PARATICA PRIVACY POLICY

Paratica Bilişim Danışmanlık ve Finansal Hizmetler A.Ş (hereinafter also “Paratica”, “we”, “us”), a joint stock company registered in Turkey with the MERSIS number 0721074131000001 in ISTANBUL TRADE REGISTRY OFFICE and incorporated and registered in Kordonboyu Mah. Ankara Cad. 147/A İstmarina Konutları S1 Kule Kat:24 D:300 Kartal/İSTANBUL, cares about your privacy and personal information and takes its data protection, privacy, and confidentiality responsibilities seriously. Our goal is to provide you with an automatic trade and strategy bot where you, cryptocurrency investors, can build, customize and personalize your own strategy.

This Privacy Policy (“Policy”) aims to explain how we collect, use, store, share and protect your personal information in the course of our business activities and inform you about your rights related to personal information.

1. Personal Data We Collect

We may collect and process your personal data such as:

  • Identity information including your name, surname, username, TR Identity Number,
  • Contact information including your e-mail address, phone number, and social media accounts,
  • Geolocation information including your residential address,
  • Financial information including your balance information, buying and selling values, payment method and payment amount,
  • Visual information including your photos,
  • Customer transaction information including your transaction history, transaction details, instructions such as numerical indicators that you use when trading cryptocurrencies, your request, and complaints,
  • Process security information including your password, Application Programming Interface (API) information,
  • Marketing information including cookie records.

2. Collection Methods Of Your Personal Data

We collect your personal data in several ways, including:

  • Directly from you via e-mail, telephone or website,
  • From exchange platforms,
  • From our own records of how you use our services,
  • Through other electronic and physical environments.

3. Use of Your Personal Data

We may use your personal data to:

  • update, customize and develop our products and services in accordance with your needs and demands,
  • review your requests, suggestions, and complaints regarding our service;
  • fulfill contractual obligations to you and anyone involved in the process;
  • identify and resolve errors, problems, or bugs in our products and services;
  • comply with our legal and regulatory requirements, respond to requests from public and government authorities, including authorities outside your country of residence, and meet national security or law enforcement requirements;
  • detect prevent and fight fraud and other illegal, criminal activities;
  • confirm whether you are a verified user;
  • provide our products and our services to you;
  • manage our customer and user relationships;
  • conduct refunds upon request of the user paying with credit card;
  • provide KVKK services for our services;
  • conduct marketing activities and marketing analysis by showing advertisements through various channels,
  • perform trading transactions of users on the exchange platforms;
  • determine the strategy in which the user runs its algorithmic bot.

4. Legal Basis for Processing of Your Personal Data

We collect and process your personal data on the following bases which are stated in Article 6(1) of the GDPR:

  • You have given consent to the processing of your personal data for one or more specific purposes,
  • Processing is necessary for the performance of our contract,
  • Processing is necessary for compliance with a legal obligation to which we are subject,
  • Processing is necessary for the purposes of our legitimate interests pursued by the controller or by a third party, provided always that such interests are not overridden by your interests or fundamental rights and freedoms which require the protection of personal data.

5. Disclosure of Your Personal Data

We may disclose your personal data for the purposes mentioned in Section 3 to third parties (e.g. our representatives, suppliers, business partners, legally authorized persons and institutions, public authorities). Please note that we will never sell your data to a third party.

For instance, we may share your personal data

  • with public authorities, legally authorized persons, and institutions for complying with our legal obligations;
  • with our suppliers for marketing and sales activities, mailing activities, sending newsletters, targeting activities, serving relevant ads for you, improving our website.

We may also, pursuant to a valid legal process (such as a search warrant, subpoena, or court order), allow access to information in our possession in order to comply with such process and to protect our rights and property. We reserve the right to disclose any data or information obtained from or about you, to third parties in connection with a merger, acquisition, bankruptcy, or sale of all or substantially all of our assets, to the extent that this is necessary for the process.

Since we operate on a global basis, your personal data may be transferred and stored outside of the European Economic Area. In such event, we systematically ensure the application of an adequate level of protection of such data by means approved by applicable data protection legislation. You may request a copy of such measures by getting in touch with us through the contact details below.

6. Security of Your Personal Data:

In order to prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.

Some of the measures we take include:

  • Protecting our data servers with state-of-the-art anti-virus programs and similar software;
  • Limiting and recording physical access to our premises and facilities;
  • Limiting and recording access to our data servers;
  • Preparing and organizing corporate policies on access, information security, usage, retention, and disposal;
  • Placing confidentiality requirements on our staff members and service providers;
  • Conducting awareness training on data privacy for employees;
  • Destroying or permanently anonymizing personal data when it is no longer needed for the purposes for which it was collected;
  • Following strict security procedures in the retention and disclosure of personal information to prevent unauthorized access to it;
  • Using two-factor authentication for transactions;
  • Using secure communication transmission software that encrypts all information you input on our website before it is sent to us.

7. Your Rights

If you are from the European Economic Area or in certain countries, you are also entitled (with some exceptions and restrictions) to:

  • Access: You have the right to request information about how we process your personal data and to obtain a copy of that personal data.
  • Rectification: You have the right to request the rectification of inaccurate personal data about you and for any incomplete personal information about you to be completed.
  • Objection: You have the right to object to the processing of your personal information, which is based on our legitimate interests (as described above).
  • Deletion: You can delete your account by using the corresponding functionality directly on the service.
  • Automated decision-making: You have the right to object a decision made about you that is based solely on automated processing if that decision produces legal or similarly significant effects concerning you.
  • Restriction: You have the right to ask us to restrict our processing of your personal data so that we no longer process that personal data until the restriction is lifted.
  • Portability: You have the right to receive your personal data, which you have provided to us, in a structured, commonly used, and machine-readable format and to have that personal data transmitted to another organization in certain circumstances.
  • Complaint: You have a right to lodge a complaint with the authorized data protection authority if you have concerns about how we process your personal data. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work, or where we are established.

You may, at any time, exercise any of the above rights, by contacting us via [email protected] together with proof of your identity, i.e. a copy of your ID card, or passport, or any other valid identifying document.

In some cases, we may not be able to give you access to the personal data that we hold, if making such a disclosure would breach our legal obligations to our other customers or if prevented by any applicable law or regulation.

8. Residents of the State of California (USA)

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights in relation to their personal information, subject to limited exceptions. For personal information collected by us during the preceding 12 months that is not otherwise subject to an exception, California residents have the right to access and delete their personal information.

We will not discriminate against any customer that asserts their rights under the CCPA. We will not: (1) deny you goods or services; (2) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (3) provide you a different level of qualify of goods or services; or (4) suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services.

If you are a California resident, you have the right to request certain information from us regarding our information-sharing practices with third parties for direct marketing purposes. To the extent that we share your personal information for direct marketing purposes, you may receive the following information: (1) the categories of information and sources of information that we disclosed to third parties for direct marketing purposes during the preceding year; and (2) the names and address information of third parties that received such information, or if the nature of their business cannot be determined from the name, the examples of the products or services marketed.

To the extent that we sell your personal information to third parties, you also have the right to request that we disclose to you: (i) the categories of your personal information that we sold, and (ii) the categories of third parties to whom your personal information was sold. You also have the right to direct us not to sell your personal information.

California residents may also designate an authorized agent to make a request to access or delete on your behalf. Your authorized agent must submit proof that you have provided them with power of attorney pursuant to Probate Code sections 4000 through 4465. We may deny a request from a purported authorized agent who does not provide proof of authorization to act on your behalf.

9. Right to Withdraw Consent

If you have provided your consent to the collection, processing, and transfer of your personal data, you have the right to fully or partly withdraw your consent. To withdraw your consent please contact us via [email protected]

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights, and freedoms or for the establishment, exercise or defense of legal claims.

10. Collection of Children’s Personal Data

Paratica can be used only by users at or above the age of 18. Therefore, we strive to not collect personal data of any children under the age of 18. We do not collect any personal data of anyone under the age of 18. If you have any concerns about your child’s privacy with respect to our services, or if you believe that your child may have provided his/her personal data to us, please contact us using the details provided below. We ensure to delete such personal data from our records immediately.

11. Retention of Your Personal Data

We will only retain your personal data for as long as necessary to fulfill our collection purposes, including for the purposes of satisfying any legal, accounting, or reporting requirements, and where required for our company to provide services, until the end of the relevant retention period. Additionally, we must keep personal data as evidence both to prove our compliance to law and to use it in a legal dispute. Furthermore, we will retain personal data in order to prevent banned users that violate our terms of use not to create a new account.

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 unauthorized 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. Upon expiry of the applicable retention period, we will securely delete, destroy or anonymize your personal data in accordance with applicable laws and regulations.

12. Changes to Our Privacy Policy

We may update and change this Policy from time to time, as we may find necessary and as our site evolves and grows. We will inform you of any significant changes that occurred in this Policy. Your continuing use of this site constitutes an acknowledgment of any changes in this privacy statement.

13. Contact Us

If you have any questions or concerns about our privacy practices or would like to exercise any of the rights mentioned in this Privacy Policy, please contact us via [email protected]