PRIVACY STATEMENT ON THE PROCESSING OF PERSONAL DATA
Last Updated July 7, 2024

1. Scope

This privacy statement on processing personal data (hereinafter “Privacy Statement”) aims at providing information to real person members who created a membership account on the “Asktrology” mobile application and/or the associated website/ mobile internet site (hereinafter referred to as “Application” collectively) and/ or log in the application as an online visitor without becoming a member of the application (hereinafter referred to as “Members” collectively) about the subjects related to processing their personal data under the scope of the Law on the Protection of Personal Data

When the member logs in the Application as an on-line visitor and/or becomes a member to the Application, s/he agrees, declares and undertakes that s/he has read and understood this privacy statement and that s/he was informed concerning the issues related to personal data in line with the provisions of law and the related legislation.

2. Data Controller

Vera International Technology Inc. (“Company”) with the registered address at 100 King St. W Suite 5700 PO Box 214 Stn 1st Can Place Toronto, Ontario Kanada acts as the “data controller” concerning the personal data belonging to the Member.

3. Personal Data That May be Collected By The Company

3.1. Identity Details: Name, surname, gender, place of birth, date of birth, time of birth
3.2. Contract Details: Email address, mobile phone
3.3. Financial Data: Invoice details
3.4. Member Transaction Data: Member’s movements, browsing and clicking history on the Application, purchasing and payment information on the Application, comments, evaluations and scores, written and visual meetings made by the Member with the astrologers/(AI) relationship advisor over the Application and/or the questions asked to them, pages viewed by the Member over the Application, purchasing and payment history, written communications made with the Application support team, messages/questions written on the support or communication forms on the Application and/or various forms and areas, all kinds of personal information shared by the Member over the Application, exchange of messages between the Members including text, audio and visual contents
3.5. Process Security Data: IP Address /Port Information, Application Log in & Log out information, User Name Details, Password information, Traffic Data (Connection Time/ Duration, etc.), the device logged in, operating system, browser and mobile application version information
3.6. Visual and Audio Data: Photographs and video records of the talks made with the astrologers; photographs uploaded for the profile of the member
3.7. Location Data: Location data and Geolocation data if consented by the Member.
3.8. Profile Data: Interests, preferences and sexual orientation data.
3.9. Marketing, Survey and Research Data: Surveys run by the Application for research and marketing purposes.
4.0. Third-Party Data: Information about other people shared by the Member in order to use a specific service.

4. Personal Data Collection Methods

The above-mentioned personal data (hereinafter “Personal Data”) may be directly collected by the Member either over the Application or email addresses belonging to the Company, customer services panels on the Application and other communication channels by means of sharing them with the Company.

Personal data may also be collected by the company through automatic methods when the member logs in as an on-line visitor on the Application and/or creates a membership account and benefits from the services offered through the Application.

5. Purposes and Legal Grounds of Processing Personal Data

The Company may process the above-mentioned personal data for different purposes based on different legal grounds.

Information about the purposes of, and legal grounds for, processing personal data are given below:

5.1. Personal data may be processed for the purposes specified below based on the legal ground of the necessity of processing the personal data belonging to the parties of the contract pursuant to the legislation, provided that it is directly related to the execution or enforcement of a contract under the scope of the Membership Contract and/or Terms of Use agreed on between the Member and the Company.

5.1.1. Completing the membership record, confirmation of membership account and matching the membership account with the personal data

5.1.2. Replying requests of the Member about the Application, evaluation of his/her complaints and suggestions, ensuring customer satisfaction by solving the problems s/he experiences, obtaining his/her support, etc. and informing the Member thereof

5.1.3. Making the transactions, confirmations and controls required for the payments that the Member will make during the purchasing transactions over the Application, examine and evaluate requests for return and inform the Member accordingly

5.1.4. Making sure that the Member may view and use the membership account and the Application, ensure that s/he benefits from the Application, make transactions, examinations and controls required in terms of the above-mentioned issues and inform the Member accordingly

5.1.5. Informing the Member about the updates, changes and developments of the Membership Account and Application

5.1.6. Keeping the personal data belonging to the Member on the servers where the Application data are kept

5.1.7. Keeping and viewing the documents and records related to the payment transactions made over the Application

5.1.8. Making sure that the Member may see again the talks, purchasing transactions that s/he made, and the documents related thereto and various records related to his/her transactions on the Application

5.1.9. Performance of the basic functions required for the operation of the Application and its use by the Member

5.1.10. Making sure that the Member logs in the membership account on the Application and the session logged in remains permanently open and that the Member is able to use it without any necessity to enter the user name/ password again every time s/he logs in

5.1.11. Making sure that the Member is remembered and recognized during the logs in to the Application, remember the past transactions and preferences of the Member on the Application

5.1.12. Providing support / help to the Member by means of various guidances to realize the transactions that s/he wants to make concerning his/her membership account

5.1.13. Under the scope of the services provided over the Application, preparation of the texts containing the daily astrology readings related to the Member and their delivery to the User on a daily basis and, sending them to the member by email and/or over the Application

5.1.14. Under the scope of the services provided over the application, ensuring that the questions of the Member about astrology are answered by astrologers operating on the Application and acting as intermediary in this regard

5.1.15. Under the scope of the services provided over the Application, providing the service of Solar Return and acting as an intermediary in this regard

5.1.16. Under the scope of the services provided over the Application, making sure that the Member has video chats with the astrologers operating on the Application and acting as an intermediary in this regard

5.1.17. Making sure that the personal data may be viewed by other members under the scope of the service of meeting with other members provided over the Application in order to provide the services

5.1.18. Providing astrology-related services over the Application or acting as an intermediary for providing those services

5.2. Personal data may be processed for the purposes specified below based on the legal ground of “being mandatory for the data controller to fulfill its legal obligation” pursuant to the provisions of the legislation

5.2.1. Viewing and examining the personal data to meet the requests of the law enforcement, legal and administrative authorities concerning the Application and the Member, replying to the incoming official correspondences and sharing the information related to the request

5.2.2. Making sure that the procedures related to membership and purchasing processes are carried out in accordance with the legislation in force

5.2.3. Making sure that the personal data that the company is obliged to retain as per the legislation in force may be retained for the periods of time determined by the relevant legislation

5.2.4. Ensuring the technical legal and commercial security of the Company and the persons and entities who are in relation with the Company

5.3. Personal data may be processed for the purposes specified below based on the legal ground of “being mandatory for the purpose of establishment, exercise or protection of a right” pursuant to the provisions of the legislation

5.3.1. Retention of the Personal Data for the duration of the relevant lapse of time to enable the Company to exercise its legal rights regarding the potential disputes between the Company and the Member

5.3.2. In case of a dispute between the Company and the Member, the Company may keep, examine and use the personal data to make the necessary evaluation and initiate the legal proceedings

5.4. Personal data may be processed for the purposes specified below based on the legal ground of “being mandatory for the protection of the legitimate interests of the data controller, provided that the basic rights and obligations of the relevant person are not thereby harmed” pursuant to the provisions of the legislation

5.4.1. Facilitating, customizing or developing the Application and the services provided in the Application for the use of the Member

5.4.2. Preventing, detecting and minimizing and investigating the activities that may involve a cheat or fraud, violation of security rules or that may be suspicious, and retention, visualization and examination of the personal data for the above-mentioned purposes

5.4.3. Maintenance, view and examination of the Member’s usage information and purchasing movements on the Application in order to monitor the process security on the Application

5.4.4. Making it possible to solve any complaint and/or dispute concerning the Application and/or Member and/or the services provided over the Application, view and examination of personal data for that purpose

5.4.5. Examining and tracking the payment movements of the Member on the Application

5.4.6. Monitoring and developing the security of the Application

5.4.7. Retention, view and examination of the written and/or video meetings made by the Member with the astrologers operating on the Application to examine evaluations, comments and complaints of the Member about the astrologers

6. Sharing Personal Data

6.1. If any of the purposes stated in the articles 5.1., 5.2., 5.3., and 5.4. of this privacy statement exists, the Company may share the Personal Data with the companies outsourced for Support Services in various areas, including but not limited to customers services, hosting, accounting, legal affairs, payment systems, software support, e-mail/SMS delivery service, maintenance & technical support services based on the legal grounds stated for the purposes of processing personal data in the above-mentioned articles.

6.2. If one of the purposes stated in the articles 5.1, 5.2, 5.3 and 5.4 of this privacy statement exists, the Company may share the Personal Data related to the Member with the other astrologers operating on the Application and other members on the Application based on the legal grounds stated for the purposes of processing personal data in the above-mentioned articles.

6.3. If any information and documents are requested concerning the Application and/or the Member under the scope of the official communications sent by law enforcement, administrative and/or legal authorities, personal data may be shared with them in order to reply those official communications and meet the requests based on the legal ground of “being mandatory for the fulfillment of the legal obligation of the data controller pursuant to the legislation

In addition to the foregoing, the Company may also share the personal data with the law enforcement, administrative authorities and/or legal authorities if one of the purposes stated in the articles 5.1., 5.2., 5.3., and 5.4. of this Privacy Statement exists, based on the legal grounds stated for the purpose of processing personal data in those articles.

7. Member’s Rights

By sending an email to the email address [email protected] the member has the right to:

a) learn whether the personal data have been processed or not,
b) if processed, request information about it,
c) Learn the purpose of processing and whether they were used in conformity with their purpose of use,
ç) know the third persons to whom they were transferred at home and abroad,
d) request correction of the incompletely/incorrectly processed data,
e) request deletion/removal of personal data
f) request notification of the third persons to whom the personal data are transferred about the transactions made pursuant to sub-paragraphs (d) and (e) above,
g) object to any consequence or outcome against the Member due to the analysis of your personal data exclusively by automatic systems,
ğ) Claim compensation of the Member’s losses if s/he incurs losses due to the unlawful processing of personal data.

8. Measures Taken to Ensure Security of the Personal Data

Various measures taken by the Company to ensure the security of the personal data include applications like Cloudflare CDN protocol, back-up and firewall security wall. Furthermore, the server access information is updated with intervals of 3 monthly periods.

9. Miscellaneous Provisions

This Privacy Statement is only valid in terms of use of the Personal Data by the Company.

If the Member shared his/her personal data with third persons outside the Company and/or was directed to third person websites over the Application s/he will be subject to the personal data policy of the third persons or their applications concerning personal data

The Company has no responsibility whatsoever concerning the personal data that the Member will share during written and/or visual talks that s/he will hold with third party astrologers operating over the Application and independently from the Company. If the astrologers commit any unlawful act concerning the above-mentioned personal data, all kinds of legal and punitive liability for those acts will belong to the astrologers who had perpetrated the relevant act.

The Company will not be held liable in any manner whatsoever for the acts of such third persons and/or astrologers concerning the personal data and the Member agrees, declares and undertakes that s/he will direct all kinds of requests, complaints and loss claims to the above-mentioned third persons/astrologers.

10. Changes to Be Made on the Privacy Statement

The Company may always make changes on this Privacy Statement. Those changes shall immediately take effect after the new, changed Privacy Statement is published. The Member shall be duly informed about the changes made on this Privacy Statement.

11. Children’s Privacy

Application is restricted to individuals who are 18 years of age or older. The company does not permit individuals under the age of 18 on the Application. If you suspect that a member is under the age of 18 please report or contact us through support.