INFORMATION TEXT REGARDING THE PROCESSING OF PERSONAL DATA

IDENTITY OF THE DATA CONTROLLER

As the Data Controller within the scope of the Personal Data Protection Law No. 6698, we, Two Ltd Şti, registered with Istanbul Trade Registry Office with trade registry number 612540-0, would like to inform you about the personal data we process.

Our aim is to inform you about the ways your personal data is collected, the purposes of processing, the legal reasons, the transfer to third parties in cases permitted by legislation, and your rights.

According to Article 3 of the Personal Data Protection Law No. 6698, personal data refers to any information relating to an identified or identifiable real person. Tvrads carries out personal data processing activities by taking necessary security measures, primarily for the protection of privacy and fundamental rights and freedoms.

Your personal data may be processed within the framework of our obligations arising from all legal regulations, primarily the KVKK, in order to provide the best service to Tvrads customers, in line with the purposes specified below.

PROCESSING OF PERSONAL DATA AND PURPOSES OF PROCESSING

The identity, email address, contact information, and visual and audio recording data you will share directly or indirectly with us through Tvrads are processed by us for the following purposes:

To enable the user to use the product

To ensure uninterrupted product usage

For the establishment and execution of contracts

For integration with third parties and conducting post-integration operations

METHODS AND LEGAL REASONS FOR COLLECTING PERSONAL DATA

Your personal data is processed based on the following legal reasons specified in Article 5 of Law No. 6698, and your explicit consent is requested if the need to process personal data arises outside these legal reasons:

It is expressly provided for by the laws,

It is directly related to the establishment or performance of a contract,

It is necessary for the data controller to fulfill its legal obligation,

It is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject,

It is necessary for the establishment, exercise, or protection of a right.

YOUR RIGHTS REGARDING THE PROTECTION OF PERSONAL DATA

Within the scope of Article 11 of the Personal Data Protection Law No. 6698, which regulates the rights of the data subject, everyone has the following rights:

To learn whether personal data is processed or not,

To request information if personal data is processed,

To learn the purpose of processing personal data and whether they are used in accordance with its purpose,

To know the third parties to whom personal data is transferred domestically or abroad,

To request the correction of personal data if it is incomplete or incorrectly processed and to request notification of the operations carried out within this scope to third parties to whom personal data is transferred,

To request the deletion or destruction of personal data and to request notification of the operations carried out within this scope to third parties to whom personal data is transferred,

To object to the emergence of a result against the person himself/herself by analyzing the processed data exclusively through automated systems,

To demand compensation for the damage in case of damage due to the unlawful processing of personal data.

You can submit your requests within this scope via the application form on our website and the methods specified in the application form.

DEASU USER AGREEMENT and TERMS OF USE

Tvrads User Agreement

• This agreement is made between Two Productions Ltd. Sti located at Küçükçamlıca Mahallesi Bulgurlu Caddesi No: 84 Istanbul / TURKEY (hereinafter referred to as Tvrads) and individuals and legal entities who receive services under this agreement via the website Tvrads.com, entering their title and contact information and making electronic payments.
• Tvrads.com has adopted various principles for the security of individual/corporate information and data to protect the privacy of its users and members, whether individual or corporate, and to ensure they can benefit maximally from all technological services. These privacy principles have been established and declared to be applied to data collection and/or usage on Tvrads.com, all internet sites connected to Tvrads.com, all mobile applications, and all sub-services.
• By visiting Tvrads.com and its affiliated internet sites and/or using its mobile applications and/or becoming a registered member, all these principles are deemed accepted by the User. Tvrads.com reserves the right to make corrections and updates in the “Privacy Notice” section at any time without prior notice, based on feedback received from the contact addresses specified on the communication pages of its affiliated internet sites.
• Tvrads.com will not disclose any individual/corporate information and data transmitted to it electronically by users through Tvrads.com and its affiliated internet sites and/or mobile applications to third parties. Tvrads.com may send newsletters with permission, perform marketing activities with permission, and collect statistical data from these communication activities by various means and methods, as regulated by Turkish laws, via email, SMS, or phone communication activities. Tvrads.com declares and undertakes not to engage in communication activities without the user’s consent, not to market without permission, and to provide tools for the user to exit the system easily and for free. Tvrads.com will not share, sell, or permit the use of individual/corporate data and information provided to it with third parties outside the purposes explained above.
• In the event of possible system issues on Tvrads.com and its affiliated internet sites and/or mobile applications, Tvrads.com may record users’ IP addresses, other communication information, and registered information on social network accounts, and use these records for the aforementioned purposes. These data/information can also be used to generally identify users and create comprehensive demographic data. Tvrads.com’s obligation to store traffic data as stated in Law No. 5651 and related regulations remains.
• Tvrads.com may provide links (connections) to other sites and/or mobile applications within its affiliated internet sites and/or mobile applications. It may publish advertisements, application forms, announcements, and surveys of third parties it has agreements with. Tvrads.com may direct users to advertisers’ or agreed third parties' sites/services/mobile applications via these forms, announcements, surveys, and advertisements. Tvrads.com has no responsibility for the privacy practices and policies, or any visual, textual, or other content contained within the sites and/or mobile applications accessed through these links.
• Individual/corporate information refers to any information that identifies the user, such as name and surname, address, telephone number, email address, and other identifying information. Unless otherwise stated in this privacy notice, Tvrads.com will not disclose any individual/corporate information to companies or third parties with whom it is not in cooperation. However, in the following cases, Tvrads.com may disclose user information to third parties, breaking the provisions of this privacy notice. These situations are:
• Cases where compliance with the legal obligations stipulated in current legislation and effective international agreements in domestic law is required,
• Cases where the requirements of the agreements between Tvrads.com and its users need to be fulfilled and implemented,
• Cases where information about users is requested by authorized administrative and/or judicial authorities as part of an investigation or inquiry conducted in accordance with procedural methods,
• Cases where it is necessary to provide information to protect users’ rights or safety.
• Tvrads.com undertakes that it will keep confidential information strictly private and confidential, consider it a secret, take all necessary technical, legal, and administrative measures to ensure and maintain confidentiality, prevent any part of confidential information from entering the public domain or unauthorized use or disclosure to a third party, and exercise all necessary care.
• Tvrads.com may obtain information about users' usage of Tvrads.com and its affiliated internet sites and/or mobile applications through cookies, which are technical communication files, and IP or Social Network account user data. A cookie is a data file designed and used to obtain statistical information about how many people use the website at a given time, for what purpose, how many times a person visits the relevant website, and how long they stay, and to produce dynamic variety advertising and content from specially designed user pages. Users can change their browser settings at any time to prevent cookies from being placed on their computers or to warn them when such a file is sent.
• Information requested from users who respond to periodic or non-periodic surveys conducted by Tvrads.com within the Site or Applications can be used by Tvrads.com and its cooperating persons or institutions for direct marketing purposes, statistical analysis, and the creation of a special database.
• Tvrads.com may change the provisions of this privacy notice at any time, provided that it publishes the updates on Tvrads.com and its affiliated internet sites and/or mobile applications. The provisions of the privacy notice amended by Tvrads.com are deemed to have entered into force on the date they are published on the Site or Application.
• The Customer (end-user) consents to the transfer of information related to the payment method, membership, and order to iyzico Payment Services Inc. for the realization of the payment and the prevention, investigation, and detection of payment fraud, and the processing and storage of this information by iyzico as described in the most current version of the Privacy Policy available at https://www.iyzico.com/gizlilik-politikasi/.
• All intellectual property of the content produced and shared by Tvrads.com belongs to Tvrads.com. The Tvrads.com brand name, logos, domain names, and other brand features cannot be used without written permission. Unless written permission is given by Tvrads.com, source codes, the website, collected data cannot be copied, reproduced, altered, subjected to data mining, or reverse-engineered.
• All intellectual property of data and content collected from third-party sources belongs to the original idea owner. Rights to modify, reproduce, and sell these contents belong to the content owner.
• Content within Tvrads.com and compiled from external sources may be offensive or illegal. Tvrads.com is not responsible for content compiled from external sources. In cases where such content is identified, it will be removed.

Terms of Use for the Tvrads Application

By using the Tvrads application, you, our users, agree, declare, and undertake that you have read, fully understood, and unconditionally accepted the following conditions, and all matters specified in the usage conditions and in the Tvrads application.

SUBJECT AND PURPOSE

These terms of use regulate the obligations users must comply with while using the Tvrads application.

The user benefiting from the Tvrads application acknowledges that these terms will come into effect from the moment they start using the application and that they are obliged to comply with the regulations stated in these terms. The warnings and legal records published on the application are also part of these terms.

These terms of use are an inseparable appendix and part of the user agreement you have read above. The User agrees, declares, and undertakes that they are bound by the User Agreement. In case of conflict between the provisions of the Terms of Use and the User Agreement, the provisions in these Terms of Use will be binding and valid.

DEFINITIONS

Tvrads: Refers to Two Ltd. Sti., which provides the application service.

User: Refers to individuals or legal entities who are currently using the Tvrads product and have purchased the application and become members or are using the basic package for free.

Content: Refers to the data uploaded to the application by the User to benefit from the application.

USAGE OF THE APPLICATION

In order for the user to use the application, they must have selected the basic package of the application or purchased the pro package.

If the user is using the basic package of the application, they must log in to the application at least once every 120 days. Users who do not log in to the application within 120 days will have their memberships suspended.

If the user has purchased the pro package of the application, they will continue to use the application as a pro package until the package period expires. If the subscription is not renewed after the expiration of the pro package period, the user may continue to use the basic package.

USER RIGHTS AND OBLIGATIONS

The User and Third-Party Platforms are responsible for ensuring that the information regarding integrations with Third-Party Platforms is complete, accurate, and up to date. The Company bears no responsibility in this regard.

Tvrads reserves the right to delete product, visual, and integration information related to orders from basic package holders who do not log in to the system within 120 days, except for legal obligations.

The User acknowledges, declares, and undertakes that the integration of goods and services on Third-Party Platforms does not create any illegality or infringement of rights, and that the User is solely responsible for the publication, offering for sale, and sale of relevant advertisements and Content of goods and services on the internet.

CHANGES

The provisions and information in the Terms of Use may be changed by Tvrads at any time, and it is the user's responsibility to follow up on such updates. The User shall be deemed to have accepted any changes made to these terms of use.

INTELLECTUAL PROPERTY

All rights, ownership, and interests in the Tvrads application belong to Tvrads. Under these Terms of Use, the User is granted a personal, worldwide, royalty-free, non-transferable, and non-exclusive license to use the application. None of the provisions in other articles regarding the application can be interpreted as transferring rights and benefits related to the application to the User. The User grants Tvrads the right to use their information and Content for purposes of accessing the application, using the application, and providing services, including copying, transmitting, storing, and backing up.

The User does not have the right to copy, modify, reproduce, subject to reverse engineering, decompile, or in any other way access the source code of the software on Tvrads.com for any reason. Modification of the browser and content related to the application in any way or linking to or from the application without the explicit permission of the Company is strictly prohibited.

The User shall not use Tvrads's trade name, trademark, service mark, logo, domain name, etc. under any circumstances.

OTHER PROVISIONS

These Terms are governed by Turkish Law, and Istanbul Courts have jurisdiction over any disputes that may arise between the Parties.