# Personal Data Protection Law Information Text

## 1. Data Controller and Representative

Pursuant to the Personal Data Protection Law No. 6698 ("PDPL"), in our capacity as data controller, we may process, record, store, classify, update and transfer to third parties your personal data within the scope of the purposes explained below, in accordance with the law and principles of good faith.

Data Controller:

- Email: caemobile@yandex.com

## 2. Purpose of Personal Data Processing

Your personal data is processed for the following purposes:

- Primary Purposes:
  - Execution and management of membership processes
  - Creation and management of user accounts
  - Provision and development of platform services
  - Improvement of user experience
- Security Purposes:
  - Ensuring platform security
  - Prevention of fraud and misuse
  - Age verification and controls
  - Account security
- Communication Purposes:
  - Providing user support services
  - Sending information and announcements
  - Managing user complaints
- Legal and Administrative Purposes:
  - Fulfillment of legal obligations
  - Communication and reporting with official institutions
  - Management of legal processes

## 3. Categories of Personal Data Processed and Collection Methods

The following personal data is collected through the specified methods:

- Automatically Collected Data:
  - IP address and location information
  - Device information and identifiers
  - Usage statistics and log records
  - Data collected through cookies and similar technologies
- User-Provided Data:
  - Identity and contact information
  - Profile information and photos
  - User preferences and interests
  - Messaging contents
- Data from Third Parties:
  - Social media integrations
  - Identity verification services
  - Security checks

## 4. Transfer of Personal Data

Your personal data may be transferred to the following recipient groups within the framework of personal data processing conditions specified in Articles 8 and 9 of the PDPL:

- Domestic Transfer:
  - Authorized public institutions and organizations
  - Judicial and administrative authorities
  - Service providers and business partners
  - Audit and consulting companies
- International Transfer:
  - Cloud service providers
  - Analytics service providers
  - Security service providers

## 5. Rights of the Data Subject

Your rights under Article 11 of the PDPL:

- Basic Rights:
  - Learn whether your personal data is being processed
  - Request information if your personal data has been processed
  - Learn the purpose of processing and whether data is used in accordance with the purpose
- Correction and Deletion Rights:
  - Know the third parties to whom your personal data is transferred
  - Request correction of incomplete or inaccurate data
  - Request deletion or destruction of your personal data
- Objection and Complaint Rights:
  - Object to adverse results about you analyzed through automated systems
  - Claim compensation for damages due to unlawful processing of personal data

## 6. Data Security

The following measures are taken for the security of your personal data:

- Technical Measures:
  - Firewalls and antivirus software
  - Encryption and masking methods
  - Access log records and auditing
  - Backup and disaster recovery plans
- Administrative Measures:
  - Staff confidentiality agreements
  - Regular training and audits
  - Data processing policies
  - Risk analysis and assessments

## 7. Application and Communication

To exercise your rights under PDPL, you can apply through the following methods:

- Application Methods:
  - Email: caemobile@yandex.com
- Application Process:
  - Applications are responded to within 30 days
  - Additional information and documents may be requested
  - Applications are free (fees may be charged for detailed or repetitive requests)

## 8. Changes and Updates

This information text may be updated in line with legal regulations and company policies. You will be informed about significant changes.

Last updated: 2025