Withbuff Privacy Policy
WITHBUFF, a company established under the laws of NETMARBLE EMEA FZ LLC. is strictly adhering to the Law No. 6698 on Personal Data Protection Law, General Data Protection Rules (GDPR) and other applicable regulations and recognize the importance of a secure environment for the information we collect. Henceforth, we see the importance in providing an on-line, open access set of rules and regulations for how and when we collect your personal data (as defined under Law No.6698 and other applicable regulations) as well as how we process and utilize them. In this Privacy Policy, we explain to you how we secure and safeguard the privacy of the data provided by you. This Policy is an integral part of the End User License Agreement (“User Agreement”).
By using this application or related website(s) or any other WITHBUFF’s platforms (together “platforms”), as applicable, you accept this Privacy Policy and explicitly consent us under Law No. 6698 to proceed of your personal data in accordance with this Privacy Policy. In the scope of this Policy, “proceed” or “process” means any operation which is performed upon your personal data such as collection, recording, storage, preservation, alteration, adaptation, disclosure, transfer, retrieval, making available for collection, categorization or blocking its use by wholly or partly automatic means or otherwise than by automatic means which form part of a filing system.
Please note that WITHBUFF Privacy Policy does not apply when you access other sites, applications, mediums or programs via the web links located on WITHBUFF platform, as we have no control over the activities of these other sites. Furthermore, this Privacy Policy may vary from time to time through the Platforms. We have no obligation to notify you of any changes hence please consult this document periodically so that you are aware of any changes. The platforms will always publish the latest version of this Privacy Policy.
This Privacy Policy respects all applicable laws on privacy and data protection.
Collection of Data
By using any features of the WITHBUFF’s through the platforms, you accept and agree that WITHBUFF proceeds personal data that is usable for personal identification. WITHBUFF collects only the information that is permitted by law (i) when you voluntarily share such information with us while using the platforms, and (ii) automatically in accordance with the purposes stated in the Policy, while you are using the services on the Platforms.
WITHBUFF may request that you submit certain personal data, including your name, your telephone number, your address, your email address, your age, your date of birth, social media information and/or payment details (such as credit card number, expiry date and verification code) and update this requested information should a change occurs. We may also proceed the information that your computer or mobile device provides to us in connection with your browser type, computer type, or your use of the service, such as mobile device, browser language, or IP address; or usage or profiling information such as search history, the time you spend in or platforms, links you have clicked; or preferences information such as your selected preferences associated with your WITHBUFF account; communications information such as help requests or queries via e-mail and other electronic methods or other social media details as applicable.
You may be unable to access certain areas of the platforms or use certain features, such as the forums, without registering, or receive certain materials such as our information bulletins without providing a certain amount of personal data.
For users that do more than browsing, WITHBUFF may request other data such as your valid credit card number and credit card expiration date. WITHBUFF does not store this additional information unless consented by the user.
WITHBUFF also processes your personal data as anonymous data in order to analyze and produce statistics related to the habits, usage patterns, and demographics of users as a group or as individuals. Such anonymous data does not allow the identification of the users to which it relates. WITHBUFF may share anonymous data with third parties without your consent.
Storing your Personal Data
WITHBUFF stores the data provided by you in a safe and secure way and takes all the necessary precautions to prevent unauthorized access or collection of the information you have shared, as is required by law.
We keep your personal data only for as long as we need to in any case within the time period specified in the applicable law and regulations. This depends on why it was collected, or if we have a continuing legal basis to do so (such as to fulfill a contract between us, perform a service you requested or for our legitimate interests). If we no longer have a reason or legal requirement to process your personal data, we will delete it or store it in a way so that it no longer identifies you.
WITHBUFF may require you to update certain information from time to time, WITHBUFF will make the necessary changes in this Privacy Policy and the User Agreement in order to ensure the conformity of these documents and the new rules and regulations with the information you provide.
Use of Personal Data
WITHBUFF respects your right to privacy and only processes your information in accordance with the applicable data protection law in Turkey and European Union. WITHBUFF uses your personal information internally to increase the quality of service, deliver and improve products which the users have signed up for and to maximize our customer satisfaction. Whereas WITHBUFF may share your personal data to third parties under contract with WITHBUFF such as order or payment processors or other service providers, located in and outside the European Union, to access and use personally identifiable information, but only to the extent necessary to provide those services.
Additionally, WITHBUFF may use your personal data to improve or optimize our services, protect our legitimate interests, for fraud prevention, product enchantment or to personalize our services, generate internal statistics for marketing, consumer profiles or demographic research to tailor our products and services to satisfy your requirements. Where we process your personal data based on a legitimate interest we will only do so where the processing is relevant, adequate and limited to what is necessary for the purpose it was collected for.
If you use a service provider and provide a personal or any other data for the payment of the purchased content, you acknowledge and agree that you are the sole responsible from the accuracy, completeness of this data and any other material or non-material issues, losses, damages, etc. rising from this data or its transaction.
With Whom Your Information is Shared
We share your information, only where you ask to us, where it is necessary part of doing business with you and providing you with the services or where you need to for legal reasons. To this respect, WITHBUFF may channel this data to third party vendors as a response to a product order or to add you to a commercial bulletin circulation list or certain parts of the information WITHBUFF collects will be shared with other users of WITHBUFF for profile displaying purposes that the information that will be displayed in your profile will be your choice.
We share information relating to our users with our affiliates or subsidiaries on a need to know basis and with selected third party service providers in Turkey or in abroad who provide us with a variety of different services that support the delivery of our services by complying with the applicable laws. These service providers range from providers of technical infrastructure to customer service and authentication tools. We require any service providers which handles information on our behalf to do so pursuant to contractual terms which require that the information is kept secure, is processed in accordance with applicable data protection laws, and used only as we have instructed and not for that service provider’s own purposes (unless you have explicitly consented to them doing so).
External websites and companies may reach your personally identifiable information via links to and from WITHBUFF platforms. These websites and companies reach beyond the extend of this Privacy Policy and cannot be applied to those websites and companies. Please refer directly to the privacy policy of the relevant websites and companies.
WITHBUFF may release personally identifiable information to comply with court orders or laws that require us to disclose such information without your consent. We may also disclose your information if necessary to prevent, detect or prosecute illegal or suspected illegal activities, including fraud, or to prevent other damage or where necessary in response to legally binding requests, legal action against us, or to enforce our rights and claims.
Due to the enforcement of the Terms of Use or other agreements or in the event of a reorganization, sale or merger we may transfer personally identifiable information to the relevant third party with the user’s consent if required by law.
Your Rights
WITHBUFF gives the users the right to observe the way in which the personal information is used by WITHBUFF. WITHBUFF may send you promotional e-mails, newsletters, information bullets etc. which contain an internal mechanism to unsubscribe from these. Where we process your personal data based only on your consent, you can withdraw this consent at any time either by using the functionality provided within the appropriate product feature or by contacting us on https://netmarble.zendesk.com/hc/tr.
You have the absolute right to contact us and request to change the way your personal information is used. However, if you wish to remove the minimum personal detail required by WITHBUFF, please note that WITHBUFF may re-request the missing information from you in order to proceed with your interactions on the platform.
The Level of Security
WITHBUFF gives highest importance to the personally identifiable information as well as its integrity and safekeeping. Thus, we make sure that the data provided by you is unaltered and kept safely in our high security databases in which access to any information is strictly monitored. Furthermore, we will do our utmost to ensure that the third parties to whom we may forward this information provide sufficient guaranties of security with regard to this personal information.
Children Data Protection
Minors under 16 years of age should not enter into transactions enabling WITHBUFF to receive their personal data, sign into or use the platforms, order or subscribe to any paid service on-line without the permission of their parents or guardians. We would ask parents and guardians to be particularly vigilant and to ensure that their minors do not transgress when using our sites or on-line services.
Visiting, downloading content and/or using the WITHBUFF Platforms and using our on-line services indicates your acceptance of WITHBUFF Privacy Policy. If you do not accept this Privacy Policy, please do not visit our platforms or use our on-line services.
