VR Social
Privacy Policy

This Privacy Policy has been prepared by Metaverse Software Information Technologies Trade Limited Company, established at Üniversiteler Mahallesi İhsan Doğramacı Boulevard, ODTÜ Teknokent İkizler Building K1-4A, Çankaya/Ankara/Türkiye, acting as the data controller (hereinafter referred to as “Metaverse”), in order to inform you, within the framework of Article 10 (“Obligation of the Data Controller to Inform”) and Article 11 (“Rights of the Data Subject”) of the Turkish Personal Data Protection Law No. 6698 (“KVKK”), about the methods of collection, processing, use, transfer, and destruction of your personal data within the scope of the VR Social Service.

Within the scope of the VR Social Service, Metaverse processes your personal data in accordance with the personal data processing conditions and purposes specified under KVKK:

• in compliance with the law and the principles of honesty,

• by ensuring that the personal data you share is accurate and kept up to date,

• for specific, explicit, and legitimate purposes,

• in a manner that is relevant, limited, and proportionate to the purposes for which they are processed,

• for the periods stipulated in the relevant legislation or required for the purposes for which they are processed.

1.   Collection of Personal Data, Processed Personal Data, and Purposes

1.1.   Collection

The VR Social Service application does not require users to create an account, register, or log in. Therefore, no direct identity information such as name, surname, email address, or phone number is collected. Only technical identifiers necessary for providing the service, such as Device ID, are processed.

1.2.  Processed Personal Data and Purposes

The following data is processed for the purposes of providing, improving, securing the VR Social Service, and fulfilling legal obligations:

·         Device ID: Processed within the scope of contract performance to ensure the technical delivery of the service, enable interaction in the virtual environment, and manage sessions.

·         Potential legal case data (identity information, address information, and documents related to disputes): Processed for the purpose of tracking legal and enforcement files in case of disputes, including unpaid service fees and unauthorized software usage.

1.3. Legal Grounds for Processing

Data processing is based on Article 5/2 of KVKK for the purposes of purchasing services through the Platforms and benefiting from customer services and support, namely:

(a) being explicitly stipulated by law,

(c) being necessary for the establishment or performance of a contract,

(ç) being mandatory for Metaverse, as the data controller, to fulfill its legal obligations, and

(e) being necessary for the establishment, exercise, or protection of a right.

The processing of such data is not subject to your consent. Therefore, you are not entitled to request the deletion or destruction of your personal data until the end of the service period and the legally required retention periods.

2.       Transfer of Personal Data to Third Parties

Metaverse may transfer or disclose your personal data specified above, without requiring your consent, in order to comply with obligations arising from the law and/or to perform its responsibilities under the service agreement and/or where it is mandatory to fulfill its legal obligations, to:

·         third parties such as banks, audit firms, lawyers, law offices, financial advisors, suppliers—especially the psychologists providing services—limited to and proportionate with the service received and solely for the fulfillment of obligations, and

·         law enforcement units, public institutions, relevant ministries and directorates, and public institutions and legal entities including the Social Security Institution assigned pursuant to labor and social security legislation, as well as other public authorities authorized by law.

Domestic data transfers within Türkiye shall be limited to the cases stipulated under Article 8/2(a) of KVKK, namely where processing is required by law pursuant to Article 5/2(a), necessary for the establishment and/or performance of a contract pursuant to Article 5/2(c), required for the fulfillment of a legal obligation pursuant to Article 5/2(ç), or necessary for the establishment, exercise, or protection of a right pursuant to Article 5/2(e).

With respect to personal data you share during communications with service providers, the data controllers are the relevant service providers themselves. Likewise, transactions you carry out through channels outside Metaverse during the provision of the service (for example, payment transactions) and records related to the provision of the service form part of the legal relationship between the service provider and the service recipient; therefore, Metaverse does not act as the data controller regarding the data processed and stored within this scope.

Information regarding third parties and/or categories of third parties to whom your data are disclosed in Türkiye is always available for your information and review.

3.       Access to Personal Data

Metaverse shares your personal data with servers located in Türkiye belonging to the company Natro.

These transfers are carried out pursuant to Article 8/2 of KVKK.

4.       Protection, Retention Period, and Destruction of Personal Data

Metaverse is obliged to take, and takes to the maximum extent, all necessary physical, technical, and administrative measures to ensure an adequate level of security in order to prevent unlawful processing of personal data, prevent unlawful access to personal data, and ensure the preservation of personal data.

Unless otherwise stated in the Information Notice, your personal data are retained until the end of the 10 (ten) year retention period following the termination of the service relationship. For detailed information, please review the Information Notice.

Your personal data processed for marketing purposes are limited to the duration of the service. Upon the expiration of the service period, Metaverse will not use your personal data to contact you for marketing purposes.

At the end of these periods, your personal data will be deleted, destroyed, or anonymized during the first disposal period.

Metaverse has prepared separate and specific information notices (“Information Notice”) for users, employees, employee candidates, suppliers, and managers. These information notices have been delivered to or made accessible by each relevant data subject group. At the end of these periods, your personal data will be deleted, destroyed, or anonymized during the first disposal period.

5.   Your Rights

As a data subject, pursuant to applicable legislation, you have the right to: (a) request information as to whether your personal data are processed and how they are processed (Art. 11(a), (b)), (b) learn the purpose of processing and whether they are used in accordance with such purpose (Art. 11(c)), (c) know the third parties to whom your personal data are transferred (Art. 11(ç)), (d) request correction of your personal data (Art. 11(d)), (e) request the deletion of your personal data if the reasons requiring their processing cease to exist (Art. 7, Art. 11(e)), (f) request notification of correction or deletion operations to third parties to whom personal data have been transferred (Art. 11(f)), (g) object to any result arising against you as a result of analysis of your personal data (Art. 11(g)), (h) request restriction of processing (Art. 7), and (i) request compensation for damages incurred due to unlawful processing of personal data (Art. 11(ğ)).

The above-mentioned rights are limited by law and may only be provided by us under certain conditions (please particularly review Articles 10 and 13 of KVKK).

You may submit your requests regarding the rights listed above to kvkk@metaverse.com.tr. Metaverse will conclude your request as soon as possible and at the latest within 30 (thirty) days from receipt of the relevant documents.

Data Controller: Metaverse Software Information Technologies Trade Ltd. Co.

MERSIS No: 3958-6264-9135-7424

Address: Üniversiteler Mahallesi İhsan Doğramacı Boulevard, ODTÜ Teknokent İkizler Building K1-4A, Çankaya/Ankara/Türkiye

Email: kvkk@metaverse.com.tr

Upon request, Metaverse may update your personal data as well as this Privacy Policy and the Information Notice at any time. You can always access the Terms of Use, the current Information Notice, and the Privacy Policy at www.vrsocial.com.tr

Right to File a Complaint with the Personal Data Protection Authority

To exercise your right to file a complaint with the Authority (KVKK Articles 13, 14, and 15):

Authority: Personal Data Protection Board

Address: Nasuh Akar Mah. Ziyabey Cad. 1407. Sok. No: 4, 06520 Balgat-Çankaya/Ankara

Phone: +90 312 216 5000

Website: http://www.kvkk.gov.tr/