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Who Analytics Dijital Hizmetler Ltd. Şti. including all of its affiliates (collectively, "Who Analytics" or "We") respects your privacy and is committed to protecting it through our compliance with this policy. With this privacy policy, we would like to inform you how we process your personal data.
The data controller according to art. 4 European General Data Protection Regulation ("GDPR") is Who Analytics Dijital Hizmetler Ltd. Şti., Vişnezade Mah. Süleyman Seba Cad. No:79/1 Beşiktaş, Istanbul, Türkiye.
Responsible for data processing in contracts with your respective contractual partner:
If one of our subsidiaries is the data controller and the registered office is outside the EU, its EU Representative is Who Analytics Dijital Hizmetler Ltd. Şti., Vişnezade Mah. Süleyman Seba Cad. No:79/1 Beşiktaş, Istanbul, Türkiye
In case of any questions relating to data protection, please get in touch with us at privacy@whotechs.com.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. This policy may change from time to time (see Changes to our Privacy Policy). If you are a California resident, please also review our California Resident Privacy Notice ("CCPA").
Personal data is all information relating to personal and objective circumstances through which a person may be personally identified. This may for example entail information such as your name, address or other contact details such as phone number or e-mail address.
We base the processing of your data on the following legal bases:
When processing your data on the basis of art. 6 para. 1 lit. f) GDPR, we pursue the following legitimate interests:
Furthermore, with this information we will be able to ensure the stability and security of our website.
We use information that we collect about you or that you provide to us, including any personal information:
We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, you may elect to unsubscribe and we will cease using your information in that manner.
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at Who Analytics Dijital Hizmetler Ltd. Şti., Vişnezade Mah. Süleyman Seba Cad. No:79/1 Beşiktaş, Istanbul, Türkiye, via email at privacy@whotechs.com.
This privacy policy and the CARU icon shown on our websites and online services, confirm that Who Analytics, is a valid licensee and participating member in the CARU Safe Harbor Program (“CARU Safe Harbor”). To protect your privacy, we have voluntarily undertaken this privacy initiative. CARU has reviewed and certified that we meet established online information collection and use practices on all Who Analytics’s websites and online services where this privacy policy is posted.
As part of the CARU Safe Harbor, we are subject to audits and frequent monitoring of our websites and online services and other enforcement and accountability mechanisms administered independently by CARU.
If you believe that we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, please contact CARU at:
CARU Safe Harbor
Attn: Director
1676 International Drive #550
McLean, Virginia 22102
InfoCaru@bbbnp.org
PLEASE NOTE: CARU is not a data controller or a data processor for Who Analytics, and cannot process personal data requests made pursuant to CCPA. Please direct your personal data request directly to Who Analytics, through the link in our privacy policy under “Your California Privacy Rights”.
We receive the information from you (including about the devices you use). In addition, if we do not collect the personal data directly from you, we will also tell you the source of the personal data and, if applicable, whether it comes from publicly available sources.
We collect several types of information from and about users who visit our Website via internet connection or through your device which you use to access our Website, including certain user details. Such information includes:
Furthermore, we are processing data with which you may be personally identified such as your name, postal address, e-mail address, phone number and any other identifier with which you may be contacted online or offline ('personal data') insofar as you provide us with this data in our online form. Keep in mind that we also handle correspondence and process data to that respect.
The technologies we use for this data processing may include:
The information we collect on or through our Website may include:
You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Some third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
Automated decision-making - including profiling - does not take place.
Unless this is expressly stated, the provision of your data is not required or obligatory.
We store your data:
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you provide as described in this privacy policy:
We may also disclose your personal information:
Unless otherwise stated herein, your personal data will be processed on our servers. If we have commissioned technical service providers, they will only process the data after having received express instructions and they are contractually obliged to guarantee adequate technical and organizational measures for data protection. Insofar as we refer to integrated services of other providers in this privacy policy, it can be assumed that personal data will be transmitted to the specified headquarters of these providers. These providers may be based in a so-called third country outside the European Economic Area.
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
If you subscribe to our newsletter, we will process your e-mail address and data to verify your subscription. You can cancel your subscription at any time by sending a message to us or by clicking the 'unsubscribe' button in every email.
As the data subject, you have the right of access (art 15 GDPR), the right to rectification (art 16 GDPR), the right to erasure of your personal data (art 17 GDPR), the right to restriction of and object to the processing of your personal data (art 18 GDPR and art. 21 GDPR) as well as the right to data portability (art 20 GDPR). Furthermore, you have the option to file a complaint against the processing of your personal data with a supervisory authority (for example, the data protection authority responsible for us, which is the Berliner Beauftragte für Datenschutz und Informationsfreiheit at https://www.datenschutz-berlin.de/, Art. 77 GDPR).
If you have given your consent to the processing of your data, you can withdraw the given consent at any time (art.7 para.3 GDPR) by sending us an email to privacy@whotechs.com. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
You can object to the processing of your personal data insofar as we base the processing of your personal data on our legitimate interests. This is the case in particular if the processing is not necessary for the fulfillment of a contractual obligation to you, which we in each case present in the description of the functions which follow. In case of such objection, we kindly ask for an explanation of the reasons for the objection against the processing of your personal data. In the case of your justified objection, we will examine the situation and will either discontinue or adapt the data processing or point out to you our compelling legitimate reasons based on which we continue the processing your personal data.
Of course, you can object to the processing of your personal data for direct marketing purposes at any time.
In this case, please send an e-mail to privacy@whotechs.com.
If you are a California resident, please review our California Resident Privacy Notice ("CCPA") for information regarding your California privacy rights.
If personal data is being transferred to countries outside the European Economic Area, we only transfer it to third countries where the EU Commission has confirmed an adequate level of protection or where we can ensure the careful handling of personal data by means of contractual agreements (Standard Contract Clauses) or other suitable guarantees, such as certifications or proven compliance with international security standards. Information on this is available from us upon request.
Who Analytics complies with the EU-U.S. Data Privacy Framework (“DPF”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. We have certified to the U.S. Department of Commerce that it adheres to the DPF Principles. If there is any conflict between the terms in this privacy policy and the DPF Principles, the DPF Principles shall govern. To learn more about the DPF program, and to view the certification of Who Analytics, please visit https://www.dataprivacyframework.gov/s/
In compliance with the DPF Principles, we are committed to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our DPF policy should first contact us at: privacy@whotechs.com
We have further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved DPF complaints concerning data transferred from the EU. We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). You have the possibility, under certain conditions, to invoke binding arbitration. Please be aware, that we are required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Furthermore, we take liability in cases of onward transfers to third parties.
We use the Google Analytics service of the provider Google Ireland Limited Gordon House, Barrow Street, Dublin 4, Ireland on our website.
Google Analytics is a web analytics service that allows us to collect and analyze data about the behavior of visitors to our website. Google Analytics uses cookies for this purpose, which enable an analysis of the use of our website. This involves processing of personal data in the form of online identifiers (including cookie identifiers), IP addresses, device identifiers, and information about interaction with our website.
Some of this data is information that is stored on the terminal device you are using. In addition, further information is also stored on your end device via the cookies used. Such storage of information by Google Analytics or access to information that is already stored on your terminal device only takes place with your consent.
Google Ireland will process the data collected on our behalf to evaluate the use of our website by the users, to compile reports on the activities within our website, and to provide us with further services associated with the use of our website and the use of the internet. In doing so, pseudonymous usage profiles of the users can be created from the processed data.
The personal data processed on our behalf to provide Google Analytics may be transferred to any country in which Google Ireland or Google Ireland's sub-processors maintain facilities. Please note the information in the section "Data transfer to third countries".
In addition to the option to reject Google Analytics in our Consent Banner, you can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: [Google Analytics Opt-out Browser Add-on](https://tools.google.com/dlpage/gaoptout?hl=en).
We only use Google Analytics with IP anonymization enabled. This means that the IP address of the user is shortened by Google Ireland within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the IP address be transferred to Google on a server in the USA and shortened there. The IP address transmitted by the user's browser is not merged with other data. You can find Google's privacy policy here: [Google Privacy Policy](https://policies.google.com/privacy?hl=en-US).
We use the Google Analytics 4 variant, which allows us to track interaction data from different devices and from different sessions. This allows us to put individual user actions in context and analyze long-term relationships.
The data about user actions are stored for a period of 14 months and then automatically deleted. All other event data is stored for 2 months and is then automatically deleted. Thereby, the deletion of the data whose storage period has expired takes place automatically once a month.
We use the online advertising program Google Ads of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”) on our website, through which we place advertisements on the Google search engine. When you access our website via a Google ad, Google sets a cookie on your terminal device ("conversion cookie"). In the process, a different conversion cookie is assigned to each Google Ads customer, so that the cookies are not tracked across the websites of different Ads customers. The information obtained with the help of the cookie is used to create conversion statistics. This tells us the total number of users who clicked on one of our Google ads. However, we do not receive any information with which users can be personally identified. When using the service, a transfer of your data to the USA cannot be excluded. Please note the information in the section "Data transfer to third countries". You can find Google's privacy policy here: [Google Privacy Policy](https://policies.google.com/privacy?hl=en-US).
We also use the Google Analytics advertising features (remarketing) from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. This function enables us, in conjunction with the cross-device functions of Google, to display advertisements in a more targeted manner and to present users with ads that are tailored to their interests. Via the remarketing, users are shown ads and products for which interest has been identified on other websites in the Google network. The function allows us to link advertising target groups created via Google Analytics Remarketing with the cross-device functions of Google Ads. In this way, interest-based, personalized advertising messages that have been adapted to a user depending on previous usage and surfing behavior on an end device (e.g. cell phone) can also be displayed on another end device of the user (e.g. tablet or PC).
If you have given your consent, Google will link your web and app browsing history with your Google account for this purpose. In this way, the same personalized advertising messages can be placed on every end device on which you log in with your Google account. The aggregation of the collected data in your Google account is based solely on your consent, which you can give or withdraw at Google. For these linked services, data is then collected via Google Analytics for advertising purposes. To support the remarketing function, Google Analytics collects users' Google-authenticated IDs, which are temporarily linked to our Google Analytics data. This is used to define and create target groups for cross-device ad advertising.
Privacy policy of Google: [Google Privacy Policy](https://policies.google.com/privacy?hl=en-US)
Further information and setting options for personalized advertising at Google can be found here: [Manage Your Google Ads Settings](https://support.google.com/My-Ad-Center-Help/answer/12155451?hl=en&sjid=174251308182856932-EU).
We use the Signals feature of Google Analytics, a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Signals recognizes individual users using different devices (so-called cross-device tracking). We only receive anonymous data in the form of a report that shows patterns in user behavior. Google Signals helps us to better understand how visitors interact with our website and to show more meaningful and personalized ads to these visitors after leaving our website.
For this, session data is being processed and linked with website visitors that
If you do not wish to be subject to the Signals feature, you can deactivate the “Ads personalization” feature in your Google account.
The privacy policy of Google can be found here: [Google Privacy Policy](https://policies.google.com/privacy?hl=en)
We use the "visitor action pixels" from Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Meta") on our website. This allows user behavior to be tracked after they have been redirected to our website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Meta, which is why we are informing you, based on our knowledge of the situation. Meta may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook's Data Usage Policy. You can allow Meta and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes. You can object to the collection of your data by Meta pixel or to the use of your data for the purpose of displaying Facebook ads in your account settings. You can find Meta's privacy policy here: [Meta Privacy Policy](https://de-de.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0).
The LinkedIn Insight Tag is a piece of lightweight JavaScript code that we have added to our websites to enable in-depth campaign reporting and to help us unlock valuable insights about our website visitors. The LinkedIn Insight Tag is offered by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. We use the LinkedIn Insight Tag to track conversions, retarget website visitors, and unlock additional insights about members interacting with our LinkedIn adverts. The LinkedIn Insight Tag enables the collection of metadata such as IP address information, timestamp, and events such as page views. All data is encrypted. The LinkedIn browser cookie is stored in a visitor's browser until they delete the cookie or the cookie expires. You can opt out of cookies from LinkedIn on your LinkedIn settings page and recommend you read their [Cookie Policy](https://www.linkedin.com/legal/privacy-policy) for more information. You can find LinkedIn's privacy policy here: [LinkedIn Privacy Policy](https://www.linkedin.com/legal/privacy-policy).
Marketing Cloud Account Engagement is a B2B marketing automation tool by Salesforce, which we use to keep customers informed about upcoming events, product updates/ new features, etc. This marketing tool is embedded in our website for general marketing purposes, including e-mail, social media, digital ads, web management, and analytics. For this marketing tool, we use cookies to identify you when you visit and re-visit our website. With this tool, we track different data points when you are using our website to improve the website content we provide to you as well as to improve our marketing campaigns and make their content more relevant for you.
For more information on Salesforce's privacy policy, you can find their privacy policy here.
Drift Inc., 222 Berkeley Street, Suite 600, Boston, MA 02116, USA, is providing a conversation-driven marketing platform. We have implemented Drift’s chatbot tool on our website to engage and communicate with website visitors interested in our services. For this, Drift records conversation data, IP address, and contact information.
Drift's privacy policy can be found here.
We use Universal Event Tracking (UET) on our website via the Microsoft Advertising service of Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. Via UET, Microsoft stores a cookie in the user's browser to enable an analysis of the use of our online offer. The prerequisite for this is that the user has reached our website via an advertisement from Microsoft Advertising. In this way, we and Microsoft can recognize that someone has clicked on an ad, has been redirected to our online offer, and has reached a previously determined target page (conversion measurement). No IP addresses are stored in this process. No further personal information about the identity of the user is communicated either.
For more information on data protection at Microsoft, please refer to Microsoft's privacy statement here. Microsoft offers the opportunity to opt out here.
We use 6sense, a marketing automation software on our website. The service is provided by 6sense Insights, Inc., 450 Mission Street, San Francisco, CA 94105, United States. 6sense enables us to identify and target B2B prospects who have shown interest in our services. This allows us to optimize and improve our marketing strategy.
The data shared with 6sense includes the cookie and other online identifiers, names, email addresses, phone numbers, social media contact information, company names, customer status, industry, and job descriptions, websites visited, location information, and commercial interests. We process this data based on your consent as well as based on our commercial marketing interests. You can find more information about the data processed by 6sense in their privacy policy here.
We use G2 Track Your Prospects, a marketing analytics service on our website. The service is provided by G2.com, Inc., 100 S. Wacker Drive, Chicago, IL 60606, United States. G2 allows us to identify and target B2B prospects who have shown interest in our services to optimize and improve our marketing strategy.
The data shared with G2 includes the data collected by Google Analytics as well as data about your activity on our website as well as on the G2 website, namely cookie and other online identifiers, information stored in your G2 profile, information about your industry, customer status, websites visited, and website usage information, location information, and likely commercial interests. We process this data based on your consent as well as based on our commercial marketing interests. You can find more information about the data processed by G2 in their privacy policy here.
We use the consent technology of Usercentrics A/S, Havnegade 39, 1058 Copenhagen, Denmark (hereinafter "Cookiebot") to obtain consent for the storage of certain cookies on your terminal device or for other actions requiring consent and to document and manage these in accordance with data protection laws.
The privacy policy of Cookiebot can be found here.
In our sales activities, we use the "Gong" service of Gong.io Inc., 265 Cambridge Ave, Suite 60717, Palo Alto, CA 94306, USA. We use Gong to record, transcribe and analyse video conferences between our sales staff and you. The service is used exclusively with your consent for the purpose of employee training. You will find Gong's Privacy Policy here.
We use Facebook Lead Ads from Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. Users may submit their contact information to us through certain advertisements, which we then process for promotional and advertising purposes. For more information visit: here.
LinkedIn, meaning LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Irland, offers Ads that allow people to submit their contact and other information to us ("Lead Gen Forms"). We process the data transmitted to us for advertising purposes. You entered data will also be processed by LinkedIn. For more information visit: here.
To better understand any possible errors in the source code of our dashboard, we share some data from our dashboard users with Rollbar, Inc., 665 3rd St Ste 150, San Francisco, California, 94107, USA. These data include the dashboard user's name, email address, and device information, such as a description of the error or bug the dashboard user experienced while using the dashboard. For further information please refer to Rollbar's privacy policy at here.
We operate a Facebook page (so-called "Fanpage") on Facebook, a service of Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2.
We are jointly responsible with Meta Platforms Ireland Ltd. for the collection and processing of data of visitors to our Fanpage. The legal basis for this processing is our legitimate interest in improving the user experience when visiting our Fanpage, in effective promotional activities using social media and communication about specific products, and measuring and adjusting such activities., art. 6 para. 1 lit. f) DSGVO. We have therefore concluded a joint controller agreement with Meta regarding the processing of your data pursuant to Art. 26 DSGVO. The agreement with Meta also regulates in particular which security measures Meta must observe and that Meta must fulfill the data subject rights.
You can find more information about page insights as well as information on how to assert your data subject rights in the "Information on page insights". You can view the terms and conditions of the contract concluded with Meta here. You can find Meta's privacy policy here.
We operate a LinkedIn page on LinkedIn, a service of LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.
We are jointly responsible with the LinkedIn Ireland Unlimited Company for the collection and processing of information about visitors to our page. The legal basis for this processing is our legitimate interest in improving the user experience when visiting our LinkedIn Page, in effective promotional activities using social media and communication about specific products, and measuring and adjusting such activities, art. 6 para. 1 lit. f. GDPR. We have therefore concluded an agreement with LinkedIn on joint responsibility with regard to the processing of your data in accordance with art. 26 GDPR. In particular, the agreement with LinkedIn also regulates which security measures LinkedIn must observe and that LinkedIn must comply with the rights of data subjects.
You can find further information on the Page-Insights as well as instructions on how to assert your data subject rights in the privacy policy of LinkedIn (here). The terms of the agreement concluded with LinkedIn can be viewed here.
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our website and this privacy policy to check for any changes.
Who Analytics Dijital Hizmetler Ltd. Şti.
Vişnezade Mah. Süleyman Seba Cad. No:79/1 Beşiktaş, Istanbul, Türkiye
Seat of company: Istanbul, Turkey
E-mail: info@whotechs.com
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