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PRIVACY POLICY and Notification In Accordance With the General Data Protection (GDPR) Regulation

The purpose of this Statement is to define the terms and conditions of usage of any confidential information shared by the users (Users) to the websites administered by SmartCV Technology Inc. (Company). These sites are (Site) and MOBIXA Mobile application (Mobile Application) ( Hereon to be named, along with the sites and mobile application as PLATFORM). Definitions in the User Agreement will be taken into account in the interpretation of the expressions not defined in this Notice. By accepting the User Agreement, the User will be deemed to have accepted this Notice.

Which Data Do We Process?

The company collects the following data provided by the user in digital environment, during the membership process.


·       Name, surname, picture, business or private e-mail address, telephone number, home or workplace address,

·       Password and similar security information used for authentication and account access,

·       Demographic data such as age, gender, country,

·       Data required for payment transaction,

·       Any completed survey by the user that is sent by the Company. These surveys will be sent on a voluntary basis and are not required to be answered.

·       As a result of you playing the game, any questions you have completed while playing the game and any statistics that indicate your visual auditory and phonetic skills. 


The Company can obtain information about the Users’ use of the Platform by using cookies (Cookies), which are technical communication files. In order to determine your access to the services offered on the platforms and your usage habits, the following data can be collected via cookies.


·       Scanner Type

·       IP number

·       OS,

·       Pages Viewed

·       Display Time

·       Mobile device type

·       Mobile device operating system

·       Your instant location


The data that are irreversibly anonymized by Articles 3 and 7 of the Law on the Protection of Personal Data will not be considered as personal data in accordance with the provisions of the aforementioned law and the processing activities related to these data will be carried out without being bound by this Statement.


For What Purposes Do We Use Your Data?

The Company will utilize any data provided by Users, and any further resulting data created by the Company on the basis of provided data by Users with the purpose of increasing users’ benefits provided by the Platforms, the improvement of Platforms for the future, compliance with any laws and for the purposes highlighted in this agreement.

The Company may obtain information about the User's use of the Platforms by using cookies (Cookies), which are technical communication files, process the data in this context and transmit it to third parties for the purpose of utilizing the analytical support and services offered by such parties and only to the minimum extent required by such parties to conduct a beneficial analysis. The mentioned technical communication files are small text files that the Platforms send to the User's browser to be stored in the main memory. The company may also collect this information with its own mobile application. The technical communication file facilitates the use of the internet in this sense by storing the status and preference settings about a website. The technical communication file includes how many people use the Platforms at which times, for what purpose, how many times they visit the Platforms and how long they stay, to obtain statistical information about the usage success rate and demographics, and to dynamically generate content from user pages specially designed for users. It is designed to assist and is used for these purposes. The technical communication file is not designed to receive any other personal data from the main memory. Most of the browsers are initially designed to accept the technical communication file, but users can always change the browser settings so that the technical communication file does not arrive, or the technical communication file is sent.

The Company determines and uses the IP address of the Users, when necessary, in order to identify problems related to the system and to resolve the problems urgently. IP addresses can also be used to identify Users in general and to collect comprehensive demographic information.


Who Can Access Your Data?

The Company utilizes data provided by the Users and the data which is created by the Company through provided data for the purpose of providing appropriate and customized services for the user, to comply with the clauses highlighted in the Users Agreement and Notification, to better and customize services provided by the Company, to elevate services provided by the Company and for any purpose highlighted under “For What Purposes we use your Data” in this notification. Third Parties, for the purpose of further analysis will be used, only to the minimum extent to which such analyses require provided data. 

Your data will never be shared for advertising and promotional purposes.


The Company will also be able to process the data and share it with third parties in accordance with Articles 5 and 8 of the Personal Data Protection Law and / or in case of exceptions in the relevant legislation, without obtaining the User's consent. The main cases are as follows:


·       It is clearly prescribed in the laws,

·       In cases of life-threatening danger to the user or any other persons whereby disclosure of data is required and if the user may not physically disclose data or does not offer any legally required excuse. 

·       In cases where data is required to establish or pursue an agreement, including the User Agreement and whereby the data is directly related to such agreements.

·       It is mandatory to fulfill legal obligations,

·       It has been made public by the user themselves

·       Data processing is mandatory for the establishment, use or protection of a right

·       In cases where, for the legitimate uses of the company, data processing is required, provided that such data does not harm the personal rights and freedom of the user.


Limited to the fulfillment of the above-mentioned purposes, the Company has the right to transfer personal data to its servers located anywhere in the world (the servers may belong to itself, its affiliates, subcontractors or outsourcing service providers) in order to receive hosting services. 


Your Right to Access Your Data and Correction Requests

The user, by applying to the Company reserves the right to

·       Learn whether personal data is processed,

·       If personal data has been processed, to request information regarding this,

·       The purpose of processing personal data and whether they are used in accordance with their purpose,

·       To ascertain the third parties to whom personal data are transferred,

·       Correct personal data in case of incomplete or incorrect processing

·       Deletion of personal data within the framework of the conditions stipulated in the relevant legislation.

·       To notify any third parties the correction, deletion and destruction processes made in accordance to the relevant legislations.

·       To launch a complaint against any negative results that may occur as a result of any data analysis. This may only be applied exclusively in cases of analyses completed through automated systems.

·       In case of damage to data due to unlawful processing of personal data, the user reserves the right to demand amends to done damage.


The user may send the above-mentioned requests in writing to the e-mail address, In accordance with the above-mentioned requests, the company may give its affirmative / negative response through written or digital platforms. The user will never be charged for any requests, implications of such requests and procedures that may follow with said request. However, if the transactions require a cost, it is possible to charge a fee on the tariff determined by the Personal Data Protection Board in accordance with Article 13 of the Personal Data Protection Law.

The User guarantees that the information subject to this Notice is complete, accurate and up-to-date and will update them immediately in case of any change to this information. If the User does not provide up-to-date information, the Company cannot be held responsible.


Storage Period of Personal Data

The Company, for the purpose of users’ benefitting from the Platforms, to provide the necessary services in the Platforms and to oblige in Users Notification an Agreements, will store the data as long as services are utilized by the User.


In addition, in the event of any dispute arising from the User Agreement, the Company will be able to store personal data for the period of limitation specified in accordance with the relevant legislation, limited to the purpose of making the necessary defenses within the scope of the dispute.


Our Guarantees and Commitments Regarding Data Security

The Company guarantees the following regarding data that has been sent to it electronically, under conditions highlighted in Privacy Policy or Legislation concerned;


·       That Personal data are not processed unlawfully,

·       That Personal data are not accessed unlawfully,

·       The Company ensures that appropriate level of security measures will be taken in order to protect personal data

·       The company will be obliged to undertake periodic and necessary inspections regarding its protection systems.


The Company will not disclose any personal data obtained about its users to any third parties, which would be in violation of this Notification and the Law of Protection of Personal Data. The company guarantees that the data will only be used for purposes highlighted in mentioned Notifications and Agreements. In cases where links are provided to other applications, the Company will not be held responsible for any privacy policies or content that these applications have.


Contact Permission

By accepting the Company's User Agreement and this Notice, you consent to the collection, storage, processing, use and transfer of your personal data. This data will be used in order to provide you with various advantages and to make all kinds of electronic communication in accordance with the purpose of the application.

This personal data may be shared with the Company and all of its subsidiaries and affiliates, with third parties in Turkey and / or abroad with whom we have a contractual relationship, in accordance with the purpose of use of the platform and limited to the purposes shared with you in this text.

Users accept and declare that they consent to the use and storage of their personal data by the Company in this way. 


The Company guarantees that the data in question will be safely secured, defended against any unauthorized attempts to seize it and defend against any attempted unlawful usage of data provided by its users, in accordance of the the related laws.


Changes to the Statement

The Company may change the provisions of this Notice at any time by publishing it on the Platforms. The changes made to the notification will become effective on the date of publication. For you to be aware of the changes made in this Statement, the necessary information will be given to our members via the e-mail address you specified while registering on the platforms.


Resolution Of Disputes

This notification is subject to the laws of the Republic of Turkey. All disputes arising out of or related to this Agreement will be ultimately resolved by arbitration in accordance with the Istanbul Arbitration Center Arbitration Rules.




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