As UserVision Tüketici Araştırmaları Danışmanlık ve Yazılım A.Ş (“Our company” or “we” or “us”), we care about your privacy and take necessary steps to comply with applicable data protection regulations including the EU General Data Protection Regulation (“GDPR”) and other related laws.
1. Personal Data We Collect
a) Personal Data of Visitors When Visitors use or browse our Site, we collect their IP addresses and usage information such as page views, clicks and browser type.
If a Visitor submits a request for a trial on our Site, chats with us for support, requests to watch a webinar, subscribes to our blog or other news, submits a request through our Contact Us form, requests to download a whitepaper or other content, we may also collect the Visitor’s:
- Full name;
- User name;
- Phone number;
- Company name;
- IP address.
We use such Visitor Data to respond to the Visitor's requests, provide the Visitor with the information or materials requested, including without limitation marketing materials, newsletters and other related content, perform analytics on how the Site, Platform and Services are used, and improve the use of our website, Platform or Services.
b) Personal Data of Users
When you create an account in our platform and participate in our tests, interviews, surveys and games, we may collect and process your personal data such as:
- identity information, including your name, surname, signature, nationality, photograph, date and of birth, gender, passport or other identity documents details etc.
- contact information including your phone number, residential address, work address and e-mail address.
- financial and payment information.
- employment information including organization your job, job title, profession/expertise, educational background, affiliations.
- character traits.
- devices owned (e.g. computer, smartphone, tablet).
- voice and video recordings.
Special Categories of Personal Data
Some of our user test, interview, survey, and games may require your special categories of personal data/sensitive data. Such special categories of personal may be your race, ethnic origin, political opinions, religious and philosophical beliefs.
We may also collect your voice and video recording, however, we will not use such data as biometric data.
We do not obtain such categories of personal data unless you have explicitly given your consent. If you do not want us to process such personal data, you are free to not participate in such user test and you also have right to withdraw your consent at any time.
Unless specifically requested, we ask you to not send us, and not disclose, on or through the UserVision Platform or otherwise to us, any special categories data (e.g. racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric, data concerning health or data concerning a natural person's sex life or sexual orientation).
c) Personal Data of Customers
We may ask our customers to provide information such as identity and contact information including email address, phone number or other relevant personal data during their use of our UserVision Platform and Services.
We use such personal data of our Customers to perform our contractual obligations, to provide them with access to our Platform and Services and to invoice them. We may also use Customer Data to improve our Platform and Services and to provide Customers with notices about improvements and best practices in using the Platform and Services.
Customer may transfer personal data of third parties to us or our platform. In such case, Customer is liable to ensure that such personal data will be collected, processed and transferred to UserVision in accordance with applicable laws.
2. Collection Method of Your Personal Data
a) Personal Data Collected Directly
We collect your personal data in a number of ways, including:
- directly from our website and/or mobile application (e.g. when you register an account with UserVision),
- directly from you via e-mail and telephone (e.g. when we send you our tests, surveys etc. or when we contact you for marketing purposes),
b) Personal Data Collected Indirectly
We may collect your personal data from our business partners including ones whose services you are benefiting.
We may also collect personal data indirectly such as through the use of automated technologies or from third parties.
3. Use of Your Personal Data
We collect, hold, use and disclose your personal data to:
- carry out our interviews, tests, games, surveys to our users and examine their results;
- make and receive payments as well as reward our users;
- perform contractual obligations to you and anyone involved in the process;
- contact you if necessary;
- notify you about company news, improvements and promotions, send you marketing communications and promotional offers as well as periodic customer satisfaction, market research or quality assurance surveys;
- improve our Platform and Services based on your feedbacks and requests as well as our analysis;
- review your requests, suggestions and complaints regarding our Services;
- carry out automated decision making activities in order to carry on its contractual obligations to our customers;
- meet our legal and regulatory requirements, respond to requests from public and government authorities, including authorities outside your country of residence and to meet national security or law enforcement requirements.
We may also occasionally communicate news, updates, promotions and information relating to our Products and Services. We may also administer a contest, promotion, survey or another site feature as further explained on the website. We shall only do this where you have given us your consent or otherwise where we are permitted to do so under the data protection laws in pursuit of our legitimate interests (that is, promoting our Services).
If you do opt out of receiving promotional and marketing messages, we can still contact you regarding our business relationship with you, such as account status and activity updates, survey requests in respect of Products and Services we have provided to you after you have opted out, reservation confirmations or respond to your inquiries or complaints, and similar communications.
5. Automated Decision Making
Some of our tests, surveys, interview or games may contain automated decision making. Such mechanism may be used to profile our users based on results of tests, surveys, games and interview that we have conducted or to help identify and suspend accounts sending spam or engaged in other abusive or fraudulent activity or who have not engaged with the us for an extended period of time
6. Legal Basis for Processing of Your Personal Data
We collect and process your personal data on the following bases which are stated in Article 6(1) of the GDPR:
- You have given consent to the processing of your personal data for one or more specific purposes,
- Processing is necessary for the performance of our contract,
- Processing is necessary for compliance with a legal obligation to which we are subject,
- Processing is necessary for the purposes of our legitimate interests pursued by the controller or by a third party, provided always that such interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data.
We collect and process your special categories of personal data on the following bases which are stated in Article 9(2) of the GDPR:
- You have explicitly given us your consent to process your personal data,
- Processing relates to personal data which are manifestly made public by you,
- Processing is necessary for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity.
7. Disclosure of Your Personal Data
We disclose your personal data
- with our employees, company executives and representatives, business/solution partners and suppliers for the purposes specified in Section 3;
- with our customer to provide our Services;
- with government and regulatory authorities and other organizations, to meet legal and regulatory requirements or to protect or defend our rights or property in accordance with applicable laws;
For the compliance with the GDPR, we ensure that our suppliers and business or solution partners whether they are located outside the EEA or not, takes appropriate technical and organizational security measures in accordance with applicable data protection laws and use it solely for the purposes specified by us.
8. Your Rights
If you are from the European Economic Area or in certain countries, you are also entitled (with some exceptions and restrictions) to:
- Access: You have the right to request information about how we process your personal data and to obtain a copy of that personal data.
- Rectification: You have the right to request the rectification of inaccurate personal data about you and for any incomplete personal information about you to be completed.
- Objection: You have the right to object to the processing of your personal information, which is based on our legitimate interests (as described above).
- Deletion: You can delete your account by using the corresponding functionality directly on the service.
- Automated decision-making: You have the right to object a decision made about you that is based solely on automated processing if that decision produces legal or similarly significant effects concerning you.
- Restriction: You have the right to ask us to restrict our processing of your personal data, so that we no longer process that personal data until the restriction is lifted.
- Portability: You have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format and to have that personal data transmitted to another organization in certain circumstances.
- Complaint: You have a right to lodge a complaint with the authorized data protection authority if you have concerns about how we process your personal data. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.
You may, at any time, exercise any of the above rights, by contacting us via [email protected] below together with a proof of your identity, i.e. a copy of your ID card, or passport, or any other valid identifying document.
In some cases we may not able to give you access to personal data we hold regarding you, if making such a disclosure would breach our legal obligations to our other customers or if prevented by any applicable law or regulation.
9. Residents of the State of California (USA)
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights in relation to their personal information, subject to limited exceptions. For personal information collected by us during the preceding 12 months that is not otherwise subject to an exception, California residents have the right to access and delete their personal information.
We will not discriminate against any customer or user that asserts their rights under the CCPA. We will not: (1) deny you goods or services; (2) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (3) provide you a different level of qualify of goods or services; or (4) suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services.
If you are a California resident, you have the right to request certain information from us regarding our information-sharing practices with third parties for direct marketing purposes. To the extent that we share your personal information for direct marketing purposes, you may receive the following information: (1) the categories of information and sources of information that we disclosed to third parties for direct marketing purposes during the preceding year; and (2) the names and address information of third parties that received such information, or if the nature of their business cannot be determined from the name, the examples of the products or services marketed.
To the extent that we sell your personal information to third parties, you also have the right to request that we disclose to you: (i) the categories of your personal information that we sold, and (ii) the categories of third parties to whom your personal information was sold. You also have the right to direct us not to sell your personal information.
California residents may also designate an authorized agent to make a request to access or delete on your behalf. Your authorized agent must submit proof that you have provided them with power of attorney pursuant to Probate Code sections 4000 through 4465. We may deny a request from a purported authorized agent who does not provide proof of authorization to act on your behalf.
10. Right to Withdraw Consent
If you have provided your consent to the collection, processing and transfer of your personal data, you have the right to fully or partly withdraw your consent. To withdraw your consent please follow the opt-out links on any marketing message sent to you or contact us via [email protected].
Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
11. Collection of Children’s Personal Data
We attach great importance of protecting children’s privacy. Therefore, we make an effort to not collect personal data of any children under the age of 13. If you have any concerns about your child’s privacy with respect to our Services, or if you believe that your child may have provided his/her personal data to us, please contact us using the details provided below. We ensure to delete such personal data from our records immediately.
12. Security of Your Personal Data
We implement appropriate and reasonable technical and organizational measures to protect your personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal data. Such technical and organizational measures include:
- Preparing and implementing privacy policies, data processing inventories and other related documents.
- Creating authorization matrix for our team members,
- Blocking the authority of the team members who have changed or left their jobs,
13. Retention of Your Personal Data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements and, where required for our company to provide service, until the end of the relevant retention period.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Upon expiry of the applicable retention period we will securely delete or destroy your personal data in accordance with applicable laws and regulations.
14. Links to Third Party Sites
We reserve the right to update and change this Policy from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. Any changes we may make to our Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Policy.
16. Contact us