User Agreement

User Agreement

ARTICLE 1: PARTIES

• 1.1. General User Agreement (“Agreement”), Northernland Construction Ltd., registered as MŞ08727 in the TRNC Registrar of Companies. It has been concluded between ”Northernland” and the user (“User”) who benefits from the services of the Company, by being approved by the User in an electronic environment.

• 1.2 The USER and the “Parties” together will be referred to as the “Party” separately.

ARTICLE 2: DEFINITIONS

• 2.1.Digital Wallet: A digital wallet within the application and offered by Northernland, which allows to perform payment transactions using the information regarding the Wallet Account or Payment Instrument it is defined.

  2.2.Wallet Account: The account opened on behalf of the relevant user in the application and used for the execution of Payment Services.

  2.3.Application: Digital wallet application offered by Northernland.

  2.4.Website: northernplus.app

ARTICLE 3: SUBJECT AND SCOPE

• 3.1. The subject of this contract; It is the determination of all products and services that are available in the application and / or to be offered by Northernland in the future for the user, the conditions for benefiting from these products and services, and the rights and obligations of the parties.

ARTICLE 4: SERVICES

• 4.1 Northernland Digital Wallet is a payment method of Northernland that provides ease of payment to the User. By accepting this Agreement, the User will create a Digital Wallet account through the Application. The User will be able to add amounts to the Digital Wallet through cash stations and/or credit and debit cards in Northernland businesses. The amounts transferred to the Digital Wallet by the user can only be used to pay for the service and/or product purchased at Northernland businesses through the application. It is not possible to use the balances in the Digital Wallet account on any platform or medium except the Application.

ARTICLE 5: FUNDAMENTAL RIGHTS AND OBLIGATIONS OF THE USER

• 5.1. The User declares that he is qualified to conclude this Agreement and acts on his own behalf and on his own account.

• 5.2. The User undertakes that all information and documents provided to Northernland are correct, up-to-date and complete. The user accepts that he is responsible for any damage that may occur due to the inaccuracy of the information provided.

• 5.3. It is the User's responsibility to ensure that the card information reported to Northernland is up-to-date, clear and usable.

• 5.4. The User accepts and undertakes that he will benefit from the services under the Contract in accordance with the legal legislation.

• 5.5. All rights of the software, images and designs, texts, logos and graphics in the Application belong to Northernland. Copying and/or using the information and/or software used in the design, content and database creation of the Application beyond making use of the Application, All kinds of pictures, texts, images, files, etc. contained within the Application. Copying, distribution, processing and other use of data and content is strictly prohibited. In addition, if the User (i) takes any action that may threaten the security of the Application, prevent the software belonging to the Application from working or other users from benefiting from the Application, (ii) place a disproportionate load on the Application in such a way as to give these results, accessing, copying, deleting, modifying or attempting to access information and content published and/or entered by others without authorization; (iii) take actions that threaten the general security of the Application and/or harm the Application, the Company and other users; (iv) Using, trying to use software that will prevent the Application and the software used, or disrupting the operation of all kinds of software, hardware and servers, causing them to break down, reverse engineering, organizing attacks, occupying or otherwise interfering with the Company's servers, work is strictly prohibited.

• 5.6. The User will earn points at a rate determined by Northernland to be used as a discount for the next payments to be made at the Northernland businesses through the Digital Wallet on the Application. The points earned by the user as a result of the expenditures made by the user will be uploaded to the User's Digital Wallet through the application and can be viewed by the user along with the Digital Wallet balance. The User will be able to use these points uploaded by Northernland only in Northernland businesses for the services offered through the Application. You cannot request the cash equivalents of these points to be returned to the User and/or bank account, and these points cannot be transferred. These points have no monetary value anywhere other than Northernland businesses. If the points accumulated in the user's digital wallet are not used until the end of the relevant year, they cannot be transferred to the next year and will be reset at the beginning of each year.

• 5.7. The User can transfer all of his balance and/or a portion that can be determined by the User, excluding the points in the Digital Wallet, to another user's Digital Wallet, provided that it is spent only by paying for the services to be purchased in Northernland businesses. An amount transferred from a Digital Wallet belonging to another User cannot be requested to be refunded in accordance with this agreement under any circumstances.

• 5.8. The User accepts that the amount of points that will be uploaded to the Digital Wallet by Northernland in any way as a result of the payments made through the Application will not exceed the limit remaining in the User's Digital Wallet account and that they will not demand any price from Northernland in any way over this amount. and commits.

• 5.9. The rates and rules regarding the point earning system, which are announced to the User on the Site and/or within the Application and/or and can be changed unilaterally at any time and without notice by Northernland, are a part of this Agreement and are inseparable annexes. The User agrees that he/she may not have any right of objection and/or claim regarding the rules to be decided and/or changed by Northernland.

• 5.10. The user will be able to make a reservation through the application, if such an application exists in the businesses belonging to Norternland, and if such a reservation requires a prepayment, this prepayment will also be made through the application and through the Digital Wallet.

ARTICLE 6: BASIC PROVISIONS REGARDING THE DIGITAL WALLET SYSTEM

Digital Wallet System Fundamentals

• 6.1. The User will be able to create a Digital Wallet account to use as a means of payment in Northernland businesses, up to the upper limit amount determined by Northernland in TL currency.

• 6.2. The payment service through the Digital Wallet subject to this Agreement will be offered only in the services offered through the Application and in businesses belonging to Northernland. The form of payment/digital wallet provided through this application is not a valid payment tool anywhere except Northernland businesses.

• 6.3. The User accepts that he/she must open a Wallet Account with the application in order to benefit from the services offered by the Application.

• 6.4. After the User creates the Digital Wallet, he/she will only load the balance in TL currency to the Digital Wallet through cash stations in Northernland businesses and/or credit card and/or debit card (debit card).

• 6.5. Payment via the digital wallet can be made through the application, and the User accepts and declares that compliance with the technical and other features in the terms of use of the Application must be ensured.

• 6.6. The User accepts and declares that he/she will be responsible for the inaccuracy of the information provided or the failure to properly fulfill his responsibilities within the scope of the Payment Transaction, such as not being clear and understandable.

• 6.7. Information regarding the application by Northernland may be published on the website, brought to the attention of the User within the Application or forwarded to the User's contact address.

• 6.8. Only the amount of services and/or products purchased by the User in any of the Northernland businesses will be collected from the Digital Wallet, and the remaining amount will continue to be kept in the Digital Wallet.

• 6.9. Northernland will not, under any circumstances, use and/or operate the remaining amounts in the Digital Wallet account and/or incur any interest and/or provide the User with any time-related benefits. If the aforementioned amounts are requested by the User, an immediate refund can be requested through the application. Upon the request of the user, if the refund request is approved by Northernland, the refund will be made to the credit card and/or debit card used to make the payment through the application and/or to the account to which the relevant cards are linked and/or to another account on behalf of the registered owner of the said card and/or account. can be made by refunding the account. In this case, the user accepts that transfer and/or bank fees such as transfer fee, credit card point contribution fee, virtual pos commission that will occur due to the return transaction will be deducted from the total price to be forwarded to him.

• 6.10. The User may transfer all of his balance, excluding the points in the Digital Wallet, and/or a portion that can be determined by the User, to another user's Digital Wallet, provided that it is spent only by paying for the services to be purchased in Northernland businesses. An amount transferred from a Digital Wallet belonging to another User cannot be requested to be refunded in accordance with this agreement under any circumstances.

• 6.11. If there are unpaid service fees arising from the User's previous service purchases in businesses, Northernland will be able to automatically collect the User's Digital Wallet account without seeking the User's approval, if there is sufficient balance in the User's Digital Wallet account.

• 6.12. The total balance of the Digital Wallet can be up to the maximum amount specified in the Application. The upper limit amount will be determined by Northernland and will be published in the application and / or on the Site, and the amount can be revised at any time.

• 6.13. After the user introduces the payment card and/or wristband that he can obtain from the cash stations in Northernland businesses to this application, associates it with the application and personalizes it, he will be able to use the balance in his Digital Wallet account in businesses and purchase services through this card and/or wristbands. The user can delete the wristband and/or card that he/she introduced through the application at any time and at any time, and terminate his/her relationship with the application. It is the User's sole and sole responsibility to take the necessary precautions to prevent the related card and/or wristband from being used without the User's consent and/or knowledge, and Northernland shall not be liable for any damages that may occur otherwise.

• 6.14. Northernland reserves the right to change, reorganize, and stop the Application without any prior notice, of any service, product, terms of use and information presented in the Application, available in this Application and its extension. Changes take effect at the time of publication on the App. The User is deemed to have accepted these changes by using the Application or logging into the Application. Changes are announced to the User through the channel determined by Northernland.

• 6.15. Northernland makes no guarantee that the services it provides under the Application will be continuously active and accessible. Northernland, in particular, the decisions and practices of the judiciary and other competent official authorities, force majeure (for example, strikes and lockouts, war, threat of war, civil war, terrorist acts, natural disasters such as riots, earthquakes, fires, floods and similar public authorities' decisions and actions) ], situations caused by third parties, disruptions and delays caused by internet connection service providers and similar external factors, misuse, technical failures and other disruptions, repair works or other referrals and/or any problems that may be caused by these situations. does not accept any responsibility for damage or loss.

• 6.16. Northernland, when necessary, for the implementation of improvements and other changes to be made in the Application, for the continuity of access to the network, for the continuity of access to the network, for the prevention of possible malfunctions in the software or recorded files, in order to prevent possible disruptions or to reduce their effects, and to do other things it deems necessary. may limit or stop access to the service in certain circumstances. Northernland shall not be liable for any failure to process the payment due to the limitation or suspension of access to the Application, or any error in the payment transaction other than its own fault, or for any resulting damages.

Incorrect/Unauthorized Transactions

• 6.16.The User agrees that the phone number that he/she provides while subscribing to the Application will be taken into account when creating the Digital Wallet account and loading the balance, and that the balance cannot be loaded with a phone number other than this mobile phone number.

• 6.17.The user accepts that he is personally responsible for any transaction he will make with the registered mobile phone through the application.

• 6.18.User; Safely protect your Wallet Account, Digital Wallet, Sensitive Payment Data (such as password, security question, certificate, encryption key and PIN, card number, expiration date, CVV, CVV2, CVC2 code) and is obliged to take all measures to prevent its use by others. The User is obliged to notify Northernland and the relevant authorities as soon as possible in the event that the Digital Wallet learns that an event that raises suspicion of fraudulent and unauthorized use has occurred and that the transaction has taken place against his will. The User agrees that he will be liable as specified in this Agreement for any damages that may arise due to the use of the Digital Wallet by unauthorized persons and Northernland will not be liable in any way.

• 6.19.Northernland makes the application available if the User notifies him that the reason for the Digital Wallet's closure has disappeared.

• 6.20.Northernland, such as password, security question, certificate, encryption key and PIN, card number, expiration date, CVV2, CVC2 code used in issuing or authenticating the Payment Order, which may allow fraud or fraudulent transaction if it is seized or changed. The Agent agrees and undertakes to take all necessary measures to securely store and store personal security information on a database. Despite Northernland taking the necessary information security measures, Northernland is not responsible for any damage or loss that may occur as a result of events that develop outside of Northernland's reasonable control, including but not limited to attacks on the Application, Portal and the system, and which it cannot prevent despite showing the necessary care. will not.

Digital Wallet Balance Refund

• 6.21. The amounts that are transferred to the Digital Wallet through the application within the scope of the contract and not spent in return for the service received in the businesses belonging to Northernland and remain as balance in the payment account can be requested by the User through the application. The amount that can be refunded is the current balance of the User in the Digital Wallet account. Upon the user's request, it will be refunded to the credit card and/or debit card used for transferring money to the Wallet Account through the application and/or to the account to which the relevant cards are linked and/or to another account in the name of the account and/or the registered owner of the card. Apart from this, no payment will be made to a credit or debit card and/or account.

• 6.22. After the confirmation notification regarding the refund request is sent to the User, a refund will be made to the User's credit or debit card and/or the accounts to which the cards are linked, within a reasonable time. In this case, the user accepts that transfer and/or bank fees such as transfer fee, credit card point contribution fee, virtual pos commission that will occur due to the return transaction will be deducted from the total price to be forwarded to him. Northernland is in no way responsible if the credit card and/or debit card and/or account has been canceled and/or closed due to bank-related reasons and/or any other technical problem not within the control of Northernland.

ARTICLE 7: OTHER PROVISIONS

Force Majeure

• 7.1. In all cases deemed force majeure, Northernland cannot be held responsible for late or incomplete performance or non-performance of any of its obligations specified in this Agreement. force majeure; including, but not limited to, natural disasters, riots, wars, threats of war, civil wars, acts of terrorism, earthquakes, fires, floods, strikes, lockouts, failures caused by telecommunication infrastructure, power outages and bad weather conditions. shall be interpreted as events that occur beyond its control. During the force majeure, the actions of the Parties are suspended.

Privacy

• 7.2. Northernland may use information about the User within the scope of the “Confidentiality Agreement” and the “Clarification Text on the Protection and Processing of Personal Data”, which are an integral part of the User Agreement. The Company may disclose or use confidential information of the User to third parties outside the scope of this Agreement but within the conditions specified in the “Confidentiality Agreement”.

Term of Agreement and Termination

• 7.3. This User Agreement enters into force on the date it is approved electronically by the User. The Agreement will remain in effect as long as the User is a member of the Application and will continue to have its terms and consequences between the parties.

• 7.4. With this Agreement, the User has the right to unsubscribe at any time without any notice.

• 7.5. Northernland may unilaterally terminate this Agreement and terminate the User's use of this Application at any time without giving any reason, without any notice and without any obligation to pay any compensation, with immediate effect. In such a case, if the User has a balance in the payment account, this amount will be refunded to the credit card and/or debit card used to make the payment through the application and/or to the account to which the relevant cards are linked and/or to the said card, if the refund request is approved by Northernland. and/or by returning it to another account in the name of the registered owner of the account. In this case, the user accepts that transfer and/or bank fees such as transfer fee, credit card point contribution fee, virtual pos commission that will occur due to the return transaction will be deducted from the total price to be forwarded to him.

• 7.6. Northernland may temporarily suspend or completely suspend the ability of relevant Users to make payments or request balance refunds through the Digital Wallet, due to security concerns or malicious User actions. Northernland will not have any responsibility towards its users or third parties due to the temporary suspension or complete suspension of the use of the Digital Wallet.

• 7.7. If Northernland cancels the mobile application, this Agreement will automatically terminate without any indemnity liability.

• 7.8. Courts of the Turkish Republic of Northern Cyprus are authorized in disputes arising from this Agreement.

ARTICLE 8: FITPLUS USERS

• FitPlus users acknowledge and accept that all purchases of packages and services are final and non-refundable under any circumstances. FitPlus users acknowledge and accept that all purchases of packages and services are final and non-refundable under any circumstances.

• FitPlus users confirm that they are solely responsible for their own health and fitness levels. By purchasing and using FitPlus services, users guarantee that they have no health conditions that would prevent them from participating in sports or fitness activities. Any injuries or health issues arising during the use of FitPlus facilities are entirely the responsibility of the user, and FitPlus assumes no liability. FitPlus users confirm that they are solely responsible for their own health and fitness levels. By purchasing and using FitPlus services, users guarantee that they have no health conditions that would prevent them from participating in sports or fitness activities. Any injuries or health issues arising during the use of FitPlus facilities are entirely the responsibility of the user, and FitPlus assumes no liability.

• Users agree to notify FitPlus immediately if they experience any health concerns or conditions that might affect their ability to safely participate in fitness activities. Users agree to notify FitPlus immediately if they experience any health concerns or conditions that might affect their ability to safely participate in fitness activities.

• FitPlus reserves the right to suspend or terminate a user's membership, without prior notice or refund, in the event of any behavior deemed inappropriate, disruptive, or in violation of facility rules and regulations. This includes, but is not limited to, harassment of staff or other members, misuse of equipment, failure to comply with hygiene and safety guidelines, or any conduct that negatively affects the experience of other members. FitPlus reserves the right to suspend or terminate a user's membership, without prior notice or refund, in the event of any behavior deemed inappropriate, disruptive, or in violation of facility rules and regulations. This includes, but is not limited to, harassment of staff or other members, misuse of equipment, failure to comply with hygiene and safety guidelines, or any conduct that negatively affects the experience of other members.

Privacy Policy

The purpose of this Privacy Policy is, during the operation of the NorthernPlus mobile application operated by (“Northernland Group), shared by the mobile application users/members (“Data Owner”) with Northernland Group or by the Companies, the Data Owner’s mobile application to determine the terms and conditions regarding the use of personal data generated during its use.

Which Data is Processed?

Under this heading, the data processed by Northernland Group and considered as personal data in accordance with the Personal Data Protection Law are listed. Unless expressly stated otherwise, the term “personal data” within the scope of the terms and conditions provided under this Privacy Policy will include the information contained in Article 2 of the Clarification Text on the Protection and Processing of Personal Data and the information below. Northernland Group processes data related to name, surname, address, phone number, identity and/or passport information, e-mail address, company title, documents required for membership, contact information, credit/debit card information, account information, device and application usage data, transaction history and shopping habits, GPS data to be obtained during the service, IP address, device operating system and version, device type, hardware model, user transaction records and traffic data, location information, device ID, complaint and suggestion records, bank IBAN number, membership date, customer ID, complaint and suggestion records, mobile application usage details, call center records, application usage information, wallet balance, information on payment and payment methods, user Transaction Information, Transaction Security Information, Marketing Information, Request/Complaint Management Information and Incident Management Information.

For What Purposes Are The Data Used?

Your personal data is used for the purposes stated below and included in Article 2 of the clarification text on the Protection and Processing of Personal Data. Carrying out the necessary work for the relevant business units to benefit from the services offered by the Northernland Group and to carry out the activities carried out by the Northernland Group; Verifying the identities of users and providing security measures for the correct and effective operation of the application, performing and tracking payment transactions; Providing customer support, collecting analytical data for the development of services and application, presenting special offers and promotions to users, data processing process, establishment of the relevant contract for benefiting from the products and services offered by Northernland Group; Performing contractual acts such as receiving payment orders, realizing payment transactions, executing registration procedures to create an account and operating user accounts, providing payment tools, especially digital wallets, tracking accounts and transactions through the mobile application, providing expense summaries and similar functions; Carrying out information and promotion activities about the services offered by Northernland Group, monitoring and controlling unauthorized transactions and/or uses and suspicious transactions, and taking necessary measures and realizing transactions in unauthorized/suspicious transactions; operation of customer recognition and identity verification processes, control of information and documents required by the legislation, follow-up of financial transactions; Carrying out the necessary work by our business units and executing the relevant business processes in order to benefit the related persons from the products and services offered by the Northernland Group, including the sales and marketing activities of our services; To carry out the necessary work by the relevant business units for the realization of the commercial activities carried out by Northernland Group and to carry out the related business processes, to ensure the legal, technical and commercial-occupational security of the Northernland Group and the persons who have a business relationship with the Northernland Group, determining and implementing legal affairs, executing information security processes, performing audit and ethical activities, performing reservation and/or reservation activities in businesses within the Northernland Group, ensuring compliance with company policies and procedures, in case of explicit consent by the user Performing the marketing processes of the products and services offered by Northernland Group by communicating with the user with identity, communication, customer transaction and financial data, customizing the products and services offered by Northernland Group, including profiling and analysis activities, according to the tastes, usage habits and needs of the persons concerned, and recommending them to the relevant persons; to promote users, to create individual campaigns for users, to offer special opportunities by Northernland Group's business partners, to determine the target audience, to carry out activities to increase the user experience, to personalize the application, to carry out direct and personalized marketing activities, to provide services and services offered by Northernland Group. management, supervision and improvement of its operations; conducting market research, conducting strategic planning processes, performing non-personalized marketing activities, ensuring the security of our service, operation and application, detecting fraudulent or illegal activities; prevent and detect fraud and campaign abuse, conduct internal audit, internal control, legal, financial, reporting and internal operations; Again, if express consent is given, processing of preferred contact information for the purpose of sending commercial electronic messages, planning and execution of user satisfaction and corporate communication activities, realization of raffles, campaigns, competitions, promotions or advertising activities, and legal, technical in accordance with the principles to be applied in the processing of personal data specified in Articles 5, 6 and 7 of the “Personal Data Protection Law”, including the provision of commercial job security and personal data that form or are planned to form a part of a filing system within a period appropriate for its purposes. regulates the principles and procedures regarding the processing and transfer, in whole or in part, by automatic or non-automatic methods and tools, and is stored securely.

Northernland Group may use cookies, including cookies for segmentation and marketing purposes, used for analytical purposes, and in this context, data may be processed and transmitted to third parties for the purpose of processing within the scope of analysis services offered by third parties, only to the extent required by these analysis services. The technical communication files mentioned are small text files that it sends to the device to be stored in the main memory. The technical communication file facilitates the use of the Internet in this sense by storing the status and preference settings about a website or mobile application or device. The technical communication file is designed to help dynamically generate advertisements and content and is used for these purposes; to obtain statistical information for the determination of user behavior such as how many people use the websites or mobile applications in temporal proportions, how many times a person visits any website or mobile application for what purpose and how long they stay, and to obtain statistical information from user pages specially designed for users. The technical communication file is not designed to receive any other personal data from the main memory. Most of the browsers are initially designed to accept the technical communication file, but the User can always change the browser settings so that the technical communication file does not arrive or a warning is given when the technical communication file is sent.

Who Can Access the Data?

The personal data of the Northernland Group Data Owner and the new data obtained by using this personal data are sent to the third parties from whom Northernland Group makes use of its services in order to achieve the purposes set out in this Privacy Policy, to the Service providers to process the payment transactions between the Group companies and affiliates and to provide the benefits of the users. and its business partners, in order to perform and improve the functions of the application and in accordance with legal obligations, in accordance with a court decision or official requests.

Northernland Group aims to improve the Data Owner experience (including improvement and personalization), to ensure the security of the Data Owner, to detect fraudulent or unauthorized use, to investigate operational evaluation, to fix errors related to mobile application services and to fulfill any of the purposes in this Privacy Policy, in order to be able to do so, will be able to share it with third parties such as outsourcing service providers, hosting service providers (hosting services), law firms, research companies, call centers, including those who send SMS.

About Right of Access to Data and Correction Requests

Pursuant to Articles 13, 14 and 15 of the Law on the Protection of Personal Data, the subject of information is to learn whether personal data has been processed, to request information about it if personal data has been processed, to learn the purpose of processing personal data and whether they are used in accordance with its purpose, at home or abroad; knowing the third parties to whom the personal data is transferred, requesting correction of personal data in case of incomplete or incorrect processing and requesting the notification of the transaction to the third parties to whom the personal data has been transferred, even though it has been processed in accordance with the provisions of the Personal Data Protection Law and other relevant laws, the reasons requiring processing are eliminated, to request the deletion or destruction of personal data in case of withdrawal, to request the notification of the transaction made within this scope to the third parties to whom the personal data has been transferred, to object to the emergence of a result against the person by analyzing the processed data exclusively through automated systems, to incur losses due to the illegal processing of personal data has the right to demand the compensation of the damage. If Northernland Group does not respond within thirty days from the submission of the application made in accordance with the above-mentioned issues or if the response is not satisfactory, the person subject to the information has the right to apply to the Board. The Board makes the decision on this matter. The subject of the information can use the right of access with the help of an expert. The person subject to the information has the right to object at any time to the processing of his/her data that has been processed, is being processed or is planned to be processed, for legitimate reasons related to the particular situation he/she is in. The objection is made in writing to the controller and must include a request to take or not take a particular action, such as correction, temporary refusal from use, blocking, refusal from transmission or deletion, non-processing and deletion. The Controller must respond in writing to these objections within fifteen business days of the request being submitted. In his response, he should include the reasons for the action taken or, where necessary, not fulfilling the request. If the objections are rejected, the response must be forwarded to the Board. If the companies do not respond within the given time frame, or if the response is not found satisfactory, the person subject to the information has the right to apply to the Board and request that his objection be examined.

The Data Owner is obliged to immediately update the information subject to this Privacy Policy, if there is any change in this information. Northernland Group will not be liable if the person or data subject does not provide up-to-date information.

If the person or data subject to the information makes a request that will result in the inability to use any of their personal data by Northernland Group, they will not be able to fully benefit from the operation of the mobile application and any responsibility arising in this context lies with the Data Owner/User.

Retention Period of Personal Data

Northernland Group will keep the personal data provided by the person or data subject for the period required by the above-mentioned processing purposes.

In addition, Northernland Group may store personal data for the limitation period determined in accordance with the relevant legislation, in case of any dispute that may arise between the Data Owner or the person subject to the information, for the purpose of making the necessary defenses within the scope of the dispute.

Data Security Measures and Commitments

Northernland Group, under the conditions specified in the relevant legislation or expressed in this Privacy Policy, to ensure the confidentiality and protection of data against unintentional or unlawful damage, unintentional loss, alteration, transmission to unauthorized persons or providing access and any other illegal processing takes appropriate institutional and technical measures to

Northernland Group cannot disclose the personal data obtained about the Data Owner or the person subject to the information to others in violation of the provisions of this Privacy Policy and the Personal Data Protection Law and cannot use it for purposes other than processing.

In the case of linking to other applications via the mobile application, Northerland Group does not bear any responsibility for the privacy policies and contents of the applications.

Changes to the Privacy Policy

Northernland Group may change the terms of this Privacy Policy at any time. The current Privacy Policy becomes effective on the date it is submitted to the person or data owner by any means.

CLARIFICATION TEXT ON THE PROTECTION AND PROCESSING OF PERSONAL DATA

As (hereinafter referred to as Northernland Group), we show the necessary sensitivity to the security of your personal data. In this context, as Northernland Group, we attach great importance to the processing and preservation of all kinds of personal data belonging to all legal persons and real persons in accordance with the Law on the Protection of Personal Data No. 89/2007, and we undertake to act in this direction. We would like to inform and enlighten you about our personal data processing activities in accordance with Article 13 of the Personal Data Protection Law No. 89/2007.

Controller: Refers to the Public Institutions and Organizations and real and legal persons who, by themselves or together with others, determine the purposes and methods of processing personal data and have the right and authority to establish, operate and audit the personal data file system.

Personal Data: Describes all information relating to an identified or identifiable person.

Personal data file system: It describes the collection of personal data that is centrally or dispersedly stored in a system according to functional or geographical principles and can be accessed through certain methods.

Board: Describes the Personal Data Protection Board established with Article 20 of the Law No. 89/2007.

ARTICLE 1. Data Protection Officer

With the full understanding of our responsibility, through the "Data Protection Officer" appointed under Article 10 of the Personal Data Protection Law, we will be able to process, record, store, update your personal data as explained below and within the limits ordered by the legislation, and in cases permitted by the legislation and/ or to third parties limited to the purpose for which they are processed.

You can use the following contact information to get in touch:

Address:

Telephone:

Email:

Web site:

ARTICLE 2. Collection of Personal Data and Purpose of Processing

Name, surname, address, phone number, identity and / or passport information, e-mail address, company title, contact information, credit card / debit card and / or account information that you provide verbally or in writing, Device and application usage data, transaction history and shopping habits, GPS data to be obtained during the service, IP address, device operating system and version, device type, hardware model, user transaction records and traffic data, location information, device ID, complaint and suggestion records, bank IBAN number, wallet balance, information on payment and payment methods, membership date, customer ID, complaint and suggestion records, mobile application usage details, call center records, wallet balance, information on payment and payment methods, application usage information, user transaction information, transaction Data regarding Security Information, Marketing Information, Request/Complaint Management Information and Incident Management Information are collected and processed by Northenland Group for the purposes stated below in accordance with the basic principles stipulated in the Personal Data Protection Law. Collecting and processing the above-mentioned data, benefiting from the services offered by Northenland Group, carrying out the necessary work for the relevant business units to carry out the activities carried out by Northernland Group, verifying the identities of the users and providing security measures for the correct and effective operation of the application, realizing and following the payment transactions, Providing support, collecting analytical data for the development of services and application, presenting special offers and promotions to users, data processing process, conclusion of the relevant contract due to benefiting from the products and services offered by Northernland Group, execution of the obligations under the contract, such as receiving the payment order, realizing the payment transactions, account Carrying out registration procedures and operating user accounts, providing payment tools, especially digital wallets, tracking accounts and transactions through the mobile application, providing expense summaries and similar functions, carrying out information and promotion activities about the services offered by Northernland Group; monitoring and controlling unauthorized transactions and/or uses and suspicious transactions and taking necessary precautions and realizing transactions in unauthorized/suspicious transactions, operating customer recognition and identity verification processes, controlling information and documents required by the legislation, monitoring financial transactions; Carrying out the necessary work by our business units to benefit the persons concerned from the products and services offered by the Northernland Group, including the sales and marketing activities of our services, and carrying out the relevant business processes, carrying out the necessary work by the relevant business units for the realization of the commercial activities carried out by the Northernland Group, and related work ensuring the legal, technical and commercial-occupational security of Northernland Group and the persons in business relationship with Northernland Group, determining and implementing Northernland Group commercial and business strategies, following and executing legal affairs, conducting information security processes, auditing and ethical activities Carrying out reservation and/or reservation activities in the businesses within the body of Northernland Group, ensuring compliance with company policies and procedures, in case of explicit consent by the user, identity, communication, customer transaction and financial data are contacted with the user and the products and services offered by Northernland Group Processing the products and services offered by the Northernland Group, including profiling and analysis activities, for the purpose of recommending and promoting them to the relevant persons by customizing them according to the tastes, usage habits and needs of the persons concerned, creating individual campaigns for users, providing special opportunities by Northernland Group's business partners. presentation, target audience identification, user experience enhancing activities, personalization of the application, direct and personalized marketing activities, management, audit and improvement of services and operations offered by Northernland Group, market research, strategic planning processes, non-personalized marketing activities providing the security of our service, operation and application, detecting fraudulent or illegal activities, preventing and detecting fraud and campaign abuse, conducting internal audit, internal control, legal, financial, reporting and internal operations, again if your explicit consent is given Processing preferred contact information for the purpose of sending commercial electronic messages, planning and executing user satisfaction and corporate communication activities, realizing raffles, campaigns, competitions, promotions or advertising activities, and ensuring legal, technical and commercial job security of the persons in business relationship with Northernland Group It is processed in accordance with the principles to be applied in the processing of personal data specified in Articles 5, 6 and 7 of the Personal Data Protection Law, including the personal data that constitutes or is planned to form a part of a filing system, within the appropriate period of time, by automatic or non-automatic methods and tools, regulates the principles and procedures regarding the processing and transfer of wholly or partially, and is stored securely. Users' personal data is processed and stored for the above-mentioned purposes within the scope of the Personal Data Protection Law and relevant legislation. The data is stored only for the above-mentioned purposes and for the periods stipulated in the legislation. In addition, the Data Owner accepts that Northernland Group may keep personal data in case of any dispute that may arise between the Data Owner or the person subject to the information, for the purpose of making the necessary defenses within the scope of the dispute, and for the limitation period determined in accordance with the relevant legislation.

ARTICLE 3. To Whom Personal Data Can Be Transferred and Purpose of Transfer

Your personal data provided in order to provide our services in line with the above-mentioned purposes is processed within the scope of data transfer to other countries specified in Articles 11 and 12 of the Personal Data Protection Law, and within the confidentiality and security of the transaction, Group companies, our suppliers, business partners, affiliates and service providers. It can be transferred to legally authorized public institutions and organizations and private institutions in order to provide benefits and users, to perform and develop the functions of the application, and in accordance with legal obligations, court decisions or official requests. If the Data Owner does not consent to the collection and/or processing of the data and/or sharing it with the necessary persons, he/she will not be able to fully benefit from the operation of the mobile application and any responsibility arising in this context lies with the Data Owner/User.

ARTICLE 4: Collection Method and Legal Reason of Personal Data:

Your personal data; Filling in the form for creating an account in electronic environment, call center, our website, our mobile applications, short message, e-mail and physical environment that you contact Northernland Group and/or in any verbal, written or electronic media, can be collected for the purposes stated above. Your personal data collected for this legal reason can be processed and transferred within the scope of the principles to be applied when processing personal data specified in Articles 5, 6 and 7 of the Personal Data Protection Law, legal processing and processing of sensitive data.

ARTICLE 5: Rights of the Person Subject to Information and/or Data Owner as per Section 4 of the Law on the Protection of Personal Data

Within the scope of the Law on the Protection of Personal Data, the person and/or data subject subject to the information has the following rights.

• 5.1 Everyone has the right to know whether their personal data is being processed or not. Therefore, Companies must respond to the person in writing.

• 5.2 The person and/or data subject subject to the information, all personal data that has been processed, as well as their source, purpose of processing, categories of recipients or recipients of this information and categories of data being processed or being processed, progress in processing since the previous notification , has the right to know the third parties to whom personal data is transferred, in the country or abroad, and has the right to ask questions and receive answers to Northernland Group in these matters. Requesting the deletion or destruction of your personal data in the event that the reasons for the correction, deletion or blocking of the data are corrected, deleted or blocked, the processing that has not been carried out in accordance with the rules of this Law due to inaccuracies and deficiencies, although the processing has been processed in accordance with the provisions of the law, and In this context, they had the right to request the notification of the third parties to whom your personal data was transferred, and to notify the third parties about any correction, deletion and blocking of the data, unless it is impossible and does not require disproportionate effort.

• 5.3 If the Northerland Group does not respond within thirty days from the submission of the application made in accordance with clause 5.2 or if the response is not satisfactory, the person or data owner who is subject to the information has the right to apply to the Board. The Board makes the decision on this matter.

• 5.4 The person or data subject subject to the information can use the right of access with the help of an expert.

• 5.5 Health-related data is communicated to the person subject to the information through the doctor.

• 5.6 Northernland Group, by the decision of the Board, to inform the person subject to the information; (A) It is expressly stipulated in a private law, (B) It is necessary for a superior public interest, especially for the protection of the internal and external security of the State, (C) It may limit, postpone or reject the information in cases where it makes it difficult to realize the purpose of an administrative or criminal investigation, notifies the reason in writing to the person concerned.

• 5.7 The person and/or user subject to the information has the right to object, at any time, to the processing of his/her data that is processed, being processed or planned to be processed, for legitimate reasons related to the particular situation he/she is in.

• 5.8 If Northernland Group does not respond within the given time frame, or if the response is not found satisfactory by the person or data subject, the person or data subject to the information has the right to apply to the Board and request that his objection be examined.

• 5.9 Access and objection rights are exercised by submitting the application to the controller. The person's access to the data by using his right of access is in return for the fee specified in paragraph (2) of article 37 of this Law.

• 5.10 Unless the Controller proves that he is not responsible for the event giving rise to the damage, he shall indemnify the person or data subject of the information damaged due to the violation of any rule of this Law.

Article 6: Cookies and Tracking Technologies

Our mobile application may use cookies and other tracking technologies to improve the user experience and measure the performance of the application. Users continue to use the application by accepting the use of these technologies

In this context, we request your express consent for the processing of personal data that you share/share with Northernland Group in accordance with the Personal Data Protection Law and relevant legislation by informing you about the processing, protection, transfer of your personal data to third parties and the rights granted to you within the scope of the Personal Data Protection Law.

“I have read and understood the text of the disclosure and I accept and declare that I have given my express consent in the above-mentioned matters.”