In accordance with the Personal Data Protection Law No. 6698 (“Law”), your personal data may be processed by PayFi Systems LLC (“Company”) as the data controller within the scope described below.

Purposes of Processing Personal Data

Your collected personal data may be processed for the purposes ("Purposes") listed below, within the conditions and purposes of personal data processing specified in Article 5 of the Law.

• Verification and updating of user information when necessary,
• Establishment of the relevant contract due to your use of our company's products and services and receipt of the payment order, execution of payment transactions, issuance of electronic money and conversion to funds, and fulfillment of contractual obligations,
• Execution of account creation - registration processes and operation of your account,
• Provision of payment instruments, especially digital wallets,
• Providing account and transaction tracking, expense summaries, and similar functions via the mobile application,
• Informing and promoting our products and services,
• Carrying out payment and electronic money services in accordance with the legislation, especially digital wallets,
• Fulfilling requests from official institutions,
• Providing information to authorized organizations based on legislation,
• Ensuring compliance with the retention obligations stipulated in the legislation,
• Tracking and controlling unauthorized transactions and/or uses, and taking necessary measures and executing transactions in unauthorized/suspicious transactions,
• Managing customer identification and authentication processes, ensuring the control of information and documents required by the legislation,
• Evaluating and concluding your applications regarding your rights specified in Article 11 of the Law with respect to personal data processed by our company, and taking necessary actions within this framework,
• Managing user relationships,
• Monitoring financial transactions,
• Carrying out necessary work by our business units to make related individuals benefit from the products and services offered by our company, including sales and marketing activities of our products and services,
• Conducting necessary work by our business units to perform the commercial activities carried out by our company and managing related business processes,
• Ensuring the legal, technical, and commercial-business security of our company and related individuals with whom we have business relations,
• Determining and implementing our company's commercial and business strategies,
• Following up and carrying out legal affairs,
• Managing information security processes,
• Conducting audit and ethical activities,
• Ensuring compliance with company policies and procedures,
• Planning and executing user satisfaction and corporate communication activities,
• Conducting raffle, campaign, contest, promotion, or advertising activities,
• Retaining personal data for the general statute of limitations in order to constitute evidence in possible future disputes,
• Receiving, evaluating, and concluding your requests and complaints,
• Processing your identity, communication, customer transaction, and finance data with your explicit consent for the purpose of contacting you, conducting marketing processes, profiling, and analysis activities, and customizing and promoting the products and services offered by our company according to your preferences, usage habits, and needs,
• Processing your identity and communication data with your explicit consent to send commercial electronic messages to your preferred communication details.

To Whom and For What Purpose Processed Personal Data Can Be Transferred

Your collected personal data may be transferred to our suppliers, business partners, legally authorized public institutions, and legally authorized private persons within the framework of the conditions and purposes of personal data processing specified in Article 8 of the Law for the purposes of fulfilling the Purposes mentioned above.

Method and Legal Reason for Collecting Personal Data

Your personal data are collected through account creation forms filled electronically, call centers, our website, mobile applications, SMS, and email channels, and through physical forms during your communication with our company, in order to fulfill the Purposes mentioned above.

Your personal data are collected and processed by our company based on the personal data processing conditions specified in Article 5 of the Law for the purposes listed below.

For the establishment or execution of a contract, provided that it is directly related to the establishment or execution of the contract, your personal data may be processed for the following purposes:

• Establishment of the relevant contract due to your use of our company's products and services and receipt of the payment order, execution of payment transactions, issuance of electronic money and conversion to funds, and fulfillment of contractual obligations,
• Execution of account creation - registration processes and operation of your account,
• Provision of payment instruments, especially digital wallets,
• Providing account and transaction tracking, expense summaries, and similar functions via the mobile application,

Based on the legal obligation of the data controller to fulfill its legal obligations and if explicitly stipulated by laws, your personal data may be processed for the following purposes:

• Verification and updating of user information when necessary,
• Carrying out payment and electronic money services in accordance with the legislation, especially digital wallets,
• Fulfilling requests from official institutions,
• Providing information to authorized organizations based on legislation,
• Ensuring compliance with the retention obligations stipulated in the legislation,
• Tracking and controlling unauthorized transactions and/or uses, and taking necessary measures and executing transactions in unauthorized/suspicious transactions,
• Managing customer identification and authentication processes, ensuring the control of information and documents required by the legislation,
• Evaluating and concluding your applications regarding your rights specified in Article 11 of the Law with respect to personal data processed by our company, and taking necessary actions within this framework,

Based on the necessity of data processing for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the related person, your personal data may be processed for the following purposes:

• Verification and updating of user information when necessary,
• Informing and promoting our products and services,
• Managing user relationships,
• Monitoring financial transactions,
• Carrying out necessary work by our business units to make related individuals benefit from the products and services offered by our company, including sales and marketing activities of our products and services,
• Conducting necessary work by our business units to perform the commercial activities carried out by our company and managing related business processes,
• Ensuring the legal, technical, and commercial-business security of our company and related individuals with whom we have business relations,
• Determining and implementing our company's commercial and business strategies,
• Following up and carrying out legal affairs,
• Managing information security processes,
• Conducting audit and ethical activities,
• Ensuring compliance with company policies and procedures,
• Planning and executing user satisfaction and corporate communication activities,
• Conducting raffle, campaign, contest, promotion, or advertising activities,

Based on the necessity of data processing for the establishment, exercise, or protection of a right, your personal data may be processed for the following purposes:

• Retaining personal data for the general statute of limitations in order to constitute evidence in possible future disputes,
• Receiving, evaluating, and concluding your requests and complaints,

With your explicit consent,

• Your identity, communication, customer transaction, and finance data may be processed for the purpose of contacting you, conducting marketing processes, profiling, and analysis activities, and customizing and promoting the products and services offered by our company according to your preferences, usage habits, and needs,
• Your identity and communication data may be processed to send commercial electronic messages to your preferred communication details.

Rights of the Related Person as Specified in Article 11 of the Law

We inform you that as a related person, you have the following rights under Article 11 of the Law:

• To learn whether your personal data has been processed,
• To request information if your personal data has been processed,
• To learn the purpose of processing your personal data and whether they are used in accordance with their purpose,
• To know the third parties to whom your personal data is transferred, in the country or abroad,
• To request the correction of your personal data if it is incomplete or incorrectly processed, and to request that the process carried out within this scope be notified to the third parties to whom your personal data has been transferred,
• To request the deletion or destruction of your personal data if the reasons for processing your personal data have disappeared, even though it has been processed in accordance with the provisions of the Law and other relevant laws, and to request that the process carried out within this scope be notified to the third parties to whom your personal data has been transferred,
• To object to the emergence of a result against you by analyzing your processed data exclusively through automated systems,
• To demand the compensation of your damages if you suffer damage due to the unlawful processing of your personal data.

If you submit your requests regarding your rights mentioned above to our company, our company will conclude the request free of charge as soon as possible and within thirty days at the latest, depending on the nature of the request. However, if the transaction incurs an additional cost, a fee may be charged based on the tariff determined by the Personal Data Protection Board.