PRINCIPLES OF PERSONAL INFORMATION PROCESSING
While processing your personal data, we act in compliance with the following principles:
- We practice due care to ensure that your personal data is accurate and up-to-date.
- We process your personal data in good faith for specific, explicit and legitimate purposes, and present these purposes to you in a transparent and understandable manner.
- We process your personal data only when it is connected, limited and restrained with processing purposes.
- We store your personal data only for the period required by the relevant legislation or for the purpose for which they are processed. We comply with periods set forth in the legislation for the storage of personal data, and if no such a period is provided, we only store personal data for the period required for processing purposes.
- We delete or destroy your personal data in case where the grounds of processing is no longer present in accordance with the Law and the relevant legislation.
COLLECTION OF YOUR INFORMATION
We must collect information about you in a variety of ways to create and manage your account and provide you with our services. In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information.
However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving or statistical purposes) if and where this is permitted by applicable data protection laws. The information we collect depends on the content and materials you use, and includes:
Personally Identifiable Data
Identity and contact details (such as your name, phone number and email address) that you voluntarily give to us when creating a profile, fill out forms and choosing to participate in various activities related to Touch, such as posting messages and videos, and sending feedback. If you choose to share data about yourself via your Touch profile, please be advised that all data you disclose in these areas is public and your data will be accessible to anyone who accesses Touch. In particular, when you post comments, contributions or other content to Touch, your posts may be viewed by all users and may be publicly distributed outside Touch. We will also ask you to create a password for your account and we will store this information with encryption.
Information our servers automatically collect when you access Touch, such as your actions that are integral to Touch, including [PLEASE SPECIFY ACTIONS], or replying to a post, as well as other interactions with Touch and other users via server log files. Some of this information may be collected using cookies and similar tracking technology. This includes, specifically, device details, such as your, IP (Internet Protocol) address, device type, unique device identification numbers, browser-type, device location, and other technical information including user transaction records and application usage information. We may aggregate such derivative data in a way that the end-product does not personally identify you or any other user of Touch. See further the “Cookies and similar tracking technology” section below.
Data from Third Party Networks
User information received from third party sources, such as Apple and Google, including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts, but only if you connect your Touch account to such third-party accounts or use your third-party account information to register with Touch. This information may also include the contact information of anyone you invite to use and/or join Touch.
[IF APPLICABLE] Geo-Location Information
We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using Touch, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Access
We may request access or permission to certain features from your mobile device, including your mobile device’s [PLEASE DELETE OR ADD AS APPROPRIATE] bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
We may request to send you push notifications regarding your account or Touch. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
Data From Surveys
Personal and other information you may provide when responding to surveys.
WHY WE COLLECT YOUR INFORMATION
Having accurate information about you allows us to provide you with a smooth, efficient, and personalized experience. Specifically, we use information collected about you via Touch to:
- To register you to Touch, to create a personal profile about you to make your usage more personalized and to manage your account,
- To communicate with you, and enable user-to-user communications,
- To offer you the most suitable options and recommendations for your preferences, likes, interests, usage habits and location,
- Where you have consented to receive marketing communications, to deliver targeted advertising and other information regarding promotions and Touch to you,
- To deliver online advertising to you via Touch,
- To provide geolocation services if you choose to share your geolocation,
- To compile anonymous statistical data and analysis for use internally or with third parties to measure and analyze the use and effectiveness of our services and increase the efficiency and operation of Touch,
- To receive feedback and process any requests or complaints from you,
- To conduct Touch activities in compliance with the applicable legislation,
- To carry out age verification checks,
- To prevent and detect security concerns, fraud and abuse,
- To review and audit Touch business activities
- To resolve disputes and troubleshoot problems,
- Request feedback and contact you about your use of Touch.
DISCLOSURE OF YOUR INFORMATION
We may share information we have collected about you with certain categories of recipients in certain situations as provided below:
Any Competent Law Enforcement Body, Regulatory, Government Agency, Court or Other Third Party
If we believe the release of information about you is necessary to exercise, establish or defend our legal rights, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of you and others, we may share your information as permitted or required by any applicable law, rule, or regulation with any law enforcement or regulatory body, government agency, court or other third party.
Third-Party Service Providers
We may share your information with third parties who provide data processing services to us or on our behalf, including data analysis, email delivery, hosting services, customer service, marketing assistance, financial, legal, accounting services or who otherwise process personal information for purposes that are described in this Privacy Notice. Our service providers include but not limited to: [PLEASE SPECIFY AS APPROPRIATE]
We may share your information with our business partners to offer you certain products, services or promotions.
[IF APPLICABLE] Third-Party Advertisers
We may use third-party advertising companies to serve ads when you visit Touch. These companies may use information about your visits to Touch and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.
Other Third Parties
We may share your information with advertisers and investors for the purpose of conducting general business analysis. With your consent, or with an opportunity for you to withdraw consent, we may also share your information with such third parties for marketing purposes, as permitted by law.
An Actual or Potential Buyer
We will not sell, distribute or rent your personal information unless we have your permission or are required to do so by law.
INTERNATIONAL DATA TRANSFERS
We may transfer your personal information to other countries than the country in which you are resident, where our service providers operate. Touch website servers are mainly located in [PLEASE SPECIFY], however our third party service providers and partners operate in a number of countries, including [PLEASE SPECIFY]. This means that when we collect your personal information we may process it in any of these countries.
LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where,
- we need the personal information to perform a contract with you,
- the processing is in our legitimate interests and not overridden by your data protection interests or your rights and fundamental freedoms, or
- we have your consent to do so.
In some cases, we may also have a legal obligation to collect personal information from you (for example in legal proceedings) or may otherwise need the personal information to protect your vital interests or those of another person.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If we collect and use your personal information in reliance on our legitimate interests, this interest will normally be to operate our App and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, or improving our App. In addition to these, we may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, you can contact us using the “contact us” link below.
Cookies and Web Beacons
- to track new visitors to Touch,
- to help us recognize your browser as a previous visitor, including any preferences that may have been set while your browser was visiting touch, such as language,
- to store your username and password if you are registered with us,
- to work with online advertising companies to display targeted advertising on our platforms and third party platforms that you visit, based on information you submit or your activity on Touch and those third party platforms..
Most browsers are set to accept cookies by default. You should view the Help menu on the browser you use for further information. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings (often found in your browser’s Tools or Preferences menu) to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis, but be aware that such action could affect the availability and functionality of Touch.
For more information on cookies and how to disable cookies please visit your browser’s help file or sites such as www.allaboutcookies.org.
We may also partner with selected third-party vendors[, such as [PLEASE SPECIFY, e.g.: Adobe Analytics,] [Clicktale,] [Clicky,] [Cloudfare,] [Crazy Egg,] [Flurry Analytics,] [Google Analytics,] [Heap Analytics,] [Inspectlet,] [Kissmetrics,] [Mixpanel,] [Piwik,] and others], to allow tracking technologies and remarketing services on Touch through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of Touch, determine the popularity of certain content, and better understand online activity.
We do not transfer personal information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can install and/or update your settings by using the opt-out tools/features provided by them.
You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.
Depending on your permissions, we may receive your personal information from your Internet service and mobile device providers. Users of mobile devices who do not want to receive interest-based advertising may opt-out in several ways. Each operating system, (iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices) provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You should view your device or system “Settings” to determine how you can opt out of use of your device ID for “cross-app” personalized advertising.
Do Not Track Signals
Some browsers have a “do not track” feature that allows you to tell websites that you do not want to have your online activities tracked. We do not currently respond to those signals as these features are not yet uniform.
SECURITY OF YOUR INFORMATION
We place great importance on keeping your personal information safe and secure. As such, we put in place appropriate technical and organizational measures to protect it from unauthorised access and unlawful processing, accidental loss, destruction and damage. Technical security measures are implemented by Touch taking into account the requirements of the applicable legislation, the current state of technology, the nature of the information processed and the risks associated with its processing.
Where you have chosen a password which allows you to access Touch, you are responsible for keeping this password confidential. We advise you not to share your password with anyone and to use a unique password for Touch. We will not be liable for any unauthorized transactions entered into using your name and password.
POLICY FOR CHILDREN
We do not knowingly solicit information from or market to children under the age of 13. We therefore advise parents to monitor their children’s online activities, so as to prevent their personal information being collected without parental consent. If you become aware of any data we have collected from children under age 13 without consent, please contact us using the contact information provided below so that we can take appropriate measures.
OPTIONS REGARDING YOUR INFORMATION
You may at any time review or change the information in your account or terminate your account by:
- Logging into your account settings and updating your account
- Contacting us using the contact information provided below
- [IF AVAILABLE, PLEASE SPECIFY Other]
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files where we have an ongoing legitimate business need to do so (such as record keeping and compliance with our legal obligations). When we have no longer an ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Emails and Communications
If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:
- Noting your preferences at the time you register your account with Touch
- Logging into your account settings and updating your preferences
- Using the unsubscribe functionality in the communication you receive
- Contacting us using the contact information provided below
If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.
YOUR PRIVACY RIGHTS
Touch respects your privacy and data protection rights. You can access your account at any time in order to view and update your personal information. In respect of your personal information which Touch processes, you have the rights to:
- obtain information about all your personal information that we collect, use and disclose in accordance with applicable law,
- modify and delete certain of your personal information by logging into our Site using your username and password and visiting the “Account” page,
- request the deletion of your personal data, if such information is incomplete, outdated, unreliable, unreasonably obtained or is not necessary for the stated purpose of processing and if the functionality of the corresponding service does not allow you to delete such information on your own,
- object to the processing of your personal data,
- ask us to limit the processing of your personal data,
- withdraw your consent to the processing of your personal information,
- opt out of receiving marketing communications at any time,
- request your personal data to be transferred to a third party,
- complain to the data protection authority in your country about our collection and use of your personal information, or refer the matter to a court of competent jurisdiction
You can exercise these rights by contacting us using the contact details provided under the “contact us” section below. We may request proof of your identity before fulfilling these requests.
Withdrawing your consent will not affect the lawfulness of any processing we have conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent, such as statutory provisions, especially those affecting Touch’s accounting, processing of claims and mandatory data retention, which may prohibit deletion or anonymization.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We do not discriminate against those who exercise their rights. In particular, if you exercise your rights, we do not deny you services, or provide you a different level or quality of services.
UPDATES TO THIS PRIVACY NOTICE
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
We encourage you to periodically review this page for the latest information on our privacy practices.
The controller of your personal information is
TOUCH SOCIAL MEDIA NETWORK YAZILIM GELIŞTIRME VE TICARET LIMITED ŞIRKETI
KESTEL MAH. KÖKLEME CAD. NO: 9B ALANYA / ANTALYA TURKEY, or
the Touch entity in the country in which you use our Services.