Privacy Policy

Bilgera Yazilim, AS. (“Company”, “us”, “our”, and “we”) has prepared this Privacy Policy to describe to you our practices regarding the Personal Information (as defined below) we collect from users of our website located at www.bilgera.com (the “Site”), our mobile application (“Application”), and the services and resources available or enabled via the Site and/or Application (together with the Site and Application, the “Services”). So we are clear about the terminology we are using, when we use the phrase “Personal Information” in this Privacy Policy, we mean information that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing information. When we use the phrase “Anonymous Information” in this Privacy Policy, we mean information that is not associated with or linked to your Personal Information. Anonymous Information does not enable identification of or contact with individual persons.
Children. Our Services are not directed to children and children are not eligible to use our Services. Protecting the privacy of children is very important to us. We do not collect or maintain Personal Information from people we actually know are under 13 years of age, and no part of our Services is designed to attract people under 13 years of age. If we later learn that a user is under 13 years of age, we will take steps to remove that user's Personal Information from our databases and to prevent the user from utilizing the Services.
A Note to Users Outside of the United States. If you are a non U.S. user of the Services, by visiting the Site, downloading the Application and/or providing us with information, you acknowledge and agree that your Personal Information may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Information may be less stringent than the laws in your country. By providing your information, you consent to such transfer.
How We Collect Information
Personal Information
In general, the Personal Information we gather enables us to provide the Services to you and helps us learn more about the use of the Services.

Account Information: We collect Personal Information that you submit to us voluntarily at registration and in the course of your use of the Services. In order to use certain features of the Services, we require you to create an “Account”, by providing at least the following information: your name, email address, telephone number, and employer name.
Payment Information: When you order products or services through the Services, we or our third party payment provider will collect payment and billing information in order to process the complete the transaction.
Content: We retain information that you upload to or through the Service. When you upload content (text, images, photographs, videos, voice recordings, messages, comments or any other kind of content that is not your e-mail address) to or through our Services, that information will be stored in our servers and your employer and other users authorized by your employer may be able to see it. When you post or send messages via the Services, the information contained in your message will be stored on our servers and other users may be able to see it.
Location Information: We collect and store information about where you are located, such as by converting your IP address (defined below) into a rough geolocation or through GPS or wireless network triangulation. We may use location information to improve and personalize our Services for you.
Communications: When you communicate with us by sending us an email, we will collect and store any information that is contained in your communications with us.
Other Information: We also collect and store other types of information, including sales and inventory data relating to your products and services or the products and services of a third party, that you provide to us voluntarily. Certain features of the Services may allow users to create customer surveys. Such surveys, and customer responses, that are submitted through our Services are collected and stored by us. We may also collect and store personal information at other points in our Site or Application that state that Personal Information is being collected.

Our Relationship with Third Party Services
The Services may include interfaces that allow the Services to connect with certain third party services (each a “Third Party Service”). We may collect information about you, including Personal Information, from such Third Party Services. In addition, we may supply your Personal Information to such Third Party Services in order for them to perform certain services available via the Services. We may use such information in accordance with this Privacy Policy. We may add this information to the information we have already collected from you via our Services in order to improve the Services we provide. PLEASE NOTE THAT YOUR RELATIONSHIP WITH THE THIRD-PARTY SERVICE PROVIDERS ASSOCIATED WITH THESE THIRD PARTY SERVICES IS GOVERNED SOLELY BY YOUR AGREEMENT(S) WITH SUCH THIRD-PARTY SERVICE PROVIDERS, AND COMPANY DISCLAIMS ANY LIABILITY FOR PERSONAL INFORMATION THAT MAY BE PROVIDED TO IT BY SUCH THIRD-PARTY SERVICE PROVIDERS IN VIOLATION OF THE PRIVACY SETTINGS THAT YOU HAVE SET IN SUCH THIRD-PARTY ACCOUNTS. For the avoidance of doubt, none of the foregoing shall affect our right to use any Personal Information that we collect about you from Third Party Services.

Anonymous Information

We collect the following types of Anonymous Information:
Information Collected by Our Servers. To make our Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, driving logs entered into the Services, documents uploaded to the Services, messages exchanged on the Services, and clickstream data. We use this information to analyze trends, administer the Services, track users’ movements around the Services, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests.
Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services. This type of information is collected to make the Services more useful to you and to tailor the experience with us to meet your special interests and needs.
Pixel Tags. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, which are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Information.
Mobile Device. We may collect information about the computer or device you use to access our Services, including the hardware model, operating system and version, MAC address, phone number, and mobile network information. We use this information to help us deliver the most relevant information to you and to identify and fix bugs and otherwise improve the performance of our Services.

Disclosure – Analytics.
We may use third party analytics services (including, but not limited to, Google Analytics) to help analyze how users use the Services. Analytics services use Cookies to collect information such as how often users open the Services and what features they use in the Services. We use this information to improve the Services. The analytics services’ ability to use and share information collected by them is restricted by their terms of use and privacy policy, which you should refer to for more information about how these entities use this information, and how you can opt-out of their use of such information.

How We Use Information
Personal Information
We will use your Personal Information:
· to provide, develop, and improve Company products and services;
· to respond to comments and questions and provide customer service;
· to send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
· to contact you in order to solicit feedback regarding the Services;
· to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners;
· to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity;
· to facilitate the creation of and secure your Account on our network; and
· to develop and improve marketing and advertising for our products and services and partner products and services.

We may also use your Personal Information to create Anonymous Information records by excluding information that makes the information personally identifiable to you.
Anonymous Information
We use the Anonymous Information we collect to analyze trends, administer and improve the Services, track users’ movements in the App, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the Log Files may be collected so that when you use an Application again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. However, we reserve the right to use Anonymous Information for any purpose.

Aggregate Information
Company shall have the right to aggregate and anonymize any Personal Information and/or Anonymous Information to improve the Services and develop new offerings, and you hereby assign all right, title and interest in and to such aggregated and anonymized information.

How We Disclose Information

Personal Information

We may also disclose certain Personal Information:
· Third Parties Designated by You. When you use the Services, the Personal Information you provide will be shared with the third parties that you and/or your employer authorize to receive such information.
· Third Party Service Providers. We may share your Personal Information with our third party service providers that help us provide Services that we offer you.
· Information Shared with Third Parties. We may sell or otherwise share Anonymous Information with third parties for industry analysis, demographic profiling and other similar purposes.
· Affiliates. We may share some or all of your Personal Information with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), if we have such Affiliates in the future, in which case we will require our Affiliates to honor this Privacy Policy.
· Corporate Restructuring. We may share some or all of your Personal Information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.
· Other Disclosures. Regardless of any choices you make regarding your Personal Information (as described below), we may disclose Personal Information if it believes in good faith that such disclosure is necessary to (a) resolve disputes, investigate problems, or enforce our Terms of Use; (b) comply with relevant laws or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity, in which case we can (and you authorize us to) disclose Personal Information without subpoenas or warrants served on us; or (c) protect and defend our rights or property or the rights and property of you or third parties; and/or (d) investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.

Anonymous Information
We reserve the right to disclose Anonymous Information publicly without restriction.

YOUR CHOICES REGARDING YOUR INFORMATION

· Application. You can stop all further collection of information by an Application by uninstalling the Application.
· Email Communications. We will communicate with you primarily in the form of emails. You can manage the frequency and/or opt out of receiving these communications by clicking the “Unsubscribe” link at the bottom of each email. Please note that even if you unsubscribe or opt-out, we may still send you Services-related communications (e.g., emails related to your Account).
· Cookies. If you decide at any time that you no longer wish to accept cookies from our Services for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser’s technical information. If you do not accept cookies, however, you may not be able to use all portions of the Services or all functionality of the Services.
· Changing or Deleting Your Personal Information. You may review, change, update, correct or delete the Personal Information in your Account by logging into your Account or contacting us. You authorize us to use and disclose any new or modified information that you provide in accordance with this Privacy Policy, and you agree that we are under no obligation to delete or modify information that you have previously chosen to provide us. If you completely delete all of your Personal Information, then your Account may become deactivated, although any content associated therewith will remain on the Services unless you have deleted them. We may also retain an archived copy of your records as required by law or for legitimate business purposes. Please remember, however, if we have already disclosed some of your Personal Information to third parties, we cannot access that Personal Information any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures. Certain information is necessary in order for us to provide the Services; therefore, if you delete such necessary information you may not be able to use the Services. Please note that even though you may request the deletion of your Personal Information by us, we may be required (by law or otherwise, such as to prevent fraud, resolve disputes, troubleshoot problems, or enforce our Terms of Use) to keep this information and not delete it (or to keep this information for a certain time) in which case we will comply with your deletion request only after we have fulfilled such requirements. When we delete Personal Information, it will be deleted from the active database, but may remain in our archives.

Feedback
If you provide feedback to us, we may use and disclose such feedback in accordance with the terms in our Terms of Use, provided we do not associate such feedback with your Personal Information. We may publish user feedback from time to time, provided that we will obtain your consent prior to posting any feedback that is associated with your Personal Information. We will collect any information contained in such feedback and will treat the Personal Information in it in accordance with this Privacy Policy, provided that we may contact you in regards to such feedback.
Information Disclosed to Third Parties
This Privacy Policy addresses only our use and disclosure of information we collect from and/or about you on the Services. If you disclose information to others, or authorize us to do the same under this Privacy Policy, the use and disclosure restrictions contained in this Privacy Policy will not apply to any third party. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable.
The Services may contain content or links to other websites that are not owned or controlled by us. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other websites. When you click on such a link, you will leave our Site or Application and go to another site. During this process, another entity may collect Personal Information or Anonymous Information from you. Please review the privacy policy of any new site you visit.
Third Party Payment Processor
For online payments, we currently use the payment services of Stripe (https://stripe.com/) and PayPal (www.paypal.com). For more information on how payments are handled, or to understand the data security and privacy afforded such information, please refer to https://stripe.com/us/privacy and/or https://www.paypal.com/us/webapps/mpp/ua/privacy-full.
How We Respond to Do Not Track Signals
We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on the Services.
Changes to this Privacy Policy
This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy at https://www.bilgera.com/legal/privacy and we will change the “Last Updated” date above. You should consult this Privacy Policy regularly for any changes.

Contacting Company
If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at: info@bilgera.com.