personal data is processed.

Personal Data: All kinds of information regarding an identified or identifiable natural person.

Special Quality Personal Data: Data on race, ethnicity, political opinion, philosophical belief, religion, sect or other beliefs, dress code, membership of associations, foundations or trade unions, health, sexual life, criminal conviction and security measures, and biometric and genetic data are data of special quality.

Data Supervisor:  The person who determines the purposes and means of processing personal data and manages the place where the data is kept systematically (data recording system) is the data controller. 

Data Processor: Real and legal person who processes personal data on behalf of the data controller based on the authority given by him/her.

Data Recording System: Recording system in which personal data is processed by structuring according to certain criteria

Law:  Personal Data Protection Law No. 6698. 

Anonymizing:  Making the data previously associated with a person unrelated to an identified or identifiable real person under any circumstances, even by matching with other data. 

ARTICLE 4- ISSUES ON THE POLICY OF THE PROCESSING OF PERSONAL DATA

I) General Principles in Processing Personal DataStablex, within the sco

pe of Constitution of Turkey, Personal Data Protection Act processing and protecting the personal data of Users. 

In this context, Stablex acts in line with the following principles:

Stablex;

•As a prudent merchant, it acts in accordance with the principles introduced by legal regulations and the general rule of trust and honesty in the processing of personal data,

•It ensures that the personal data it processes are accurate and up-to-date, taking into account the fundamental rights of personal data owners and their own legitimate interests within the scope of the Law on the Protection of Personal Data together with other laws that it has to comply with within the scope of its activities,

•Our company clearly and accurately determines the legitimate and lawful personal data processing purpose. In this context, personal data are presented or processed limited to the services to be provided and legal obligations. The purpose for which personal data will be processed by our company is determined before the personal data processing activity begins.

•Our company processes personal data in a way to achieve the identified purposes and avoids the processing of personal data that is not required or not related to the realization of the purpose.

•Our company maintains personal data only for the time required by the relevant legislation or for the purpose for which it was processed.

II) Terms Of Processing Personal Data

Stablex, processes the personal data only in cases stipulated by law or with the express consent of the person in accordance with the Constitution; 

The explicit consent of the personal data owner is only one of the legal bases that make it possible to process personal data in accordance with the law. The basis of the personal data processing activity can be only one of the conditions stated below, and more than one of these conditions can also be the basis of the same personal data processing activity.

One of the conditions for processing personal data is the explicit consent of the owner. The explicit consent of the personal data subject should be disclosed on a specific subject, based on information and free will. 

Everyone who is a member of the site declares and undertakes that they have read the user agreement and the information regarding the processing of personal data and accepted in advance. In this context, all objection, lawsuit and complaint rights regarding processing of personal data are deemed to have been waived in advance.

The personal data of the data owner may be processed if it is necessary to process the personal data of the person who is unable to disclose his/her consent due to the actual impossibility or whose consent cannot be validated, or to protect the life or body integrity of another person.

In case of the fact that it is required to process personal data of the parties to the contract, provided that the processing is directly related to the conclusion or fulfilment of that contract.

If the personal data is made public by the data owner himself/herself, the relevant personal data can be processed. 

If it is necessary to process data for the establishment, use or protection of a right, the personal data of the data owner may be processed.

In Article 6 of the Law on the Protection of Personal Data, some personal data that have the risk of causing victimization or discrimination when unlawfully processed are defined as ‘special quality’. 

Stablex acts in accordance with the regulations stipulated in the Personal Data Protection Law in the processing of personal data determined as ‘special quality’ by the Law on Protection of Personal Data. 

By Stablex, in accordance with the Personal Data Protection Law; Special quality personal data are processed in the following situations, provided that adequate measures are taken by the Personal Data Protection Board:

If the personal data owner has explicit consent or the personal data owner does not have explicit consent; Special quality personal data other than the health and sexual life of the personal data owner, in cases stipulated by the law, special quality personal data related to the health and sexual life of the personal data owner can be processed by persons under confidentiality obligation or authorized institutions and organizations for the purpose of financing planning of health services and management, to protect public health, preventive medicine, medical diagnosis, treatment and care services.

Although it has been processed in accordance with the provisions of the Personal Data Protection Law and other relevant laws, if the reasons for its processing disappear, the personal data are deleted, destroyed or anonymized by the data controller ex officio or upon the request of the person concerned.

When the storage periods stipulated in the relevant legislation or required by the processing purpose expire, Stablex within the 6-month period stipulated for periodic destruction; deletes the personal data it processes by using one or more techniques that are most suitable among the deletion and anonymization methods specified in the guide on Deletion, Destruction or Anonymization of Personal Data published by the Personal Data Protection Board for business processes and activities, or continue to use it by anonymizing it. 

ARTICLE 5- OBLIGATION OF CLARIFICATION 

Article 20 of the Constitution reveals that everyone has the right to be informed about their personal data. Accordingly, in Article 11 of the Personal Data Protection Law, ‘requesting information’ is among the rights of the personal data owner. 

In this context, Stablex provides the necessary information when the personal data owner requests information in accordance with the Constitution and Personal Data Protection Law. 

Stablex also, in accordance with Article 10 of the Personal Data Protection Law, informs personal data owners during the acquisition of personal data, the purpose for which personal data will be processed during the acquisition of personal data, to whom and for what purpose the processed personal data can be transferred, the method and the legal reason of collecting personal data and about the rights the data subject has within the scope of Article 11 of the Personal Data Protection Law. Each User who accepts the User Agreement on the Site and is a member of the Site accepts that this clarification is provided to them. 

In addition, Stablex provides information and transparency in personal data processing activities by announcing to personal data owners and those concerned that it is engaged in personal data processing activities in accordance with all the issues in the Personal Data Protection Law and ‘the rule of law and honesty’, with various public documents, especially with this Policy.

ARTICLE 6- PROCESSING THE USER’S PERSONAL DATA

Although it may vary depending on the service provided by Stablex and the commercial activities of Stablex Your personal data in order to be used in all kinds of services to be offered to the User regarding crypto money trading transactions carried out on the site, to determine the identity of the User correctly and in the way it is included in the legislation, and to prevent all kinds of illegal money movements and can be collected and presented in verbal, written, or electronic environment through Stablex's business units, website, call centre, phone calls, SMS records, e-mail addresses, social media channels, mobile applications, and similar means, automatically or non-automatically and it will continue to be updated during the time you use the products and services and / or within the legal periods.

Your collected personal data are processed with the explicit consent of the data owner within the scope and purposes of personal data processing specified in the Laws for the fulfillment of legal and administrative obligations, the establishment and performance of your contracts with Stablex, establishment and execution of contracts with Stablex, to be used in the products and services you purchased / will receive from Stablex, to communicate about the product and service you received / will receive, and to provide an effective user service so that it can be used in marketing activities, if you have given your consent in this regard, product / service offer, modeling, reporting, scoring, risk monitoring, intelligence, current or new product studies and potential user detection, ensuring the legal and commercial security of Stablex, determining and implementing Stablex’s business strategies, ensuring and developing coordination, cooperation and efficiency in and between units within Stablex, resolving existing and future legal disputes, answering requests and questions from our users, ensuring the security of Stablex's website and other electronic systems and physical environments, Explicit consent of the data subject in accordance with Article 5 of the Personal Data Protection Law 6698 to fulfil our legitimate interests, such as investigating, detecting, preventing, and reporting violations of the contract and the law to the relevant administrative or judicial authorities in order to carry out our activities we offer you by reporting changes in legislation or in the rules and policies accepted by Stablex or making other notifications that concern you, for it is necessary to process personal data of the parties to the contract Provided that it is clearly stipulated in the laws, is obligatory for the protection of the life or physical integrity of the person or someone else who is unable to explain his consent due to actual impossibility or whose consent is not legally valid, provided that it is directly related to the establishment or execution of the contract with Stablex,  It is mandatory for Stablex to fulfill its legal obligation, it is made public by you personally, data processing is mandatory for the establishment, exercise or protection of a right, data processing is mandatory for the legitimate interests of Stablex, provided that it does not harm your fundamental rights and freedoms, and Pursuant to Article 6, with the explicit consent of the data owner.

ARTICLE 7- TRANSFER OF USER’S PERSONAL DATA

Personal data of Users with Stablex for the purposes listed above are securely stored.  And to third parties outside the legal framework.  Stablex, to obtain personal data such as individuals, institutions and / or organizations required / permitted by the current legislation, business partners, all authorities and channels required for the execution of the User Agreement, Courts, Public Prosecution Offices, BRSA, CMB, MASAK(Financial Crimes Investigation Board), BKM( Interbank Card Center) to authorized public entities, authorities, domestic / foreign affiliates; to companies operating as an intermediary / agency, to third parties that have received and provided services to carry out the activities of the Site, to the program partner institutions, organizations, domestic / foreign banks, funds, cooperated organizations, will be able to transfer user personal data to domestic / international / international organizations from which service / support / consultancy is obtained or which is a project / program / financing partner and independent audit and support services due to legal obligations only within the framework of legal restrictions.

ARTICLE 8- RIGHTS OF THE DATA OWNER USER

By applying to Stablex, the users have right; 

1.To find out whether their personal data are processed or not, 

2.Requesting information regarding the personal data if they are processed, 

3.To learn the purpose of data processing and whether this data is used for the intended purposes, 

4.Knowing the third parties to whom your personal data has been transferred inside or outside the country, 

5.Requesting correction in case it's incomplete or incorrectly processed, 

6.Requesting the erasure or destruction of their personal data under the conditions laid down in Article 7 of the Personal Data Protection Law, 

7.Requesting notification of the operations carried out in compliance with subparagraphs (5) and (6) to third parties to whom his personal data has been transferred, 

8.To object to the emergence of a result against the user because it is analyzed exclusively by automated systems, 

9.To demand the compensation of the damage in case of damage due to unlawful processing.

At the same time, with the use of the Site, the user also declares that they accept the provisions of the above paragraph, are informed about these issues, and especially they have read and understood the regulations in Articles 5 and 6 of the Law No. 6698, declares, accepts and undertakes that they give ‘express consent’.

ARTICLE 9- FINAL PROVISIONS

In case of inconsistency between the provisions of the Personal Data Protection Law and other relevant legislation and this Policy, the provisions of the Personal Data Protection Law and other relevant legislation will be applied first.

Stablex may change the content of this Policy at any time it deems necessary. The Current Policy will enter into force on the date it is published on the Site. In case of any dispute, Stablex records are valid and binding on their own.