Privacy Policy

1. Introduction

TbtPay offers cards designed exclusively for managing travel expenses for individuals traveling to Turkey. In the course of providing these services, TbtPay may process certain personal information about you. This Privacy Policy ("Policy") outlines how TbtPay collects, uses, and discloses your personal information, and describes your rights and choices regarding this information. In this Policy, "TbtPay," "we," "us," and "our" refer to TbtPay and its affiliates, while "you" and "your" refer to any individual interacting with us.

2. Applicability of this Policy

This Policy applies to:

• (a) TbtPay's travel expense management cards, including related technologies (e.g., app.TbtPay.com and our mobile applications) (the "Services");
• (b) The website www.TbtPay.com (the "Website");
• (c) Emails, advertisements, and any other locations, online or offline, where you interact with our business (collectively referred to as the "Business").

TbtPay’s relationship with you as an individual is governed by the terms of any agreement we have with you (the "Agreement"). If you are a user of our travel expense management cards, any personal information we process on your behalf is governed by the Agreement and not by this Policy. For any issues concerning your personal information processed under an Agreement, please contact us directly.

3. Definition of Personal Data

In accordance with Turkey’s Personal Data Protection Law No. 6698, "Personal Data" refers to any information relating to an identified or identifiable individual. This information may include names, addresses, contact information, financial information, and other similar data. Sensitive data includes information such as race, political opinions, religion, philosophical beliefs, health information, sexual life, or sexual orientation, which requires specific and explicit consent for processing.

4. Information Processed by TbtPay

TbtPay processes information in various ways, as described below:

a. Information Provided to TbtPay

We receive information that you provide through our Services or when interacting with our Business:

• Contact Information: Your name, email address, phone number, and address.
• Communications: Records of your interactions with our sales or support teams, including questions, feedback, or other correspondence.
• Content: Any documents, files, or other information you provide that may include data about you or your travel.
• Third-Party Information: Information you provide about fellow travelers, contractors, vendors, or referrals.
• Job Applicant Data: Information related to job applications, including your employment history, transcripts, and references.
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b. Information Generated and Collected by TbtPay

TbtPay also generates and collects information through your use of our Services and interactions with our Business:

• Usage Data: Information on how you interact with our Services and Website, including pages visited, features used, and time spent.
• Device Data: Data about your device, browser, and operating system, including IP address.
• Location Data: Approximate location information derived from your IP address or other travel-related data.
• Travel Details: Including booking details, travel destinations, and payment information.
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c. Information Collected by TbtPay from Other Sources

We also collect information from other sources to enhance our understanding of your travel needs:

• Financial Partners and Compliance Associates: To verify identities, prevent fraud, and comply with regulations.
• Service Providers: To support our operations and improve our Services.
• Publicly Available Sources: To gather information for business intelligence and due diligence.
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5. How TbtPay Uses Information

We use the information collected for various purposes, including:

• Providing and Maintaining Services: Ensuring the smooth operation of our Services and Website.
• Communicating with You: Sending notifications, updates, and support messages.
• Security and Fraud Prevention: Protecting our Services and Business from unauthorized access and fraudulent activities.
• Legal Obligations and Rights Enforcement: Complying with laws and protecting our rights.
• Developing and Improving Our Services: Enhancing the functionality and offerings of our Services based on user behavior and feedback.
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6. Disclosure of Information by TbtPay

We may share the information we collect under the following circumstances:

• Service Providers: To assist with service delivery and operational support, such as payment processors, analytics providers, and cloud service providers.
• Legal and Regulatory Authorities: To comply with legal obligations and respond to lawful requests.
• Marketing and Advertising Partners: For the purpose of targeted advertising and marketing efforts.

We may also transfer your data to countries outside of Turkey. In such cases, we ensure that adequate protections are in place to safeguard your data during these transfers.

7. Data Security

We employ industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include encryption, firewalls, and access controls. We regularly monitor our systems for vulnerabilities and implement appropriate safeguards.

8. Data Retention

We retain your information for as long as it is necessary to fulfill the purposes for which it was collected. For example, transaction data is retained for a specific period for accounting purposes, while marketing data is retained for a defined period. After the retention period expires, your information will either be securely deleted or anonymized.

9. Data Transfers Outside of Turkey

If your data is transferred outside of Turkey, we will ensure that the destination country provides an adequate level of data protection, or we will take necessary measures to protect your data during the transfer. By using our services, you agree that your data may be transferred outside of Turkey.

10. Your Rights

As a user, you have the right to:

• Access Personal Data: Request information about your personal data.
• Correct Data: Request the correction of inaccurate or incomplete information.
• Delete Data: Request the deletion of your personal data, except where retention is required to comply with legal obligations.
• Restrict Processing: Request a restriction on the processing of your personal data.
• Object to Processing: Object to the processing of your personal data under certain conditions.
• Data Portability: Request the transfer of your personal data to another data controller.

To exercise these rights, you can contact us.

11. Right to Complain

If your rights are violated, you may file a complaint with the Turkish Personal Data Protection Authority. However, by registering and using our services, you agree to first attempt to resolve any disputes by contacting us directly.

12. Data Controller Responsibilities

TbtPay, as the data controller, is responsible for ensuring compliance with Law No. 6698 and must take the necessary actions to fulfill this responsibility. By using our services, you acknowledge that you have read and agreed to this Policy.

13. Changes to the Policy

We may update this Privacy Policy. Any changes to this Policy will be communicated to you via email or by posting a notice on our Website. Continued use of the services after changes are made will be deemed as acceptance of the revised Policy.

14. Contact Us

If you have any questions about this Policy or our data practices, please contact us:

• Email: [email protected]
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Last Updated: August 27, 2024