Last Update Date: 18.01.2021
NARKASA SOFTWARE TRADE CORPORATION
THE PROCESSING AND PROTECTION OF PERSONAL DATA
CLARIFICATION DOCUMENT CONCERNING THE WEBSITE AND MOBILE APPLICATION
This clarification document has been drafted by the data processor and controller Narkasa Software Trades Corporation (hereinafter: “NARKASA”), which is registered at the Chamber of Commerce of Istanbul under number 184965-5 and Central Civil Registration System number 0629108212100001.
This document provides information about
- Which type of personal data are processed,
- For which purposes the personal data are processed,
- To whom the personal data will be transferred and for what goal,
- What the method is for gathering personal data and what the legal reasons are,
- Which legal rights the person has
- With regard to the natural person who visits the NARKASA website and mobile applications under the domain name www.narkasa.com or subdomains connected to this domain or the user who opens an account within the framework of the NARKASA ‘Processing and Protection of Personal Data Policy’ and the ‘Cookie Policy'.
A-)Personal data processed by NARKASA and processing purposes
1-) Personal data which are processed
The personal data of the natural person who visits the NARKASA websites and mobile applications or the user who opens an account and which are processed are listed below by category, scope and type:
| Data Category | Scope | Type | |
| 1 | Identification | Name, last name, date of birth, nationality, identification serial number, identity card/document or passport or an internationally valid driver’s license containing the validity date, photograph confirming the identity. | Personal data |
| 2 | Contact | Address (work or home address), residence document confirming the address, utilities invoice, phone number, e-mail address. | Personal data |
| 3 | Customer processes | Account information of users who opened an account via the website and mobile application, customer support and support center registers, invoice and receipt information, transactions realized by the user with his cryptocurrency wallet | Personal data |
| 4 | Transaction safety | IP address information, operating system, network system, type of browser and settings, information about the computer and mobile device, login and logout information concerning the website and mobile application. | Personal data |
| 5 | Finance | The user’s account information with regard to the bank, electronic money or intermediate financial institution, the name of the bank, electronic money and intermediate financial institution, IBAN and account number, receipt | Personal data |
| 6 | Marketing | History information of visiting the website and mobile application, survey information, cookie registrations, information gathered via campaigns, user habits regarding the website and mobile applications.History information of visiting the website and mobile application, survey information, cookie registrations, information gathered via campaigns, user habits regarding the website and mobile applications. | Personal data |
2-) The purpose and conditions of processing personal data (legal basis)
The personal data which are processed by the data controller NARKASA and the processing conditions (legal basis) are listed below:
| Data category | Processing purpose | Processing conditions (legal basis) | |
| 1 | Identification | • Conducting audit activities • Follow up of support / requests / complaints • Carrying out activities in accordance with the legislation • Conducting finance and accounting processes • Carrying out purchasing and after sales support services • Follow up and execution of legal affairs • Conducting communication activities • Carrying out activities regarding customer relations and satisfaction • Conducting marketing analysis studies Sending mail and cargo • Storing and archive activities • Conducting contract processes • Conducting advertisement / campaign / promotion / marketing processes regarding the services offered • Ensuring the security of data controller operations • Informing the authorized persons, institutions and organizations |
Legal Liability
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| 2 | Contact | Sending mail and cargo Follow up of support / requests / complaints Carrying out activities in accordance with the legislation Conducting finance and accounting processes Carrying out purchasing and after sales support services Follow up and execution of legal affairs Conducting communication activities Carrying out activities regarding customer relations and satisfaction Conducting marketing analysis studies • Storing and archive activities • Conducting contract processes • Conducting advertisement / campaign / promotion / marketing processes regarding the services offered • Ensuring the security of data controller operations • Informing the authorized persons, institutions and organizations |
• Express Consent • Execution of the Contract • Act of Law, Legal Liability • Execution of the Contract Execution of Contract, Establishment, Protection, Exercise of the Right • Execution of the Contract • Legal Liability • Execution of the Contract • Execution of the Contract • Legitimate Interest • Legal Liability • Execution of the Contract • Express Consent • Legal Liability, Legitimate Interest • Act of Law, Legal Liability |
| 3 | Customer processes |
|
• Execution of the Contract • Act of Law, Legal Liability • Execution of Contract, Establishment, Protection, Exercise of the Right • Execution of the Contract • Legal Liability • Express Consent • Act of Law, Legal Liability |
| 4 | Transaction safety |
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| 5 | Finance |
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• Execution of the Contract • Act of Law, Legal Liability • Execution of Contract, Establishment, Protection, Exercise of the Right • Execution of the Contract • Legal Liability • Legitimate Interest, Legal Liability • Legal Liability • Execution of the Contract • Act of Law, Legal Liability |
| 6 | Marketing |
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All of the personal data specified in the categories above are collected by automatic means (through the website and mobile applications, the call center, e-mail addresses, social media), and in line with the above-mentioned purposes. In the event of the "express consent" of the relevant person or in other circumstances set forth in articles 8 and 9 where express consent is not required these data may be transferred domestically and abroad.
B-) The method of collecting personal data, the recipients and the transfer purposes
In this context, personal data may be transferred to NARKASA’s affiliates and subsidiaries, shareholders, business partners, representatives, consultants, service providers, third parties, auditors, legally authorized public institutions and organizations.
C-) Rights of the person involved
Within the scope of Article 11 of the Code, the person involved may always file a request to the data controller NARKASA relating to the following information about himself; to ask whether personal data are processed, to request information if personal data have been processed, to ask for the purposes of processing personal data and whether they are used for their purpose, to get information about the domestic or foreign third parties to whom personal data are transferred, to request correction of personal data in case of incomplete or incorrect processing, to request the deletion, destruction or anonymization of personal data in the event that the grounds requiring the data processing cease to exist even though the data have been processed in accordance with the provisions of the law and other relevant codes, to object to the appearance of an incommodity against oneself as a result of an analysis done exclusively through automated systems, to request compensation of the damages incurred due to the unlawful processing of personal data.
When exercising these rights notifications can be made through the following means:
- Via mail to the address of NARKASA at Huzurevler Mahallesi Maslak Ayazağı Caddesi No:4 H/201 Sarıyer/İstanbul/Turkey,
- To the registered electronic e-mail address (KEP), via a secured electronic signature, a mobile signature or the e-mail address previously registered with NARKASA. E-mails may be sent to kisiselveri@narkasa.com or the NARKASA KEP address: narkasa@hs01.kep.tr,
- Via the “application form”.
This clarification document and its content may be updated at any time in case of changes in the law, new requirements and your feedback.
Narkasa Software Trades Corporation
Address (Headquarters): Huzur Mahallesi Maslak Ayazağa Caddesi No:4 H/201 Sarıyer/İstanbul
KEP Address: narkasa@hs01.kep.tr
e-mail : destek@narkasa.com / kisiselveri@narkasa.com
Appendix: application form