A. About Us
Pairextr Yazılım ve Teknoloji A.Ş. (the “Pairextr” or the “Company” ) is a joint-stock company incorporated in Turkey with a trade registry number 241113 and having a registered office at MANSUROĞLU MAH. 288/6 SK. NO: 4 İÇ KAPI NO: 112 BAYRAKLI/ İZMİR, Turkey. The company is an international organization providing services in relation to the purchase, sale and marketing of certain cryptocurrencies in compliance with the applicable laws and organizing auctions in these fields ( “Services” ).
B. About This Legal Disclosure
This Legal Disclosure has been prepared to fulfill our legal responsibilities and obligations arising from the Personal Data Protection Law No.6698 ( “Law” ) and other legislation and it is an integral part of the User Agreement executed between Pairextr and the user registered at www.pairextr.com ( “Internet Address” ). In accordance with Article 10 of the Law, we would like to inform you with this Legal Disclosure about how we collect, process, store and share your personal data as a data controller and the legal rights you have regarding your personal data.
We respect your right to privacy and take our responsibilities seriously in relation to the processing of personal data. We do not process any of your sensitive personal data. We do not collect or process personal data unnecessarily. By subscribing to the Internet Address, you declare and accept that you have read the User Agreement and this Legal Disclosure and accept them in advance.
C. Data Controller – Processing Personal Data
Unless we have entered into a different agreement with you, as Pairextr, we will act as a data controller. We process, transfer, store, and delete personal data which includes ID data, contact data, customer transaction data, transaction security data, risk management data, finance data, marketing data and audio-visual data submitted to us by our employees, employee candidates, former employees, Company shareholders, Company officials, customers receiving services and potential customers, supplier employees and supplier executives in accordance with the Law. Your personal data can be processed, recorded, stored, classified, and updated in accordance with the law and good faith for the following purposes and it can be disclosed/transferred to third parties limitedly by the regulation and/or for the purpose for which they are processed.
D. Processing and Purpose of Personal Data
Your personal data may be processed verbally, in writing, or electronically, through automated or non-automated methods depending on the commercial activities of Company, through the Company’s units and offices, www.pairextr.com the Website, mobile application and similar means.
Your personal data categorized as identity data, contact data, employee / personel data, legal transaction, customer transaction, process security, risk management, finance, marketing and audio visiual data that you shared with Company is processed by the Company in accordance with the basic principles regulated in the Law. Your personal data will be processed by the Company within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law, limitedly for the following purposes:
- Provision of the Services;
- Execution of Emergency Management Processes
- Execution of Information Security Processes
- Execution of Employee Candidate/Intern/Student Selection and Placement Processes
- Execution of Employee Candidates’ Application Processes
- Execution of Employee Satisfaction and Loyalty Processes
- Fulfilment of Obligations Arising from Employment Agreement and Legislation
- Execution of Side Benefits and Interests Processes for Employees
- Execution of Audit/Ethical Activities
- Execution of Training Activities
- Execution of Access Authorizations
- Execution of Activities in Compliance with the Legislation
- Execution of Finance and Accounting Affairs
- Execution of Assignment Processes
- Execution of Loyalty Processes to Company/Product/Services
- Follow Up and Execution of Legal Affairs
- Execution of Communication Activities
- Execution of Internal Audit/ Investigation/ Intelligence Activities
- Planning of Human Resources Processes
- Execution/Audit of Business Activities
- Execution of Occupational Health/Safety Activities
- Execution of Business Continuity Activities
- Execution of Goods/Service Purchase Processes Execution of Goods/Service After Sales Support
- Execution of Goods/Service Production and Operation
- Execution of Customer Relationship Management Processes
- Execution of Activities for Customer Satisfaction
- Management of Organization and Events
- Execution of Performance Evaluation Processes
- Execution of Advertising/Campaign/Promotion Processes
- Execution of Social Responsibility and Civil Society Activities
- Execution of Custody and Archive Activities
- Execution of Agreement Processes
- Execution of Sponsorship Activities
- Execution of Strategic Planning Activities
- Execution of Risk Management Processes
- Execution of Investment Processes
- Ensuring Security of Movable Goods and Resources
- Execution of Custody and Archive Activities
- Tracking of Requests/Complaints
- Execution of Wage Policy
- Execution of Marketing Processes of Products/Services
- Ensuring the Security of Data Controller Operations
- Foreign Personnel Work and Residence Permit Procedures
- Execution of Talent/Career Development Activities
- Informing Authorized Person, Institutions and Organizations
- Execution of Management Activities
E. Transfer of Personal Data
Your personal data can be shared with third-party institutions and organizations such as business partners, suppliers, affiliates and subsidiaries, group companies and authorized public institutions and organizations within the scope of the aforementioned purposes, in accordance with your explicit consent or in other cases regulated in Article 5/2 of the Law and within the framework of personal data processing conditions and purposes set out in Articles 8 and 9 of the Law, in addition to the purposes stated in this text, in order to carry out the commercial activities of our Company, in a limited and measured manner, in order to carry out the commercial activities of our Company
F. International Transfer of Personal Data
Personal Data, by adopting all necessary technical and administrative security measures may be shared and/or transferred to our group companies Pairextr Software & Techology Ltd. and trusted partners and service providers. This is only for the purposes of providing, and in case it is necessary to provide, the Services to you. There are special requirements set out to regulate such data transfers and ensure that adequate security measures are in place to safeguard and maintain the integrity of your transferred data.
For more information please contact us at info@pairextr.com.
G. The Method and Legal Basis of Collection of Your Personal Data
Your Personal Data is processed by either fully or partially automated methods as well as non-automated methods that are part of the data recording system.
The Website uses cookies (the “Cookies” ). Cookies are small text files which are stored by your browser on your computer and are normally used to gather statistical information and to analyze trends of use or access to the Website. Cookies cannot be used to run programs or deliver viruses to your computer. We use cookies to collect such information as IP-addresses, type of operating system, browser type, browser language, the history of queries, data concerning shows of advertising messages, and user’s clicks on them.
Cookies may be used to save your personal preferences, so you do not have to re-enter them each time you access the Website.
Your personal data are processed on the basis of the following legal reasons specified in Articles 5 and 6 of the Law:
- If it is clearly regulated by regulation;
- If it is mandatory for the Company to fulfill its legal obligations;
- If the data processing is directly related and necessary with the establishment or performance of the contract;
- If it is obligatory to operate for the legitimate interest of the Company, provided that it does not harm your fundamental rights and freedom;
- If it is publicized by you;
- If processing is necessary for the establishment, use or protection of a right; or
- If you have explicit consent.
H. Change of Purpose
Your personal data will only be used for the purposes collected by us. However, it must be used for another purpose and if this purpose is compatible with the original purpose, we may also use your personal data for these new purposes. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at info@pairextr.com. If we need to use your personal data for an unrelated purpose, we will notify you by explaining the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with this Legal Disclosure, where this is required or permitted by law.
I. How Long We Keep Your Personal Data
We will only retain your relevant personal data for 10 years to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. This means that the period of time for which we store your personal data may depend on the type of data we hold. In order 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 unauthorised 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. This may vary according to legal requirements or other regulatory requirements in a particular country. For more information about our data retention policies please contact us at info@pairextr.com.
J. Your Legal Rights Under the Law as Data Subject
Regarding the processing of your personal data, by applying to the Company as a data subject, you can use your legal rights below:
- Finding out whether your personal data is processed or not;
- Requesting information on your personal data;
- Finding out the purpose of processing your personal data and whether they are being processed in accordance with their purpose;
- Finding out third parties to whom your personal data transferred domestically abroad;
- Requesting correction of your personal data if it is incomplete or incorrectly processed;
- Requesting that your personal data be deleted within the framework of the conditions regulated in Article 7 of the Law;
- Requesting that the actions made in accordance with subparagraphs (e) and (f) above are notified to third parties to whom your personal data are transferred;
- Objecting to the emergence of a negative result against you by analyzing the processed data exclusively through automated systems; and
- Requesting the compensation of the loss if you suffer a loss due to the processing of your personal data against the provisions of the Law.
You can send your requests and complaints about your personal data to the Company, via info@pairextr.com. You can send your written applications to address MANSUROĞLU MAH. 288/6 SK. NO: 4 İÇ KAPI NO: 112 BAYRAKLI/ İZMİR, Turkey by filling out the form at link. As a personal data subject, if you submit your requests regarding your rights to the Company by the methods set out above in this Privacy Policy, the Company will conclude the request free of charge within thirty days at the latest, according to the nature of the request. However, if a fee is foreseen by the Personal Data Protection Board, it will be charged.
This Legal Disclosure is updated on 19 Jan 2024. In case of any change in the text, the effective date and content of this Statement will be updated.