PRIVACY POLICY
MEMO GLOBAL MARKETING AND DISTRIBUTION DANIŞMANLIK VE TİC A.Ş. (“Company” or “us” or “our”) operates US Green card and immigration online consulting and management services (“Service(s)”) as governed by our terms, available at: https://www.abdgochizmetleri.com/en/terms-of-use/ (“Terms of Use” or “ToU”). This Privacy Policy (“Policy”) is an integral part of the Terms of Use, definitions herein shall have the same meaning as defined therein.
We have designed this Policy to provide transparent and detailed explanation regarding our privacy practice, the data we collect and how we use it, as required under applicable privacy laws and among others, according to the EU General Data Protection Regulation (“GDPR”).
THE TYPES OF DATA COLLECTED
When you access and browse our website or use the Services in any manner, we collect certain types of data that can be classified as follows:
(A) non-identifiable aggregated data (“Non-Personal Data“), for example technical information transmitted by the device you are using and certain aggregated data regarding your use of the Services.
(B) individually identifiable information (“Personal Data”, or “Personal Information”, subject to applicable law definitions). This may include name, email address and online identifiers, as detailed in the table below.
It is important to mention that the Company will not combine Personal Data you voluntarily provide with Non – Personal Data Triple Space will collect. However, if we will combine these types of data, we will treat the combined data as Personal Data.
Please see the list below which details the types of data collected while you browse our website or use the Services offered therein, as well as the purpose of collection and how we use it.
Application Details:
If you wish to be provided with our Services you will be required to provide us such details as: full name, gender, English level, education level, income level, email address, date of birth, birth country, marital status, phone number, occupation, etc.
Some of our services features may require you to provide us with additional information according to the certain feature of our Services.
You may enter your details through an online form or in an application that we operate, or through phone call, voicemail, email, online chat, social network communication, postal delivery, or using any other method.
Further, during the application process you will be supplied with username and password for your account, at which time you thereby represent and warrant that you are responsible for maintaining the confidentiality of your details and password. You represent and warrant that you will not provide us with inaccurate, misleading or false information.
Purpose of Collection and How We Use It – We collect and process the application details in order to provide our Services.
For EU Individuals: Legal Basis under the GDPR – Performance of a contract
Recorded Phone Calls:
If you contact us or a representative acting on our behalf, including through our customer service representative, your calls may be recorded and or documented in writing.
Purpose of Collection and How We Use It – We record and process the phone calls in order to monitor the quality of the service provided to you, to provide our Services or to prevent fraud.
For EU Individuals: Legal Basis under the GDPR – Performance of a contract
Contact Details:
If you voluntarily choose to contact us for any reason, including support or any questions you may have, through any means of communication available (i.e., online form, email, mail, etc.) we will collect and process the information you provide which may include your name and email address.
Purpose of Collection and How We Use It – We will process your contact details as well as your contact history for the purpose of responding to your inquiries and provide you the service or support you have requested. In addition, we may store this information if we believe it is necessary under our legitimate interests, for example, in order to defend legal claims.
For EU Individuals: Legal Basis under the GDPR – Performance of a contract
Internet Protocol Address (IP) and Technical Data:
When you access our website and use the Services, we (directly or by our third part service providers) will collect your IP address. Note that, while IP address is considered personally identifiable information in many jurisdictions (such as the EEA), there are some jurisdictions in which such data sets are not considered as Personal Data. Therefore, we treat such information as Personal Data, in accordance with applicable laws.
In addition, we may collect technical Non-Personal Data, including type of operating system, type of device, type of browser, language preference, time and date of accessing the website, click stream in the website, approximate geographical location, etc.;
Purpose of Collection and How We Use It – We will process this data for the purpose of operating, providing, maintaining, protecting, managing, customizing and improving our website and the services offer through the website, as well as for auditing and tracking usage statistics and traffic flow. This data may also be collected for remarketing purpose, as detailed under the “Cookies” section below, and subject to your consent, where required under applicable law.
For EU Individuals: Legal Basis under the GDPR – We process this information based on your consent provided through our cookie notice.
Newsletter:
In the event you sign up to receive our newsletter or other marketing materials, you will be requested to provide your email address and additional information such as, name, company and job title. We will use Upland’s services for our email marketing. Please read Upland’s privacy policy for more information: https://uplandsoftware.com/privacy/
Purpose of Collection and How We Use It – We will use this data solely to send the marketing materials.
In order to Opt-out – you may easily unsubscribe by contacting us at Privacy@ABDGocHizmetleri.com or by other means we will make available (e.g. “unsubscribe” link within the applicable email).
For EU Individuals: Legal Basis under the GDPR – If you registered to our newsletter, you have provided your consent. Otherwise, as our partner or Customer we have legitimate interest to send you such updates and content.
Payment Information:
When you make a payment for our Services or products offered by us using a credit card, you will be asked to submit data such as the credit card number and details.
Purpose of Collection and How We Use It – We will use this information in order to process the payment for our Services.
For EU Individuals: Legal Basis under the GDPR – Performance of a contract
HOW WE COLLECT YOUR DATA
The data detailed above can be collected if you voluntarily provide it (meaning when you contact us), or, automatically, through the use if of certain tracking technologies, for example, through the use of cookies and pixels.
COOKIE POLICY
Our website includes tracking technologies such as cookies and pixels. These tracking technologies are used for the purpose of gathering some information automatically, by ourselves or by service providers on our behalf.
“Cookies” are small text files that are placed on your hard drive by a web server when you access our website or use the Services. Cookies are used for many purposes, and for example, for making the interaction between you and the Services quicker and easier, enabling automatic activation of certain features, efficient navigation, providing the website in an applicable language in accordance with your country, etc., as well as for remarketing purposes (as detailed below).
You can find comprehensive information about cookies at: www.allaboutcookies.org
Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You may remove cookies by following the instructions in your device preferences. However, please note that if you choose to disable cookies, some features of our website may not operate properly and your online experience may be limited.
In addition to our cookies used to operating the website and track performance of our campaigns, we may permit third parties to use cookies or other tracking technologies, as follows:
Analytics and Performance-related Cookies:
Source:
Google.com
Google Analytics.
This cookie is placed in order to track and analyze the use of our Services, for internal purposes, and may include the collection of your IP.
Privacy Policy / Opt Out:
www.google.com/policies/privacy/partners
https://tools.google.com/dlpage/gaoptout
For additional information of our use of Google products, click here.
Essential, Functionality & Operation:
Source:
Google Tag Manager
This cookie is strictly necessary and is used to load scripts into our website pages.
Privacy Policy / Opt Out:
https://policies.google.com/privacy
https://policies.google.com/technologies/managing?hl=en
Targeting & Advertising:
Source:
Google AdWords Remarketing
Facebook Remarketing
Taboola
Outbrain
Yahoo
Privacy Policy / Opt Out:
https://policies.google.com/privacy
https://policies.google.com/technologies/managing?hl=en
https://www.facebook.com/policies/cookies/
https://www.taboola.com/privacy-policy#users
https://www.taboola.com/cookie-policy
https://www.outbrain.com/legal/
https://policies.yahoo.com/xa/en/yahoo/privacy/index.htm
https://policies.yahoo.com/xa/en/yahoo/privacy/topics/cookies/index.htm
You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser.
Please refer to the support page of the browser you are using.
Additionally, you may opt out of certain Advertisers’ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative’s (“NAI”) website – NAI consumer opt-out and the Digital Advertising Alliance’s (“DAA”) website – DAA opt-out page.
SHARING DATA WITH THIRD PARTIES
We do not share any Personal Data collected from you with third parties except in the following events:
Authorized Disclosures: We may disclose your information to third parties when you consent to a particular disclosure. Please note that once we share your information with another company, that information becomes subject to the other company’s privacy practices;
Legal Requirement: We may share your information in this situation, only if we are required to do so in order to comply with any applicable law, regulation, legal process or governmental request (e.g., to comply with a court injunction, comply with tax authorities, etc.);
Third Party Rights: We may share your information in order to prevent harm to the rights (including any legal rights), property (including intellectual property) or other or safety of us, our users or any applicable third party;
Affiliated Companies and Corporate Transactions: We may share your information with our parent company, any of our subsidiaries, joint ventures, or other companies that are under common control with the Company (“Affiliated Companies”) solely if and when applicable or necessary for the purposes described in this Policy, as well as in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, we will make our best efforts to ensure that our Affiliated Companies or acquiring company assumes the rights and obligations as described in this Policy.
Service Providers & Business Partners. We may share your information with third parties that perform services on our behalf (e.g., analytic services). Certain of our Service Providers shall include governmental agencies and representatives, legal advisers or consultants.
We reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed Non-Personal Data to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.
YOUR RIGHTS
Data protection and privacy laws may provide you with the ability to exercise some rights regarding your Personal Data that we hold (which might be different in each jurisdiction). Please review our Privacy Rights Policy to learn more. In addition, if you wish to submit a request to exercise your rights, please download our Data Subject Request Form and send it to: Privacy@ABDGocHizmetleri.com
When you contact us and request to exercise your rights regarding your Personal Data, we will require certain information from you in order to verify your identity and locate your data and that the process of locating and deleting the data may take reasonable time and effort, as required or permitted under applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.
DATA RETENTION
We retain the Non-Personal Data we collect for as long as needed to provide the Service, carry out our business purpose, perform our contract with you, and to comply with our legal obligations, resolve disputes and enforce our agreements, in accordance and compliance with applicable laws, or until an individual request us to delete its Personal Data, as detailed above.
We are entitled to rectify, replenish or remove incomplete or inaccurate information, at any time and at our sole discretion.
SECURITY
We use physical, technical and administrative security measures for the Services that we believe are in compliance with applicable laws and industry standards in order to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed or accidentally lost. For more information, please see our security policy available here: https://www.abdgochizmetleri.com/en/security-policy/
If you feel that your privacy was treated, or if suffered from individual attempt to abuse our Site or Service or acted in an inappropriate manner, please contact us directly at: Privacy@ABDGocHizmetleri.com
CHILDREN
You represent and warrant that: (i) You are above the age of 18; and (ii) you are of legal competence to enter into this Policy. The Service are not directed or intended for individuals under the age of 18 and we do not knowingly collect or solicit information from them. If we obtain actual knowledge that a user is under 18, we will take steps to immediately delete such user’s Personal Data. If you become aware or have any reason to believe that an individual that is under the age of 18 has shared any information with us, please contact us at: Privacy@ABDGocHizmetleri.com
TRANSFER OF YOUR DATA
We may store or process your information in the United States or in other countries. If you are a resident of the European Economic Area (“EEA”) we will take appropriate measures to ensure that your information receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where transfer of your data requires your consent, then your consent to this Policy includes your express consent for such transfer of your Personal Data.
AMENDMENTS
We reserve the right to periodically amend or revise the Policy which will go into effect immediately upon the implementation of the revised Policy on our website. We will make a reasonable effort to notify you in the event that we implement any changes that substantially changes our privacy practices. We recommend that you review this Policy periodically to ensure that you understand our privacy practices and to check for any amendments.
CONTACT US
You may contact us by sending an email to the Data Protection Officer at: Privacy@ABDGocHizmetleri.com
