PRIVACY POLICY

Last modified: 03.12.2024

SUMMARY

Below is a summary of some key terms of this Privacy Policy and Clarification Text Regarding the Processing of Personal Data (“Clarification Text”).

We at Shorten Medya Ticaret Anonim Şirketi listen to our users and we are committed to protecting the principles of privacy and fair use that underpin our values to offer a transparent and secure service. We want you to be confident that your personal data is safe and secure with us.

This Clarification Text explains the following:

how we collect your personal data;
what personal data we collect;
how and for what purpose we use your personal data;
who we share your personal data with;
what measures we take to keep your personal data safe;
how long we keep your personal data;
age limits and
the rights and choices you have when it comes to your personal data.

SHORTEN Privacy Policy and Clarification Text Regarding the Processing of Personal Data

The confidentiality and security of your data is of great importance to us. We aim to inform you about how we collect, process and share your personal data as a data controller as part of our Services as defined in our Terms of Service in this Privacy Policy and Clarification Text Regarding the Processing of Personal Data (Clarification Text). The use of data collected on our Services is limited to the purposes set out in this document. This Clarification Text should be read in conjunction with our Terms of Service.

We have prepared this Clarification Text to inform you about how we process your personal data as the data controller Shorten Medya Ticaret Anonim Şirketi ("SHORTEN").

When we say “SHORTEN” “our,” “we,” or “us,” we’re talking about Shorten Medya Ticaret Anonim Şirketi acting as the data controller. This Clarification Text applies to all of our apps, services, games, features, software and website (together, “Services”) unless specified otherwise.

For any questions and requests regarding the protection and processing of your personal data, you can contact us via support@shorten.com and Suadiye Mah. Hasan Bedrettin Sk. No: 3 İç Kapı No: 2 Kadıköy / İstanbul. We will get back to you within 30 days at the latest from the date of your request.

Identity of the Data Controller

Shorten Medya Ticaret Anonim Şirketi , with its headquarters at Suadiye Mah. Hasan Bedrettin Sk. No: 3 İç Kapı No: 2 Kadıköy / İstanbul, registered before the Istanbul Trade Registry with the registration number 375782-5 , with Mersis No. 0622-2216-7950-0001 is the data controller.

Which of My Personal Data is Being Collected and Processed by SHORTEN?

Within the scope of the Service we provide to you, we process the following personal data that you provide to us during the registration for and/or use of our Services:

Identity & Contact	User Transaction	Transaction Security	Other Information
Name-surname, e-mail, phone number, username, Social Media Information (if you choose to register with your social media account)	Application usage information, request/complaint information	Device ID, IP address, user transaction logs, IDFA (advertising ID)	Payment information

Along with these information, we are processing your personal data regarding preference, liking, interests and usage habits and also information acquired as a result of analysis of your data determined above in order to provide you with the service that suits your tastes and needs.

It is your sole responsibility to check and ensure that all information, data (including personal data), content, materials or data that you provide to us are true, complete, accurate and not misleading.

Data that you may provide voluntarily

Certain parts of our Services may ask you to provide personal data voluntarily. For example, we will ask for certain data in order for you to register for an account with us, to begin using our Services, to subscribe to marketing communications from us, and/or to submit enquiries to us and for us to provide our Services to you, such as:

Contact and correspondence data (such as name and email address);
User name and password;
Other data you choose to give us (such as data to identify a lost account).

We will try to explain to you at the point we ask you to provide your personal data The personal data that you are asked to provide, and the reasons why you are asked to provide it.

Data that may be collected automatically

When you use our Services and if you have given express consent, we may also collect data automatically from you and/or your device which may be considered personal data under applicable data protection laws, such as:

Data and analytics about your use of our Services;
Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI);
Data about your device, such as device name and operating system, browser type and language;
Data we collect with cookies and similar technologies;
Broad geographic location based on your IP address;
Data about your use of our Services, such as in application interaction and usage metrics.

Advertising ID means Apple Identifier for Advertisers (“IDFA”) on Apple. These are unique identifiers for mobile device that advertisers use for interest based advertising. They are consistent across all apps and thus allow cross-app tracking. On Apple you can opt-out this by choosing “limit ad tracking” option from privacy settings.

Advertising IDs are non-permanent, non-personal identifiers, which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognise your device when you use websites and applications.

Data about your device refers to data about your device type, device model, device maker, device operating system and its language or other technical data like screen size or processor, or combination of this data available from a device for a developer for checking the device compatibility with a particular application.

Some of this data may be collected using cookies and/or similar technologies (such as "SDKs" or software development kits), as explained further below.

Data that we may obtain from third party sources

We may receive personal data about you from third party sources. For example, if you clicked on an advertisement to direct you to one of our Services we may be provided with data from which ad-network and advertising campaign the install originated from.

You may choose to connect to our Services via your social media account(e.g., TikTok, Facebook, Google, or Apple). We may collect specific data, subject to your permissions on that platform, exactly what data we receive from your social media will depend on your social media privacy settings, but it would typically include your basic public profile data such as:

your username;
profile picture;
age range; and

The data that we may collect from our partners could include;

Data we receive if you link a third-party tool with our Services (such as Facebook, Tiktok, Apple or Google);
Demographic data (such as to determine the location of your IP address);
Data to fight fraud (such as click fraud in advertising);
Data from platforms that our Services run on (such as to verify payment); and
Data for advertising and analytics purposes, so we can optimise the Services we deliver to you.
This data is used to enable account creation, manage your login, and personalize your app experience. For example, when using TikTok’s Login Kit, we collect your TikTok username, profile picture, and age range to streamline your registration process.Additionally, if you use a share feature within our app, you can share content (e.g., videos, images, or links) directly to your social media account. All shared content is initiated by you, and you retain full control over the message or post through your social media platform’s editing and privacy settings. You can manage or revoke permissions through the settings of your social media account.

We do not request or intend to collect any special or sensitive categories of data such as any data on health, race, religion or political opinion.

By Which Methods is My Personal Data Collected by SHORTEN?

We collect your personal data through websites operated by or on behalf of our company, our SHORTEN mobile application or other similar devices, channels or applications; by automatic and non-automatic methods.

For What Purposes is My Personal Data Processed?

As SHORTEN, we process your personal data mentioned above for the following purposes:

- To make improvements in order to provide the most appropriate service for your preferences, likes, interests, usage habits,

- Conducting analyses to improve our services,

- Conducting activities for customer satisfaction,

- Conducting marketing and promotion activities,

- Receive and evaluate feedback to improve our services,

- To carry out our activities in accordance with the law,

- Review and audit of our business activities,

- Detection and prevention of illegal activities.

We may use your personal data for the following purposes:

1. to enable you to access and use the Services. For example;

To create user accounts and profiles;
To provide you with the correct versions of our applications; and
To send you service related communications including confirmations, technical notices, updates, security alerts, and support or administrative messages

2. to personalise and improve aspects of our Services. For example;

To respond to your customer support requests;
To receive error messages about any issues you / your device encounters with our Services to enable us to fix bugs and interoperability issues;
To track application installs, for purposes of measuring the effect of our marketing campaigns;
To conduct optional user feedback surveys;
To remember you next time you visit one of our Services; and
Communicate with you about promotions, rewards, upcoming events, and other news about products and services offered by us.

3. to communicatewith you, including some or all of the following:

To provide you with in-app offers and rewards based on your interaction with our Services;
To serve you with relevant targeted advertisements;
To make you offers to purchase in-app items on discount based on your activity with our application and your purchase history; and
To send you marketing communications and/or newsletters if you have subscribed for them about rewards and promotions.

4. for research, such as analysing market trends and customer demographics;

5. to comply with legal obligations, including to prevent and/or detect fraud or provide disclosure to the authorities when required by applicable law.

What are the Legal Grounds SHORTEN Relies on When Processing my Personal Data?

If you are within the scope of the Law on the Protection of Personal Data we process your personal data based on the legal reasons specified in Article 5 of the Law on the Protection of Personal Data, based on the following:

Personal data processing is necessary for the establishment or performance of the contract between you and SHORTEN: This occurs when we provide you with Services or communicate with you about them. This includes when we process personal data to receive and administer paid (premium) services and packages; and to carry out payment processes. Your data under Identity & Contact, User Transaction, and Other Information are processed in order for you to use SHORTEN effectively; and your Identity & Contact and User Transaction data are processed in order for you to submit your possible requests/suggestions.

Processing is necessary for our legitimate interests: We may use and process some of your personal information if we have reasonable and legitimate business grounds to act in this way. Under the relevant legal regulations, there is the concept of "legitimate interests" as a justification for processing your personal data. Our legitimate interests for processing your personal data are to enable you to access and use our Services, to communicate with you about our Services and to improve our Services, to provide you with a better service and to carry out our customer service activities. For this purpose, your Identity & Contact, User Transaction, Transaction Security data are processed.

Processing of personal data is based on your explicit consent: In order to promote SHORTEN and to carry out marketing activities, your contact information is processed to contact you via e-mail and sms if we have your explicit consent. In addition, your personal data will be shared with group companies and service providers located abroad in accordance with your explicit consent for the purpose of obtaining and performing the services necessary to carry out commercial activities and limited to this purpose.

Legal obligations - We may need to process your personal data to comply with a legal obligation.

Under Which Conditions Are My Personal Data Transferred to Third Parties?

Your personal data are transferred to group of persons at domestic and abroad as shown below in the table and transferred only with the purposes determined in the table:

Group of Persons to Whom Data May be Transferred	Explanation About Group of Persons	Purpose of Data Transfer
Business Partners, Group Companies	Parties that SHORTEN carries out commercial activities with regardless of their name.	Data transfer will be ensured with the purpose of establishing business partnership and carrying out commercial activities subject to this partnership and transfer of data is limited to only this purpose. For example; confirming your phone number.
Third Party Service Providers Resident in Turkey or Abroad That Provide Data Processing Services	Parties that provide services to SHORTEN in any way on the basis of service agreement between them as part of SHORTEN’s commercial activities.	Data transfer will be ensured only limited to the purpose of obtaining necessary services to carry out commercial activities and performing these services. -Usage of “contact us” section in the application for the purpose of ensuring immediate help; -Showing contents relevant to your field of interests by means of monitoring the buttons and contents you view is within this scope. - Cloud information systems that provide us services for the purpose of storing your data in a secured manner. -Your information about payment and payment methods (payment institutions, PSP (payment service provider), payment intermediaries, payment service providers, technical integrator are also included in this scope) for the Services, that provide a specific service on our behalf is transferred for the performance, development and analysis of the core service we provide under our Terms of Service agreement; and in order for our Company to fulfil its legal obligation as the data controller, information on payment and payment methods are transferred to our Business Partners, who are third parties including those located outside your region.
Other persons you give consent to disclosure	Parties presented to your approval by notifying which personal data will be disclosed to whom within the scope of product/services of SHORTEN.	Third parties that provides us our payment platform to complete payment processes directed at our services.
Legally Authorized State Institutions and Organizations and Private Persons	Law enforcement bodies authorized in accordance with the relevant legislations, regulatory, executive institutions, courts or other third parties whom we believe it is necessary to disclosure to.	Data transfer will be provided to relevant state institutions and organizations and private institutions pursuant to the authority vested to them within the scope of relevant legislation and will only be limited to the purpose requested by them.

In addition, your personal data may and will be transferred abroad and processed by our Group Companies, third party service providers and partners located outside the borders of your country, based on your approval. By accepting our terms of Service, you are deemed to have consented to the processing and transfer of your personal data abroad. If you do not accept the processing and transfer of your personal data abroad, you may choose not to use our Services.

What cookies do we use?

A cookie is a very small text file placed on your computer or device. We and our partners use cookies and similar technologies to provide and personalise our Services, analyse use, target advertisements and prevent fraud. You can disable cookies in your browser settings, but some parts of our Services may then not function properly.

What advertisements do we show on our Services?

The advertisements that you see displayed on our Services are delivered on our behalf by certain third-party advertising companies. No data which identifies you, for example your name, address, email address or telephone number, is used to provide this advertising. In order to display advertising most likely to be relevant to you, these third-party advertisers may place or recognise a unique cookie on your browser. This cookie does not collect personal data about you nor is it linked to any identifiable data about you. By using our Services, you are consenting to the use of these third-party cookies for these purposes.

If you would like more data about online advertisements and your choices about how this data may be used by these companies, please find more data here http://www.youronlinechoices.com/uk/your-ad-choices.

What steps do we take to keep your personal data safe?

Your personal data’s security is very important to us. This is why, where it’s appropriate, we use HTTPS to help keep data about you secure. However, no data transmission over the internet can be guaranteed to be totally secure.

We do our best to keep the data you disclose to us secure. However, we can't guarantee or warrant the security of any data which you send to us, and you do so at your own risk. By using our Services, you accept the inherent risks of providing data online and will not hold us responsible for any breach of security.

How long do we keep your personal data?

Unless a longer retention period is required or permitted by law, we will only retain your personal data only for as long as reasonably necessary to fulfil the purposes outlined in this Privacy Policy and for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements. We will for example periodically de-identify unused user accounts and regularly review our data sets.

Do we transfer your personal data outside of the country you are resident?

Our Services are global by nature and your personal data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country. We take steps to ensure adequate safeguards are in place to protect your data as explained in our Privacy Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA.

Your personal data will be transferred to our group companies, third party service providers and partners located outside the borders of your residence country, based on your consent. By accepting our terms of service, you are deemed to have consented to the processing and transfer of your personal data abroad. If we do not accept the processing and transfer of your personal data abroad, you can choose not to use our Services.

Age Limits

We do not knowingly collect or solicit personal data about or direct or target interest based advertising to anyone under the age of 18 or individuals between the ages of 12 and 18 without the consent of a parent or legal guardian, knowingly allow such persons to use our Services. If you are under 18 or if you are over 12 years of age but do not have the consent of your parent or legal guardian you, please do not send any data about yourself to us, including your name, address, telephone number, or email addressIf we learn that we have collected personal data about a child under 18 years of age or over 12 years of age but without the consent of a parent or legal guardian, we will delete that data as soon as it is practicably possible.

How Can I Exercise My Legal Rights Regarding My Personal Data?

Article 11 of the Law on the Protection of Personal Data, regulates the rights of respective persons (real persons whose personal data are processed). If you are within the scope of the Law on the Protection of Personal Data your rights are as follows:

Learning whether your personal data are processed,
Requesting information if your personal data has been processed,
Withdrawing any prior consent you have given us regarding the use of your personal data,
Learning the purpose of processing your personal data and whether they are used in accordance with their purpose,
Knowing the third parties to whom personal data are transferred at home or abroad,
Requesting correction of personal data in case of incomplete or incorrect processing,
Requesting deletion or destruction for evaluation within the principles of purpose, duration and legitimacy,
Requesting that these transactions be notified to the third parties to whom personal data are transferred in case of correction, deletion or destruction of personal data,
Objecting to this result if a result is found against you in case the processed data is analyzed exclusively through automated systems,
Requesting compensation in case you suffer damage because of unlawful processing of personal data

You may prefer methods mentioned below to exercise your rights determined in this article and send your requests to SHORTEN:

You can send your requests to support@shorten.com by using your e-mail address registered in our systems.
You can send your requests by printing out the application form to Suadiye Mah. Hasan Bedrettin Sk. No: 3 İç Kapı No: 2 Kadıköy / İstanbul.
You can prefer other methods determined in Communique Regarding Procedures and Principles of Application to the Data Controller.

Changes to this Privacy Policy

We reserve the right to amend or modify this Privacy Policy at any time and any changes will be published on our Services. The date of the most recent revision will appear on this page. If we make significant changes to this policy, we may also notify you by other means such as sending an email. Where required by law we will obtain your consent to make these changes. If you do not agree with any changes, please do not continue to use our Services.

SHORTEN MEDYA TİCARET ANONİM ŞİRKETİ
Address: Suadiye Mah. Hasan Bedrettin Sk. No: 3 İç Kapı No: 2 Kadıköy / İstanbul
Mersis No: 0622221679500001

CCPA

This privacy notice is provided in accordance with the California Consumer Privacy Act (“CCPA”) and explains how Shorten collects, uses, and shares personal data. In the past 12 months, we may have collected information such as your name, address, and browsing history. We do not sell personal information to third parties. However, if we do, you have the right to opt-out of the sale of your personal information by using the "Do Not Sell My Personal Information" link on our website.

Under the CCPA, you have the right to request the deletion of your personal data, know what information has been collected about you, and opt-out of the sale of your personal data. We will not discriminate against you for exercising your rights under the CCPA, such as refusing services or offering different prices. We update our privacy policy every 12 months, and if there are any material changes, we will notify you directly.

To request information or exercise your rights under CCPA, please contact us at support@shorten.com .

Under the CCPA (California Consumer Privacy Act), California residents have the following rights:

Right to Know: You have the right to request information about the personal data we have collected, used, and disclosed over the past 12 months, including the categories of data, the purposes for which the data was collected, and third parties with whom the data was shared.
Right to Request Deletion: You can request that we delete personal data we have collected from you, subject to certain exceptions.
Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.
Right to Opt-Out of Sales: We do not sell personal information, so there is no need for an opt-out mechanism for the sale of personal data.
Right to Be Notified of Financial Incentives: You have the right to be notified of any financial incentives we may offer and their material terms. You also have the right to opt-out of such incentives at any time. We currently do not offer any financial incentives.

California residents may also request certain information regarding the disclosure of personal information to third parties for their direct marketing purposes. We do not disclose your personal information to third parties for their own direct marketing.

Do Not Track Signals: We do not currently respond to "Do Not Track" signals. However, you can manage your privacy settings, including opting out of tracking technologies used for interest-based advertising.

To exercise your rights, or if you are an agent authorized to make a request under the CCPA, you may email or contact us by mail at the address provided below:

Shorten Medya Ticaret Anonim Şirketi
Suadiye Mah. Hasan Bedrettin Sk. No: 3 İç Kapı No: 2 Kadıköy, Istanbul
Mersis No: 0622221679500001

To protect your privacy, we may need to verify your identity before processing your request, which may include asking for a government-issued ID.

Additional Information for Users in the European Economic Area (EEA), the United Kingdom, and Switzerland

At Shorten we prioritize the protection of your personal data in compliance with the General Data Protection Regulation (“GDPR”). We collect, process, and store personal data such as your name, contact details, and usage data based on one or more legal bases, including your consent, our contractual obligations, and legitimate interests. Your data is stored securely and will only be retained for as long as necessary to fulfill the purposes for which it was collected, after which it will be securely deleted.

You have several rights under GDPR, including the right to access, correct, or erase your data, restrict or object to its processing, and the right to data portability. You also have the right to withdraw your consent at any time, and the right to lodge a complaint with a supervisory authority. If we transfer your personal data outside the EU, appropriate safeguards, such as Standard Contractual Clauses, are in place to protect your data.

To request information or exercise your rights under CCPA, please contact us at

If you are a resident of the EEA, UK, or Switzerland, the following information applies:

Data Controller: Shorten Medya Ticaret Anonim Şirketi is the data controller responsible for the processing of your personal data.
Legal Basis for Processing:

Performance of a Contract: We process your personal data as necessary to perform our contract with you, such as to manage your account, facilitate your use of our Services, and provide customer support.
Consent: We rely on your consent to send newsletters, personalized ads, or other marketing communications. You can withdraw consent at any time.
Legitimate Interest: We may process your data for legitimate interests, such as improving our Services, debugging, or enforcing legal claims, as long as these do not override your data privacy rights.
Legal Obligation: We may also process your personal data to comply with legal obligations.

International Data Transfers: Your personal data may be transferred to, stored, and processed in countries outside of your home country, including the United States. We ensure that appropriate safeguards, such as Standard Contractual Clauses, are in place for international transfers of personal data.

Your Privacy Rights:

Right to Access, Correct, and Delete: You have the right to view, correct, update, or request deletion of your personal data.
Right to Object: You can object to the processing of your personal data where we rely on legitimate interests.
Right to Withdraw Consent: You can withdraw your consent for data processing at any time.
Right to Data Portability: In some cases, you may request that we transfer personal data you have provided to us to another service provider.

If you have concerns or complaints regarding how we handle your data, you have the right to lodge a complaint with your local data protection authority.

For more information or to exercise any of these rights, please contact us via support@shorten.com or by mail at:

Shorten Medya Ticaret Anonim Şirketi
Suadiye Mah. Hasan Bedrettin Sk. No: 3 İç Kapı No: 2 Kadıköy, Istanbul
Mersis No: 0622221679500001