Vision App Privacy Policy

Your privacy is very important to us at Airties (Airties Kablosuz Iletisim Sanayi ve Dis Ticaret A.S., incorporated and registered in Şehit Mehmet Mikdat Uluünlü Sokak No: 23, Esentepe Sisli Istanbul Turkey with tax number 010 030 2558 and company registration number 516005, hereafter also “we” and/or “us” and/or “Airties”).

To protect your privacy, we provide this policy explaining our online information practices and the choices you can make about the way your information is collected and used. To make this policy easy to find, we make it available on our website and in our Vision App.

1. General Terms:

This privacy policy informs you about how Airties processes and manages personal data when using the Vision App.

2. Contact Information

You can reach us at:

AIRTIES KABLOSUZ İLETİŞİM SAN. VE DIŞ TİC. A.Ş

Şehit Mehmet Mikdat Uluünlü Sokak No. 23 Esentepe

Şişli-Istanbul, Turkey

Zip Code 34394

Telephone number: +90 212 318 62 00

The privacy officer has been designated as the privacy contact person. You can reach the contact person by sending an e-mail to: privacy@airties.com

3. Purpose of Processing and Legal Grounds:

In the following paragraphs, you can read about the purposes of processing personal data and the applicable legal grounds.

Providing our product and our services: it will be necessary for us to process certain data such as device and network details as well as wireless performance data in order to provide the products and services that you ordered (via Airties or your internet service provider) or to which you subscribed, in the context of the delivery of the product and/or service and billing, as well as customer support.

Product development and improvement: naturally we strive to always improve our products and services in order to make them fit our customers’ needs. For this reason, we process data such as device and network information and draw insights in relation to possible improvements.

Mobile app usage: We analyze user behaviors on our mobile app to personalize our products and services based on your experiences.

Complying with our legal obligations: We may process personal data to fulfill our legal obligation.

The processing of your personal data is based on the following legal grounds:

–   Your consent;

–   The preparation or performance of an agreement with you;

–   Compliance with legal obligations;

–   Our legitimate interests.

When we process personal data on the basis of your consent, you can always revoke your consent.

We can be legally or contractually obliged to process your personal data. The processing of your personal data can be necessary to enter into a contract with you. We can also be legally obliged to process your personal data. We can then only continue our relationship with you when you provide us with the required personal data.

We can have a legitimate interest to process your personal data, i.e. improving our products and services collecting app usage statistics

4. Duration

We do not process your personal data for any longer than is necessary for the purposes mentioned in this privacy policy.

When we process your personal data on the basis of the preparation or the performance of an agreement with you, we will store your personal data for as long as the Vision App is used. The storage of personal data ceases once the Vision App is deleted.

When we process your personal data on the basis of a legal obligation, we will store your personal data for the period which is determined by law.

In case of a complaint, dispute or legal claim, we will process your personal data for no longer than for that purpose.

5. Third Parties and International Data Transfers

The data collected by us may be transferred to other Airties entities for the purposes mentioned under Section 3 above as well as to any third parties to whom the relevant Airties entity subcontracts all or part of this processing. We employ other parties to process personal data on our behalf. These are our hosting providers, internet service providers and analytical service providers. Note that we will never sell your data to a third party.

Airties may also, pursuant to a valid legal process (such as a search warrant, subpoena, or court order), allow access to information in our possession, in order to comply with such process and to protect our rights and property. We reserve the right to disclose any data or information obtained from or about you, to third parties in connection with a merger, acquisition, bankruptcy or sale of all or substantially all of our assets, to the extent that this is necessary for the process.

In the event of transfers of personal data outside of the European Economic Area, Airties systematically ensures the application of an adequate level of protection of such data by means approved by applicable data protection legislation. You may request a copy of such measures by getting in touch with us through the contact details above.

To access corresponding data privacy terms of the third parties, please follow the links provided below:

Data Privacy Policy:

•   Cujo: https://cujo.com/privacy/

•   F-Secure: https://www.f-secure.com/en/legal/privacy/consumer/sense

•   Measurement Lab: https://www.measurementlab.net/privacy/

6. Your rights

Under local legislation, you may benefit from various rights as a “data subject”. You can exercise any of the rights listed below by submitting your request by email to privacy@airties.com. Please include the mac address or a serial number of your Airties device. Please note that we may reject requests that are excessive or a misuse of the relevant right.

6.1 Access right and data portability: You may have the right to access your personal data processed by us, as well as to obtain the portability of data you have provided to us to the extent applicable.

6.2 Right of rectification and right to be forgotten: You may also have the possibility to request the rectification or erasure of your personal data, provided that the applicable legal requirements are met.

The right to be forgotten could nevertheless be subject to various exceptions, for example when processing of data is necessary to support litigation or for compliance with statutory retention requirements. In such case, however, we limit our processing to the minimum extent possible.

6.3 Right to restriction, right to object & consent withdrawal (Limits to processing): You may have the right, if applicable legal provisions are met, to object to the processing of personal data based on our legitimate interests and to otherwise obtain the restriction of certain forms of processing in specific circumstances. We will in each case examine your request and check whether you meet the requirements for the processing to be stopped.

6.4 Right to lodge a complaint with the supervisory authorities: if you have any complaints or comments about our privacy practices, we would appreciate it if you could seek contact with us first. Together we can try to find and take away the source of your complaint. At any given time, you have the right to send a complaint about our privacy practices to the authorized supervisory body.

7. Commitment to Data Security

In order to prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.

8. Changes to This Privacy Policy

We may update and change this privacy policy from time to time, as we may find necessary and as our site evolves and grows. While we will do our best to bring updates to your attention, it is your responsibility to keep track of such updates. Our privacy policy has been updated/supplemented on March 21, 2024.