Sosyo Plus Bilgi Bilişim Tekn. Dan. Hiz. Tic. A.Ş., along with our affiliates and group companies, (collectively, “Insider”) knows how important privacy is to our customers and wish to ensure you are informed about the manner in which we collect, use and share your personal data. The protection of your privacy is of the utmost importance to us, so it goes without saying that we comply with the legal stipulations on data protection.
In this notice, “Insider,” “our”, “we” or “us” refers to the organization of the member firms of Insider, each of which is a separate legal entity, or refers to one or more of those group companies. The controllers of your personal data are one or more of the Insider group companies listed here:
- Insider SG PTE LTD (Singapore)
- Insider PTE LTD (Singapore)
- Sosyo Plus Bilgi Bil. Tekn. Dan. Hiz. Tic. A.Ş.
- Insider Digital Sdn Bhd ( Malaysia)
- Insider AU PTY LTD (Australia)
- Sociya Plyus LTD
- Insider RU FAO (Russia Branch)
- Insider Polska sp z o.o (Poland)
- Insider Korea
- Insider Japan 株式会社
- Insider Services UK Limited (The United Kingdom)
- Insider Benelux B.V. (The Netherlands)
- Insider HK LTD (Hong Kong)
- Insider France
- Insider Spain
- Insider Services US LLC
- Insider Brazil
- Insider (Thailand) Co., Ltd.
- Insider DMCC
- Insider Cross-Channel Marketing Technologies GmbH
- Insider Chile
The following privacy notice (the “Privacy Notice“) sets out our policy for processing your personal data that we collect through our website at https://www.useinsider.com (“Website”)
Name and Contact Details of the Responsible Party
Sosyo Plus Bilgi Bilişim Tekn. Dan. Hiz. Tic. A.Ş.
Represented by Hande Çilingir
Sultan Selim Mah. Libadiye Sk. No:3/1 Kağıthane İstanbul
Data Protection Officer
Should you have any questions about our data protection measures, the processing of your data or the protection of your rights as a data subject, you can contact us and our data protection officer as follows:
External Data Protection Officer
represented by Prof. Dr. Christoph Bauer
Große Bleichen 21, 20354 Hamburg
If you have any questions or concerns regarding your information, please contact firstname.lastname@example.org.
If you wish to communicate directly with our data protection officer (for example, because you have a particularly sensitive matter), please contact them by post, as communication by e-mail can always have security gaps. Please state in your request that your concern relates to the company Sosyo Plus Bilgi Bilişim Tekn. Dan. Hiz. Tic. A.Ş.
Representative of Controllers or Processors Not Established in The Union (Article 27 GDPR):
Certain Insider group companies in countries outside the European Union (EU) have appointed a representative in the EU to act on their behalf if, and when, they undertake data processing activities to which the EU General Data Protection Regulation (“GDPR”) applies. Further information and the contact details of these representatives are as below/here:
- Insider Benelux B.V.
Represented by Hande Çilingir
Sultan Selim Mah. Libadiye Sk. No:3/1 Kağıthane İstanbul
Insider and its group companies are subject to GDPR compliance due to the field of their activities. Your Company is responsible for making an assessment on whether your company is also obliged to comply with the GDPR within the framework of the service provided via Insider services.
In this context, the liability arising from any legislation, especially GDPR, due to incomplete or incorrect assessment of whether you are subject to the GDPR, will not be attributed to Insider and will be yours.
Insider marketing subscription
Type of Information We Collect
We process personal data for a variety of purposes which are stated below. Personal data is all information about an identified or identifiable person. This includes the following categories of personal data that we process:
- Your contact details (such as first and last name, address, e-mail address, phone number)
- Your correspondence with us
- Log files with information about your visit to our Website
- Online identifiers (such as cookie IDs, IP addresses, unique device identifier advertising IDs)
- Individuals who visit our social media sites, social media plugins and tools
- Job applicants
- Usage, viewing, technical, and device data when you visit our sites, use our tools, or open emails we send, or connect with our wireless Internet access services and other similar technologies.
Please note that we ask you not to send us or disclose any special category of personal data on or through our Website or otherwise to us.
For Which We Process Your Data
We process your data for the following purposes:
- To respond to your inquiries, questions and comments and fulfil your requests.
- To send administrative information to you, such as for example information regarding the Website, changes to our terms and conditions, and changes to this Privacy Notice.
- Data analytics pertaining to your activity on the Websites
- Provide you with the experiences, products, and services you request, view, engage with, or purchase
- Send you offers and promotions for our products and services
- For advertising purposes such as the dispatch of our newsletter
- On quality assurance and statistics
- In order to provide our service
- For your participation in our competitions
- For your participation in our events
- For your participation in our surveys
- To consider your job application
- Operate, understand, optimize, develop, or improve our Website
- Detect, investigate and prevent activities that may violate our policies, be fraudulent or illegal
- Notify you of product recalls or safety issues.
- In order to improve our service
We never process our Partner’s customer data for profiling purposes.
We will ensure that your consent is freely given, specific, informed and unambiguous and the processing of your information, whether based on consent or any other legal ground, satisfies the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, and confidentiality. Where personal information is collected and further processed based on consent, you may withdraw your consent at any time. However, the withdrawal of consent won’t affect the lawfulness of such processing before your withdrawal.
You may exercise your right to be forgotten where your personal information is no longer necessary, your consent has been effectively withdrawn, you have objected to the processing, or your personal information has been unlawfully processed, has to be erased under a legal obligation or it relates a child being offered information society services. Where the processing is based on your consent or for the performance of a contract you may exercise your right to data portability in respect of data you have provided to us.
Our systems may associate your personal information with your activities in the course of providing you more enhanced services such as behavioral targeting and personalization (from pages you view, links you click on or items you search for).
Insider Website uses “cookies”, which are small text files containing a unique identifier that we, or one of our partners, or even a third-party analytics provider, transfer to your computer through the web browser you use. Cookies help us understand our visitors’ interests, so we use that information to improve our services and our Website.
You can block cookies at any time by changing the setting in your internet browser and by rejecting our Website cookies once you enter our Website.
In order to meet our professional and legal requirements, to establish, exercise or defend our legal rights, and for archiving and historical purposes we need to retain information for significant periods of time.
We store your data,
- if you have consented to the processing, at most until you revoke your consent;
- if we need the data for the execution of a contract, at most for as long as the contractual relationship with you exists;
- if we use the data on the basis of a legitimate interest, at most for as long as your interest in deletion or anonymisation does not outweigh the data;
- insofar as statutory storage obligations exist, until the end of the storage periods.
Insider discloses your personal data (i) where this is appropriate for the purposes described in the section “FOR WHICH WE PROCESS YOUR DATA,” including within the Insider Group Companies itself, (ii)if required, by applicable law, (iii) in connection with a reorganization or combination of Insider, (iv) if we believe that such disclosure is appropriate to enforce or apply terms of engagement, and other agreements, (v) in order to comply with a judicial proceeding, court order, regulatory inquiry or other legal obligation and (vi) with your explicit consent
Third-party recipients of personal data include:
- Facebook Custom Audience
- Facebook Lookalike Audience
- Google Ads
- Google AdSense
- The courts, police and law enforcement agencies (if requested)
- Government departments and agencies (if requested)
When processing your data, we work together with the following service providers who have access to your data:
- Provider of web analysis tools
- Web hosting and web development providers
- Service provider for IT development services
- Marketing and advertising agencies
- E-mail and newsletter provider
- Service provider for editing and translations
- CRM system service provider
- Cloud services
- Conference and Webinar Software
- Service provider for online surveys
- Service provider for chat software
- Social media platforms
- Professional advisors, such as law firms, tax advisors or auditors
- Audit regulators
Transfer to Third Countries
Data is being transferred to countries outside the European Economic Area. We only transfer personal data to third countries where the EU Commission has confirmed an adequate level of protection or where we can ensure the careful handling of personal data by means of contractual agreements or other suitable guarantees, such as certifications or proven compliance with international security standards.
- TURKEY (Cryptology and the SCC for further information please see technical organizational measure document of Insider are defined in a separate document)
- S. (Cryptology and the SCC for further information please see technical organizational measure document of Insider)
As Insider is a B2B company we will only accept requests on conditions where we are responsible for data. As a data subject, you have the following rights:
- To request information about the processing of your data, as well as to receive a copy of your personal data. You may request information on, among other things, the purposes of the processing, the categories of personal data processed, the recipients of the data (if a transfer is made), the duration of the storage or the criteria for determining the duration;
- To receive personal data relating to you in a structured, common and machine-readable format or to transfer it to another person in charge
- To correct your data. If your personal data is incomplete, you have the right to complete the data, considering the purposes of the processing;
- To have your data deleted or blocked.
- To have the processing restricted;
- To object to the processing of your data;
- To revoke your consent to the processing of your data for the future and
- To complain to the responsible supervisory authority about unauthorized data processing.
We might share anonymized behavioral data
We generally do not share any personally-identifiable information (such as name, country, and email) with third party service providers and external websites. But we might share anonymized behavioral data.
Legal Basis of Data Processing
We base the processing of your data on the following legal bases:
- Your consent, if you have given us such consent (Art. 6 para. 1 lit. a) GDPR)
- The initiation or execution of a contract with you (Art. 6 para. 1 lit. b) GDPR)
- The implementation of our legitimate interests (Art. 6 para. 1 lit. f) GDPR)
When processing your data, we pursue the following legitimate interests:
- The improvement of our offer
- Protection of our systems against misuse
- On the production of statistics
- For the storage of our correspondence with you