Last Revision Date: 16.05.2019
Our promise for being transparent about the data we collect about the Users, how such data are used, with whom they are shared and how they are protected and protecting the privacy of your data is right in the center of this mission. This Policy also provided information on how you can control personal and private personal information (“data”) collected from the Users and how they can apply to Company when they require the deletion of such data.
Which Data Are Processed?
Under this title, the data processed in the scope of the Company’s services are mentioned below. Unless otherwise specified, the statement of the "personal data" and "special categories of personal data” contain the information given below in the scope of the Policy’s terms and conditions.
Name and Contact Information: Name, surname, company name, job title, company department, country, mobile phone, home phone, work phone number, email address,
Data Collected by Cookies: Browser type, IP, operating system, viewed pages, display time
Data that are anonymized in an irreversible manner shall not be considered as data within the scope of this Policy.
You can feel safe while using our Site. However, no system is completely secure. Even if we take all the necessary actions to protect your information, the possibility of insecurity always exists. For this reason, you should be very careful when you disclose and carry out your personal information. The processing of the information submitted by you without the request of the Company shall not be counted as personal data processed by the Company under this Policy. You should avoid sending your voice, images, and other personal information that is not requested by the Company via any communication channel including but not limited to e-mail or message.
For Which Purposes Your Data Are Processed?
The Company may process the personal data provided by Users and the new data acquired by the Company to enable Users to use the Site, to provide and improve the services related to the Site, to use the personal data set out in this Policy, to fulfill the requirements of guarantee services originating from the company, for authentication, to prevent any third party from taking the advantages of the services unfairly in breach of the Contract, to present advertisements and marketing campaigns belong to the Company or the third parties, to provide promotions to the Users and to fulfill any kind of legal obligation.
The Company may obtain the information related to the Users' usage of the Site by using cookies that are technical communication files and may transfer them the third parties with the aim of processing them in the scope of the analysis services provided by third parties. The technical communication files mentioned are the small word files that are sent to the User’s browser to keep in the main memory by the Site. The technical communication file simplifies the usage of the internet by keeping the preference and condition settings about the web site. The technical communication file is used for gaining statistical information about how many people use the Site in a proportion of the time, for which purpose, how often people visit and stay on the Site and designed for helping the dynamic production of advertisements and content from the pages specifically designed for the Users.
In order to identify system problems and resolve issues promptly, the Company identifies and uses the IP address of the users where necessary. IP addresses can also be used to identify users in general and to collect comprehensive demographic information.
Who Can Access Your Data?
Company can share the personal data provided by the Users and the new data acquired by the Company with outsourcing service providers, third parties companies providing advertisements, campaigns and promotions and other third parties to provide and develop the services, to develop the experience of the Users and to fulfill any of the purposes under the title of “For which purposes your data are processed?”.
Company can share the personal data provided by the Users with the contractors provides the services, with outsourcing service providers for providing the services in the scope of specified and on condition that is used only in connection with the purpose for which it is being worked, limited and measured. In addition, the data can be processed and shared with the third parties by the Company in the scope of some exceptions under the data protection regulations. The main situations are as follows:
- It is expressly permitted by any law;
- It is necessary in order to protect the life or physical integrity of the data subject or another person where the data subject is physically or legally incapable of giving consent;
- It is necessary to process the personal data of parties of a contract, provided that the processing is directly related to the execution or performance of the contract;
- It is necessary for compliance with a legal obligation which the controller is subject to;
- The relevant information is revealed to the public by the data subject herself/himself;
- It is necessary for the institution, usage, or protection of a right;
- It is necessary for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed.
The Company has the right of transfer the personal data to servers (including servers, subsidiaries, sub-contractors or outsourcing service providers) located anywhere in the world outside of the country of residence of Users with the aim of getting hosting service in the scope of fulfilling the purposes set out above.
About the Right to Access Your Data and Correction Requests Pursuant to Personal Data Protection Law No. 6698 (“Law”)
Pursuant to the Law No. 6698, Users are entitled to submit and application to Company and:
- Learn whether or not her/his personal data have been processed;
- Request information as to processing if her/his data have been processed;
- Learn the purpose of the processing of the personal data and data are used in accordance with their purpose;
- Know the third parties in the country or abroad to whom personal data have been transferred;
- Request rectification in case personal data are processed incompletely or inaccurately;
- Request deletion or destruction of personal data within the framework of the conditions set forth under article 7;
- Request notification of the operations made as per indents (d) and (e) to third parties to whom personal data have been transferred;
- Object to occurrence of any result that is to her/his detriment by means of an analysis of personal data exclusively through automated systems;
- Request compensation for the damages in case the person incurs damages due to the unlawful processing of personal data by applying to the Company.
The Users’ Rights Arising from the European Union’s General Data Protection Regulation (“GDPR”)
Unless restricted under the applicable laws, the following are the rights granted to data owners under GDPR:
- Right to Access: Right to obtain information about data we process about you and right to request access to such data;
- Right to Correction: Right to request amendment or revision of your data in case of deficient or incorrect data;
- Right to Deletion (Right to Be Forgotten): Right to request deletion of your data;
- Right to Restriction: Right to request temporary or permanent cease of processing all or a part of your data;
Right to Object:
- Right to object the processing of your personal data based on facts related to your private condition;
- Right to object processing of your data for direct marketing purposes
- Right to Transfer Right: Right to request an electronic copy of your data and transfer such data for using in services of another party;
- Right to Be Excluded From the Automatic Processing System: Right to become subject to an automatic decision- making mechanism including profiling when the decision has legal effect or similar other effects on you.
The Users may use the right to apply for the abovementioned requests in accordance with one of the following methods or other methods to be determined by the Protection Committee of Personal Data:
- by filling in and wet-ink signing the “Application Form of Personal Data Protection” (“Application Form”) that published in the Site in accordance with the data protection regulations at www.subgen.com and transmitting it to the head office addressed at 25 N La Brea Ave, Los Angeles, CA 90038 (By submitting it in person with the incentive certificate of the applicant's identity).
- by filling in the application form and signing with the "secure electronic signature" and sending the secure electronic signed form to the e-mail address [email protected] (“the Data Protection Regulation Information Request" will be written in the subject of the e-mail.)
- by filling in the application form and signing it with wet-ink signature and sending it to 25 N La Brea Ave, Los Angeles, CA 90038 via notary public (“Information Request within the scope of Protection of Personal Data” will be written in the notification envelope.)
The Company shall provide a positive/negative response to the aforementioned inquiries by sending written or electronic response to applicants and the inquiries shall be resolved immediately but in any case, within thirty days depending on the nature of the inquiry. The Company shall process the inquiry of the applicants in the shortest time possible and provide information to applicants about the subject matter.
The Users guarantee that data constituting the subject matter of this Policy are true and up-to-date and they shall be updated in case of any changes in such data. On the contrary, the Company shall not be held responsible for any loss or damage that may arise.
The Users can transmit their right to petition via notary with filling the form which is located at www.subgen.com to the headquarter of the company located at 25 N La Brea Ave, Los Angeles, CA 90038 with the original signature. There is no way to make a request from the third parties instead of personal data owners. In any case that a third party makes a request instead of the personal data owner, there should be a special warranty of attorney which should be prepared especially relative to the subject. Personal data owners will fill the form in accordance with the Law numbered 6698 Protection of Personal Data, the application form related to the applications to be made by the Person (Personal Data Holder). In this form, the application method is also explained clearly.
The Applicant agrees that the information in this Policy is complete, correct and up-to-date and will be updated immediately if there is any change in this information. If the applicant does not have up-to-date information, the Company will not have any responsibility.
Storage Time of Personal Data
The Company is entitled to store data collected for the benefit of Users from the Site to use the Services in accordance with this Policy, fulfilling the collection purposes; complying with the data protection regulations; carrying our administrative and judicial proceedings related with a dispute and for the time limits specified under the applicable legislation.
Our Precautions And Undertakings About Data Safety
The Company undertakes to make the necessary audit and takes the necessary technical and administrative precautions about the following issues which are determined in the related regulations, indicated in this Policy and transmitted electronically from the Site:
- Do not process personal data unlawfully
- Do not access personal data unlawfully
- Provide the necessary security level to store the personal data
In case a link is provided in the Site for access to another application, the Company shall not be held responsible in connection with the privacy policies and contents of that application.
The Company covenants that such data obtained about the Users shall not be disclosed in breach of the provisions under this Policy and the Regulation, or process them beyond the purpose of processing. However, please note that no system is 100% secure. In case any breach about the system comes its knowledge, the Company may attempt to notify you by sending a notification to www.subgen.com address or sending an electronic mail to you.
If you have any question about data security, you can contact us at [email protected] address.
Your personal data as set forth in this Policy and which you have consented to be shared with us by clear consent texts may be used to provide you various advantages and to send you specific advertising, sales, marketing, questionnaires, reservations and all kinds of electronic communications for similar purposes and other communication messages; storage, processing, use, transfer of information. These personal data are used for the same purposes; The Company and all its subsidiaries and affiliates shall be shared with the third parties in the domestic and/or foreign countries in which we are in a contractual relationship. Users declare that personal data can be used and stored by the Company for these purposes.
The Company is entitled to revise this Policy time by time. You can check the last revision date in the “Last Revision Date” field. The Policy provisions revised by the Company take effect on the date of release. In addition, the Company shall display a notification or send an e-mail as appropriate, in connection with the material revisions. Therefore, please make sure that you read such notifications carefully.
Privacy of Children
SubGen’s services and the Site are not aimed at children under 16 years of age. In addition, stricter age restrictions may apply under local regulations of certain countries.
We do not collect information from children under 16 years of age or applicable age limit. If you are under 16 years of age, please do not use SubGen’s services or do not provide us any personal data. If you are a parent of a child under 16 years of age or you notice that your child provided data to the Company, please contact us at www.subgen.com address.
We will take reasonable steps to delete the data if we find our that data of children under 16 years of age are collected.
Please if you have any questions about this Policy, you can contact Data Protection Officer by writing to the following address: