FINSO PAY PRIVACY POLICY AND CLARIFICATION TEXT
The New Mobile Platform
for
Shopping & Consumer Loans
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Shopping & Consumer Loans
FINSO PAY PRIVACY POLICY AND CLARIFICATION TEXT
1. INTRODUCTION
This information is provided by Finso Finansal Teknoloji Çözümleri Anonim Şirketi (“FİNSO”) as the Data Controller for the automatic and non-automatic recording, processing and transfer of the personal data processed in the provision of our services within the scope of Finso via the Finso Pay – Finso Customer Mobile Application (“Application”), in line with the purposes described below. It consists of informing the data controller within the scope of the provisions of the disclosure obligation, which is regulated in article 10 of the Law on the Protection of Personal Data No. 6698.
2. YOUR PROCESSED PERSONAL DATA, PURPOSE AND LEGAL REASON
| Processes | Processed Personal Data | Purpose and Legal Reason for Processing |
| Creating a User Account | Your personal data in the form of name, surname, ID number information, date of birth, gender information, e-mail address, phone number, password information, verification code information | For the purposes of creating an account for the User to be able to use the Application, for the User to log into the Application, verifying identity and age, and benefiting from the services offered by Finso;
Within the scope of Article 5/2 of the Personal Data Protection Law, the establishment and performance of the contract, the establishment and protection of a right are processed based on legal reasons. |
| Creating a User Account | In the “My Profile” section, date of birth, GSM phone number, e-mail address, personal information (residence address, country, zip code, province, district, marital status, education status) and financial information (job status: not working, retired, housewife, student, public sector paid, private sector paid, self-employed, tradesman, farmer, side income holder, part-time etc. and monthly income amount) | For the purposes of using the authorizations offered in the application by the User, offering alternative payment instruments to the User, receiving application transaction requests for credit, and providing the appropriate credit type and rate;
Within the scope of Article 5/2 of the Personal Data Protection Law, the establishment and performance of the contract, the establishment and protection of a right are processed based on legal reasons. |
| Creating a User Account | Your personal data in the form of electronic documents you upload to the application, document type (payroll, service statement, official documents, etc.), document information, document name, document barcode number | In order for the User to pay for the shopping package and collect the necessary documents in line with their credit needs, and to keep electronic documents that can be verified by e-Government;
In accordance with Article 5/2 of the Personal Data Protection Law, the performance of the contract and the establishment of a right are processed based on legal reasons. |
| Using the App | Your personal data in the form of Device Operating System, Brand, Model, GSM Country, GSM Operator information, IP address | In order for the application to work with the device used by the User, to provide security elements and to keep log records;
Within the scope of Article 5/2 of the Personal Data Protection Law, the establishment and performance of the contract, the establishment and protection of a right are processed based on legal reasons. |
| Using the App | Photos and documents you upload to the app using your camera | If camera access is allowed by the User; In order to take a profile photo of the User and to be used by the User in e-Document QR Code scanning;
Within the scope of Article 5/2 of the Personal Data Protection Law, the establishment and performance of the contract, the establishment and protection of a right are processed based on legal reasons. |
| Cash Loan Application | Your personal data in the form of the reason for the loan request, the loan amount requested, the maturity selection information, the preferred financial institution and loan selection information according to the loan information provided by the contracted financial institutions, and the documents and information you uploaded to the Application system. | For the amount and type of loan requested by the User, in order for you to apply for the cash loan service to be provided by the financial institutions with which we have an agreement on the Application;
In accordance with the provision of Article 5/2 of the Personal Data Protection Law, the establishment and performance of the contract, the establishment and protection of a right are processed based on legal reasons. |
| Marketing, Commercial Electronic Message Sending Processes | Your name, surname, telephone, e-mail, gender, employment status, educational status, income status, your preference information regarding our products and services | To send commercial electronic messages to Users in the form of discounts, advertisements, promotions regarding our other services and products; For the purposes of presenting special offers according to the User’s transactions, creating personalized campaigns, creating advertisements, segmentation, profiling, reporting, marketing and analysis;
Pursuant to Article 5/2 of the Personal Data Protection Law, if you have your explicit consent and electronic commercial message approval, it is processed based on express consent. |
| Shopping Package Processes | Information about your shopping (brand-model etc. product definition, product category, quantity and price information), credit and payment request and credit extension information (continuation of the transaction, approval or rejection status, etc.), information about your cancellation-payment status transactions | stores of vendors integrated with Finso; For the purposes of making use of Finso Services, checking shopping packages and payment status, making necessary checks and confirmations for Finso, and ensuring security;
In accordance with Article 5/2 of the Personal Data Protection Law, the performance of the contract and the establishment of a right are processed based on legal reasons. |
| Finso Support | In the “Written Support” section, “How can we help you?” Your personal data in the form of the information you write in | order to support the User with our written (“chat”) support line, if he/she requests information regarding the problems he/she has experienced or the questions he/she wants to ask;
In accordance with Article 5/2 of the Personal Data Protection Law, the performance of the contract and the establishment of a right are processed based on legal reasons. |
| Finso Service Processes | Customer transaction information (demand information, transaction information), Application transaction (log records), financial information (financial information requested during Finso Services, credit information) together with personal data specified in other categories. | In order for the User to benefit from Finso Services;
Pursuant to the provisions of Article 5/2 of the Personal Data Protection Law, the provisions of the law, the fulfillment of a legal obligation and the performance of a contract are processed based on legal reasons. |
3. YOUR PERSONAL DATA TRANSFERRED, PURPOSE OF TRANSFER, RECIPIENT GROUP AND LEGAL REASON
| Processes | Transferred Personal Data | Receiving Group | Purpose and Legal Reason of Transfer |
| Legal Obligations | Your personal data specified under other categories, personal data processed during Finso Services | Authorized Institutions and Organizations
Courts |
In order to fulfill the obligations of obtaining, notifying and declaring information and documents arising from the laws, and to use our rights when necessary;
In accordance with the provision of Article 5/2 of the Personal Data Protection Law, the provision of the law and the fulfillment of the legal obligation are transferred based on the legal reasons. |
| External Service Procurement Processes | Your personal data specified under other categories, your personal data processed during Finso Services | Our “Suppliers” with whom we have a business relationship and receive service For example; Your personal data, “Lawyers” from whom we receive services in case of a legal dispute, “Financial Advisors” from whom we receive services due to financial obligations, “Auditors” in audit situations, Our Group Companies for the performance of centrally provided services, IT (Information Technologies) Service our providers | For the performance of the contracts, we have made for the provision of necessary external services and only limited to this purpose;
Pursuant to Article 5/2 of the Personal Data Protection Law, data processing is mandatory for the legitimate interests of the data controller, the establishment or performance of a contract, the establishment, exercise or protection of a right, based on legal reasons. |
| Creating a User Account | Your personal data in the form of name, surname, ID number information, date of birth, gender information, e-mail address, phone number, password information, verification code information | If the User requests a loan, financial institutions | For the purposes of creating an account for the User to be able to use the Application, for the User to log into the Application, verifying identity and age, and benefiting from the services offered by Finso;
Within the scope of Article 5/2 of the Personal Data Protection Law, the establishment and performance of the contract, the establishment and protection of a right are processed based on legal reasons. |
| Creating a User Account | In the “My Profile” section, date of birth, GSM phone number, e-mail address, personal information (residence address, country, zip code, province, district, marital status, education status) and financial information (job status: not working, retired, housewife, student, public sector paid, private sector paid, self-employed, tradesman, farmer, side income holder, part-time etc. and monthly income amount) | In case the User requests to pay the shopping or use credit, financial institutions | For the purposes of using the authorizations offered in the application by the User, offering alternative payment instruments to the User, receiving application transaction requests for credit, and providing the appropriate credit type and rate;
Within the scope of Article 5/2 of the Personal Data Protection Law, the establishment and performance of the contract, the establishment and protection of a right are processed based on legal reasons. |
| Creating a User Account | Your personal data in the form of electronic documents you upload to the application, document type (payroll, service statement, official documents, etc.), document information, document name, document barcode number, in the “My Documents” section of the Application, your data regarding the information and documents you have entered in order to keep them by adding electronic documents that can be verified by e-Government | If the documents are deemed necessary for the loan application, the financial institutions to which the loan request is directed | In order for the User to pay the shopping package and collect the necessary documents in line with their credit needs;
In accordance with Article 5/2 of the Personal Data Protection Law, the performance of the contract and the establishment of a right are processed based on legal reasons. |
| Using the App | Your personal data in the form of Device Operating System, Brand, Model, GSM Country, GSM Operator information, IP address | Mobile Application Service Provider | In order for the application to work with the device used by the User, to provide security elements and to keep log records;
Within the scope of Article 5/2 of the Personal Data Protection Law, the establishment and performance of the contract, the establishment and protection of a right are processed based on legal reasons. |
| Using the App | Photos and documents you upload to the app using your camera | If the documents are deemed necessary for the loan application, the financial institutions to which the loan request is directed | If camera access is allowed by the User; In order to take a profile photo of the User and to be used by the User in e-Document QR Code scanning;
Within the scope of Article 5/2 of the Personal Data Protection Law, the establishment and performance of the contract, the establishment and protection of a right are processed based on legal reasons. |
| Cash Loan Application | Your personal data in the form of the reason for the loan request, the loan amount requested, the maturity selection information, the preferred financial institution and loan selection information according to the loan information provided by the contracted financial institutions, the documents and information you have uploaded to the application system | If deemed necessary for the loan application, the financial institutions to which the loan request is directed | For the amount and type of loan requested by the User, in order for you to apply for the cash loan service to be provided by the financial institutions with which we have an agreement on the Application;
Pursuant to Article 5/2 of the Personal Data Protection Law, the establishment and performance of the contract, the establishment and protection of a right are shared with the financial institutions with which we have a contract based on legal reasons, limited to the necessary purpose. |
| Commercial Electronic Message Sending Processes | Your name, surname, telephone, e-mail address, gender, employment status, educational status, income status, and your preference information regarding our products and services | Domestic and international service providers that receive services for marketing, advertising, campaigns and sending commercial messages, İleti Yönetim Sistemleri A.Ş. and İleti Yönetim Sistemi (Message Management System) authorized business partner | To send commercial electronic messages to Users in the form of discounts, advertisements, promotions regarding our other services and products; for the purposes of presenting special offers according to the User’s actions, creating personalized campaigns, creating advertisements, segmentation, profiling, reporting, marketing and analysis;
Pursuant to Article 5/2 of the Personal Data Protection Law, if you have your explicit consent and electronic commercial message approval, it is processed based on express consent. |
| Shopping Package Processes | Information about your shopping (brand-model etc. product information, product category, quantity and price information), credit payment request and credit extension information (continuation of the transaction, approval or rejection status, etc.), cancellation-payment status information | Vendors and financial institutions defined in the system | In case the User makes purchases from online and physical stores of vendors integrated with Finso; For the purposes of making use of Finso Services, checking shopping packages and payment status, making necessary checks and confirmations for Finso, and ensuring security;
In accordance with Article 5/2 of the Personal Data Protection Law, the performance of the contract and the establishment of a right are processed based on legal reasons. |
| International Transfer | Since we use e-mail service that has servers abroad, your personal data processed while using this service | Data processors and service providers located abroad | In order to perform the relevant services, it is transferred based on your express consent in accordance with Article 9 of the Personal Data Protection Law. |
4. METHOD OF COLLECTION OF PERSONAL DATA
Your personal data is collected in the following ways:
5. KİŞİSEL VERİLERİN SAKLANMASI VE İMHASI
Your personal data is stored and destroyed within the scope of the Personal Data Retention and Disposal Policy. Please click this link to access the Personal Data Retention and Disposal Policy.
6. YOUR RIGHTS
To the extent that your data is processed by Finso and Finso processes your data as a data controller, you have the following rights in accordance with Article 11 of the Personal Data Protection Law No. 6698:
“Learning whether any of your personal data is processed; requesting information regarding processing activities; learning the purposes of processing; learning these persons if they have been transferred to third parties in the country or abroad; requesting their correction if they are incomplete or incorrectly processed; requesting the deletion or destruction of personal data in the event that the reasons for the processing disappear or Finso does not have a legal basis or legitimate interest to process the said data; Requesting Finso to ensure that third parties, also authorized by Finso, who process personal data respect your rights under this section; Objecting to adverse results that may arise as a result of processing personal data through automated systems, and; To request compensation for this damage in case you suffer damage due to unlawful processing.”
7. APPLICATION TO DATA CONTROLLER
You can submit your requests within the scope of Article 11 of the Law, which regulates the rights of the person concerned, in writing, in accordance with the “Notification on the Procedures and Principles of Application to the Data Controller”, or by using a registered e-mail (KEP) address, secure electronic signature, mobile signature, or any of the items previously notified by you and registered in our system. You can send it using your e-mail address.
8. DATA CONTROLLER INFORMATION
Title of the Data Controller
Mersis Number
E-Mail Address
Registered E-Mail Address
Physical Mail Address
Finso Finansal Teknoloji Çözümleri A.Ş.
0388143442200001
info@finso.com.tr
finsoteknoloji@fhs05.kep.tr
Küçükbakkalköy Mahallesi Kayışdağı Caddesi Allianz Plaza Sitesi No: 1 İç Kapı No: 108 Kat:29 Ataşehir-İstanbul, Türkiye
