Privacy Policy

SOLOSCORE TEKNOLOJİ ANONİM ŞİRKETİ — PRIVACY POLICY 1. Purpose and Scope This Privacy Policy has been prepared to explain the principles governing the processing of the personal data of users who benefit from the services offered through the Soloscore mobile application and website operated by Soloscore Teknoloji Anonim Şirketi. This Policy covers the creation and management of user accounts, the provision of live scores and match statistics, the sending of notifications, the delivery of content feeds, the operation of interaction tools, the provision of in-app messaging services, the application of security measures, the conduct of usage analytics, the management of customer relations processes and the fulfilment of obligations arising from legislation. This Policy has been prepared in order to fulfil the disclosure obligation regarding the processing of personal data. Where explicit consent is required, a separate explicit consent text may be issued. The purpose of the Policy is to set out clearly, comprehensibly and accessibly which data of users is processed for which purposes, on which legal grounds it relies, to whom it may be transferred and which rights users hold. 2. Data Controller The data controller for your personal data is Soloscore Teknoloji Anonim Şirketi. The Company determines the purposes and means of processing personal data and is responsible for the establishment, management, protection and development of the data recording system. You may contact the Company through the following channels for data protection, applications and requests to exercise your rights: • Email: support@soloscore.com.tr If the contact details change, the current information is published through the application and the website. 3. Categories of Personal Data Processed While you benefit from Soloscore services, the following categories of personal data may be processed depending on the nature of the service and the modules you use: 3.1. Identity and Account Information First name, surname, username, nickname, national identification number, user account identifier, year of birth, age range, profile information, account creation and closure records, verification information, encrypted session information and records relating to account security. 3.2. Contact Information Email address, telephone number, notification preferences, communication history and information used in support requests. 3.3. Usage and Transaction Information In-app navigation records, click actions, viewed content, favourite team or league preferences, events subject to notification, match following behaviour, in-app interactions, messaging activity, user content and system usage logs. 3.4. Technical and Device Information IP address, device model, operating system, browser type, application version, device identifiers, cookies, SDK data, session records, login attempts, unauthorized access attempts, error records and similar technical data. 3.5. Security and Audit Information Failed logins, unusual transaction records, suspicious usage detections, moderation records, security breach attempts, rule violation records and audit trail data. 3.6. Messaging and Content Information In-app message content, submitted comments, shared content, communication notes, moderation results and records of interaction between users. 3.7. Commercial and Support Information Campaign participation records, customer support correspondence, request and complaint content, feedback, satisfaction surveys and operational process records. 3.8. Legal Entity User Representation Information Company title, name and surname of the authorized person, authority relationship, contact information, the nature of the represented account and records relating to the authority of representation. The Company processes personal data only to the extent necessary for the relevant service and purpose; in line with the data minimization principle, it does not request data that is unrelated to the service, excessive or disproportionate. 4. Purposes of Processing Personal Data Your personal data may be processed for the following purposes: 4.1. Provision and Management of the Service Creation, verification, updating, suspension and termination of the user account; provision of live scores, match statistics, content feeds, notifications and interaction tools. 4.2. Messaging and Interaction Processes In-app messaging, enabling communication between users, publication of user content, receipt of complaints and conduct of moderation operations. 4.3. Security and Prevention of Abuse Prevention of fake accounts, suspected fraud, unauthorized access, attacks and misuse of the system; log analysis, identity verification and security checks. 4.4. Support and Communication Receipt, evaluation and resolution of user requests, questions, complaints and technical support applications. 4.5. Product and Service Development Improvement of service quality, enhancement of the user experience, error analysis, performance measurement, product development and system optimization. 4.6. Legal Obligations and Dispute Management Fulfilment of record-keeping and retention obligations required by legislation, responding to requests from competent public institutions and organizations, proving disputes and establishing, exercising or protecting rights. 4.7. Marketing, Analytics and Personalization Where explicit consent exists, marketing, segmentation, behavioural analysis, content personalization, campaign management and similar activities. Your personal data is never processed without limit for unclear, subsequently arising or service-unrelated purposes. Each new processing purpose requires a separate legal basis and disclosure. 5. Legal Grounds for Processing Personal Data Your personal data is processed on the basis of one or more of the legal grounds set out in Article 5 and, where applicable, Article 6 of the KVKK. The principal legal grounds are as follows: 5.1. Explicit Consent For processing that requires explicit consent, consent given freely, on an informed basis and in relation to a specific matter is taken as the basis. Soloscore Teknoloji Anonim Şirketi may also, pursuant to Articles 5 and 8 of the Personal Data Protection Law and/or where exceptions in the relevant legislation apply, process personal data and share it with third parties without obtaining the User's separate consent. 5.2. Establishment and Performance of the Contract Operations such as creating the user account, signing in, providing live scores and the service feed, operating messaging modules and performing security checks may be directly related to the establishment or performance of the contract. 5.3. Legal Obligation The Company's retention, notification, audit, response and record-keeping obligations arising from legislation fall within this scope. 5.4. Legitimate Interest The legal ground of legitimate interest may apply to ensuring system security, preventing abuse, improving service quality, performance measurement, internal audit and technical improvement activities. Such processing is carried out in a manner that does not harm the fundamental rights and freedoms of the data subject. 5.5. Establishment, Exercise or Protection of a Right Processing activities for the resolution of disputes, the examination of claims, the retention of content and transaction records, legal defence and the creation of evidence fall within this scope. 6. Methods of Collecting Personal Data Your personal data may be collected through the following methods: • Application and website registration forms, • Login, membership and profile update screens, • Messaging modules, • Support and contact forms, • Cookies, SDKs, local storage and similar technologies, • Log recording systems, • Security and verification mechanisms, • User interactions, • Third-party integrations, • Automated or partially automated data collection tools. In addition to information provided directly by the user, technical data necessary for the secure operation of the system and the provision of the service may also be processed. 7. Transfer of Personal Data Your personal data may be transferred to the following persons and organizations only in line with the purposes set out in this Policy and in compliance with the KVKK: • Cloud, hosting, database, software, security and infrastructure service providers, • Email, push notification, SMS and messaging service providers, • Customer relations and support service providers, • Auditors, legal advisers, financial advisers and similar professional consultants, • Competent public institutions and organizations, • Judicial authorities and law enforcement units, in cases of legal obligation, • Business partners, potential investors, relevant third parties and technical solution providers, only to the extent necessary for the performance of the service. The principles of purpose limitation, proportionality and data security are observed in transfers. The nature of the recipient groups is determined separately according to the data category and the processing purpose. 8. Transfer Within and Outside Turkey The transfer of personal data within Turkey is carried out where the relevant legal ground exists and with the necessary security measures in place. Where personal data is transferred abroad, the conditions set out in Article 9 of the KVKK are separately assessed. Where the cloud services, content delivery networks, analytics tools, notification infrastructures or messaging services used are located abroad, the necessary legal basis and safeguards for the relevant transfer mechanisms are provided separately. The user accepts that such technical infrastructure may be part of the service, and that the Company is nonetheless obliged to structure transfer processes lawfully. 9. Cookies, SDKs and Similar Technologies The Soloscore website and mobile application may use cookies, SDKs, local storage areas and similar technologies in order to provide the service, manage sessions, ensure security, measure performance, improve the user experience and remember preferences. Where required, separate explicit consent is obtained for non-essential cookies or similar technologies. The user may change cookie preferences through browser or device settings. However, it is accepted that if certain cookies are disabled, some parts of the service may not work fully. 10. Account Security and System Security The Company applies appropriate technical and administrative measures to prevent unauthorized use of the user account and to protect system integrity. In this context, measures such as strong encryption, multi-factor authentication, session control, logging, permission limitation, access management, backup, disaster recovery and detection of unusual usage may be applied. The user is also responsible for the security of their own account. The user may be responsible for risks arising from sharing the password with third parties, failing to secure the device, failing to exercise care against phishing attempts or failing to report suspicious access in a timely manner. Where technical examination detects unusual usage, unauthorized access or a security risk, the Company may temporarily suspend the account, request additional verification or apply a time-limited access restriction. 11. Messaging, Content and Community Rules Messages, comments, content, links and other materials created through interaction tools within the application may be processed for the purposes of operating the service, maintaining community order, security and following up legal responsibilities. The user is responsible for ensuring that the content they share complies with the law, third-party rights, personal rights, intellectual property rights, public morality and platform rules. Relevant data and records may be processed and, where necessary, retained within the scope of complaints, infringement notices, moderation, content removal, access blocking or account closure operations. 12. Retention Period of Personal Data Soloscore Teknoloji Anonim Şirketi retains personal data for the period required by the processing purposes set out in this Privacy Policy, taking into account the retention periods stipulated in the relevant legislation. Personal data is retained for as long as the membership relationship continues and limited to the period necessary for the services to be provided. Where the membership ends or the reason requiring the processing of personal data ceases to exist, personal data may continue to be retained taking into account the retention, limitation and obligation periods stipulated in the relevant legislation. In addition, Soloscore Teknoloji Anonim Şirketi may retain personal data for the limitation periods stipulated in the relevant legislation in order to resolve possible legal disputes, exercise legal rights, protect the right of defence, fulfil legal obligations and respond to requests from competent institutions or organizations. When the retention period expires or the legal grounds requiring the processing of personal data cease to exist, personal data is deleted, destroyed or anonymized in accordance with Law No. 6698 on the Protection of Personal Data and the relevant legislation. 13. Rights of the Data Subject Pursuant to Article 11 of the KVKK, users have the right to: • learn whether their personal data is being processed, • request information if it has been processed, • learn the purpose of processing and whether the data is used in accordance with that purpose, • know the third parties to whom the data is transferred within or outside Turkey, • request the correction of incomplete or incorrectly processed data, • request the deletion or destruction of the data, • request that these operations be notified to third parties to whom the data has been transferred, • object to an adverse outcome arising from analysis carried out by automated systems, • claim compensation for damage arising from unlawful processing. To exercise these rights, you may apply to the Company or submit your request through the communication channels announced by the Company. Applications are evaluated within the procedures and periods set out in the KVKK and the relevant secondary regulations. 14. Cases Requiring Explicit Consent Where explicit consent is required for marketing, behavioural analysis, user profiling, third-party advertising technologies, non-essential cookies and similar processing, separate consent based on free will is obtained from the user. Withholding explicit consent or subsequently withdrawing it affects only processing activities that rely on explicit consent; it does not automatically terminate processing that is mandatory within the scope of performance of the contract, legal obligation or legitimate interest. 15. Third-Party Links and Services The Soloscore application or website may contain links belonging to third parties, embedded content, social media tools, payment infrastructures or external service providers. While the data processing activities of these third parties are subject to their own policies, the Company is obliged to take appropriate legal and technical measures for the integrations under its own control. The user agrees to review the privacy and cookie policies of the relevant provider before using third-party pages or services. 16. Updating of the Policy This Privacy Policy may be updated in the event of legislative changes, Board decisions, technical infrastructure changes, the addition of new services or changes to data processing purposes. The current text is published through the application and the website. Significant changes may also be notified to the user by appropriate methods. 17. Third-Party Links and Limitation of Liability The Platform may contain links directing users to third-party websites, applications or services. The content on such websites, applications or services, together with their privacy practices and data processing activities, are the responsibility of the relevant third parties, and Soloscore Teknoloji Anonim Şirketi has no control or responsibility in this respect. Users are advised to review the privacy policies and terms of use of the third-party platforms to which they are directed. Within the scope of the processing and use of personal data in accordance with the procedures and principles set out in this Privacy Policy, and without prejudice to its responsibilities arising from applicable legislation, Soloscore Teknoloji Anonim Şirketi cannot be held liable for direct or indirect damages not arising from its own fault. Users are obliged to check the compliance of the services they access through third-party links with the legislation in force in their own country. Soloscore Teknoloji A.Ş. accepts no legal, administrative, criminal or financial responsibility arising from betting, gaming, payment, membership or similar transactions carried out by users on third-party platforms. The Platform is not the operator, provider, representative or marketer of any betting, gambling, game of chance or similar activity. Third-party links that may appear on the Platform are of a technical redirection nature only, and the Platform has no editorial control over the content of those links. The Platform reserves the right to remove immediately any links to websites or services found to be operating contrary to applicable legislation, and this cannot be interpreted as supporting, encouraging or intermediating such activities. 18. Changes to the Privacy Policy All users and members who benefit from the Platform are deemed to have declared that they have read, understood and accepted the provisions of this Privacy Policy. Soloscore Teknoloji Anonim Şirketi reserves the right to update, amend or repeal this Privacy Policy without prior notice in line with legislative changes, technical requirements or changes in its services. The current Privacy Policy enters into force on the date it is published on the Platform. Users and members are advised to follow the current text regularly. Contact: support@soloscore.com.tr