Privacy Policy

COCRM PRIVACY POLICY

These Privacy Policy were last updated on November 01, 2024.



  1. About this Policy

  2. Your rights and control over your personal data

  3. Personal data we collect about you

  4. Our purpose of using your personal data

  5. Sharing your personal data

  6. Data retention and deletion

  7. Transfer of data to other countries

  8. Keeping your personal data safe

  9. Changes to this Policy

  10. How to contact us



  1. About this Policy


Thank you for joining COCRM. At COCRM we respect your privacy and want you to understand how we collect, use and share data about you. This Privacy Policy covers our data collection practices and explains your rights regarding your personal data.

Data processing applies to your use of:

• All COCRM streaming services as a user. What is meant here is the use of services offered under our free or paid options.

• Other COCRM services that link to this Privacy Policy.

Hereinafter, these services will be collectively referred to as the "COCRM Service".

In the future, we may develop new services or offer additional services. Such new or additional services will also be subject to this Policy unless stated otherwise.

By using COCRM Services, you agree to the terms of this Privacy Policy.

If you do not agree to this Privacy Policy or any other agreement governing your use of the COCRM Services, you should not use the COCRM Services.

This Policy is not COCRM Terms and Conditions. It is a separate document summarizing the processing of your personal data in addition to the legal agreement between you and COCRM for the use of the COCRM Service. It also explains COCRM’s rules and your user rights.

  1. Your rights and control over your personal data

Under Article 11 of the Turkish Personal Data Protection Law No. 6698 ("Personal Data Protection Law") and privacy laws, including GDPR (General Data Protection Regulation), individuals have rights concerning their personal data. These rights include:

  • Learning whether your personal data is being processed,

  • Requesting information if your personal data has been processed,

  • Learning the purpose of processing your personal data and whether it is used appropriately for its purpose,

  • Knowing the third parties to whom your personal data is transferred, domestically or abroad,

  • Requesting correction of your personal data if it has been processed inaccurately or incompletely,

  • Requesting deletion or destruction of your personal data under the conditions stipulated in the relevant legislation,

  • Requesting notification to third parties with whom your personal data has been shared of any correction, deletion, or destruction,

  • Objecting to any unfavorable result arising from the analysis of your personal data exclusively through automated systems,

  • Requesting compensation if you suffer damage due to unlawful processing of your personal data.

These rights empower individuals to control and protect their personal data under applicable data protection laws.



  1. Personal data we collect about you



Collected when you sign up for the COCRM Service or when you update your account

Category

Description

User Data

Personal data that we need to create your COCRM account and enables you to use the COCRM Service. The type of data collected depends on the type of Service Option you have, how you create your account, the country you are in, and if you use third party services to sign in. This may include your:

  • Full Name

  • Email Address

  • Phone Number

  • Date of Birth

  • Gender

  • Full Address

  • Country - City

  • Education Level

  • Company Name

  • Company Address

  • Company Representative's Full Name

  • Company Email Address

  • Company Phone Number

  • Company Documents


We receive some of this data from you e.g. from the sign up form or account page. We also collect some of this data from your device e.g. country.


Address Data

We may ask for your address for the following reasons:

  • to check eligibility for a Service Option

  • for tax administration

  • to deliver physical goods or gifts requested by you

In some cases, we may use a third party mapping application (such as Google Maps) to help you verify your address.


Collected through your use of the COCRM Service

Categories

Description

Usage Data

Personal data collected about you when you’re accessing and/or using the COCRM Service. There are a few types of information this includes, detailed in the following sections.Information about how you use COCRM.Examples:

  • Information about your COCRM Service Option.

  • Your actions with the COCRM Service (including date and time), such as:

    • search queries

    • browsing history

    • account settings

    • interactions with other COCRM users

    • your use of third party services, devices and applications in connection with the COCRM Service

    • video and sound recording

    • skills and certificates

  • Inferences of your interests and preferences based on your usage of the COCRM Service.(our understanding)

  • Content you post to any part of the COCRM Service, such as images, text, communications, and other types of content.


Your technical data


Examples:

  • URL information

  • Online identifiers such as cookie data and IP addresses

  • Information about the devices you use such as:

    • device IDs

    • network connection type (e.g. wifi, 4G, LTE, Bluetooth)

    • provider

    • network and device performance

    • browser type

    • language

    • information enabling digital rights management

    • operating system

    • COCRM application version

  • Information (such as the device name, device identifiers, brand and version) which enables us to discover and connect with third party devices and applications such as those listed below:

    • devices on your wifi network (such as speakers) which can connect to the COCRM Service

    • devices made available by your operating system when connecting via Bluetooth, plugin, and installation

    • COCRM partner applications to determine whether the application is installed on your device

Your general (non-precise) location


This may be understood from technical data (e.g. your IP address, language setting of your device, or payment currency).


This data is required both in order to meet the geographical requirements in the contracts we have with the companies that are the owners of the advertisements and content published on the COCRM Service, to offer you contracts suitable for your geographical location, and to offer you appropriate content and advertisements.



Additional data you may choose to give us

Categories

Description

Payment and Purchase Data

If you make any credit purchases from COCRM (including a paid Service Option) or sign up for a trial, we will need to process your payment data.
The exact personal data collected will vary depending on the payment method, but will include information such as:

  • name - surname

  • date of birth

  • credit or debit card type, expiration date, and certain digits of your card numberNote: For security, we never store your full card number

  • postal code

  • mobile phone number

  • details of your purchase and payment history


Collected from other (‘third party’) sources

Categories of third parties

Description

Authentication partners

If you register for or log into our services using another service, we’ll receive your information from them to help create your account with us.

Third party applications, services and devices you connect to your COCRM account

If you connect your COCRM account to a third party application, service and/or devices, we may collect certain information from them to make the integration possible.
These third party apps, services or devices may include:

  • social media

  • devices including:

    • audio (e.g. speakers and headphones)

    • smart watches

    • mobile phones and tablets

Technical service partners

We work with technical service partners that give us certain data, such as mapping IP addresses to non-precise location data (e.g., city, state).

This makes it possible for COCRM to provide the COCRM Service, content, and features.

Payment partners

We may get data from our payment partners.

This allows us to:

  • send you invoices

  • process your payment

  • give you what you’ve purchased

Advertising and marketing partners

We may get data about you from certain advertising or marketing partners.

This may include:

  • cookie id

  • mobile device id

  • email address

  • inferences of your interests and preferences(our understanding)





  1. Our purpose of using your personal data

The table below sets out:

  • our purpose for processing your personal data


  • our legal justifications (each called a "legal basis") under data protection law, for each purpose


  • categories of personal data which we use for each purpose (see more about these categories in section 3 'Personal data we collect about you')





Purpose for processing your data

Legal basis that permits the purpose

Categories of personal data used for the purpose

To provide the personalized COCRM Service. (You can watch our video about Personalization to understand more.)

  • Performance of a Contract

  • Legitimate interest

  • Consent

  • User Data

  • Usage Data

  • Payment and Purchase Data

  • Street Address Data

To understand, diagnose, troubleshoot, and fix issues with the COCRM Service.

  • Performance of a Contract

  • Legitimate interest

  • User Data

  • Usage Data

To evaluate and develop new features, technologies, and improvements to the COCRM Service.

  • Legitimate interest

  • Consent

  • User Data

  • Usage Data


For marketing, promotion, and advertising purposes.

  • Legitimate interest

  • Consent

  • User Data

  • Usage Data

To comply with legal obligations and law enforcement requests.

  • Compliance with legal obligations

  • Legitimate interest

  • User Data

  • Usage Data

  • Payment and Purchase Data

  • Street Address Data

fulfill contractual obligations with third parties, for example our agreements with owners of content on the COCRM Service, and

  • take appropriate action with reports of intellectual property infringement and inappropriate content.

  • Legitimate interest

  • User Data

  • Usage Data

  • Payment and Purchase Data

To establish, exercise, or defend legal claims.

  • Legitimate interest

  • User Data

  • Usage Data

  • Payment and Purchase Data

  • Street Address Data

  • Contests, Surveys and Sweepstakes Data

To conduct business planning, reporting, and forecasting.

  • Legitimate interest

  • User Data

  • Usage Data

  • Payment and Purchase Data

To process your payment.

  • Performance of a Contract

  • Compliance with legal obligations

  • User Data

  • Payment and Purchase Data

To detect and prevent fraud, including fraudulent payments and fraudulent use of the COCRM Service.

  • Performance of a Contract

  • Compliance with legal obligations

  • Legitimate interest

  • User Data

  • Usage Data

  • Payment and Purchase Data

  • Street Address Data


To conduct research, contests, surveys, and sweepstakes.

  • Performance of a Contract

  • Legitimate interest

  • Consent

  • User Data

  • Usage Data

  • Contests, Surveys and Sweepstakes Data





  1. Sharing your personal data



Categories of recipients

Reason for sharing

Third party applications, services and devices you connect to your COCRM Account

To connect your COCRM account, and/or allow you to use the COCRM Service in connection with third party applications, services or devices.

For example, for such third-party applications, services and devices; Social media applications and servers that interact with the COCRM Service.

Other COCRM users

Bring users together by sharing information about your use of the COCRM Service and your profile with other COCRM users.





  1. Data retention and deletion

Retention

We keep your personal data only as long as necessary to provide you with the COCRM Service and for COCRM’s legitimate and essential business purposes, such as:

  • maintaining the performance of the COCRM Service

  • making data-driven business decisions about new features and offerings

  • complying with our legal obligations

  • resolving disputes

Deletion

If you close or request a closing account we'll delete or anonymise your personal data so it no longer identifies you unless we're required to keep something or we still need to use it for a legally justifiable reason.

Here are some examples of situations where we're legally allowed or required to keep some of your personal data:

  • if there's an unresolved issue relating to your account such as an outstanding payment or unresolved claim or dispute

  • for our legal, tax, audit and accounting obligations

  • for our legitimate business interests such as fraud prevention or to maintain security.



  1. Transfer of data to other countries

When carrying out the activities described in this Policy COCRM shares your personal data internationally with COCRM group companies, subcontractors and partners in order to provide the COCRM Service to you. They may process your data in countries whose data protection laws are not considered to be as strong as EU laws or those in your country, e.g. they may not give you the same rights over your data.

Whenever we transfer personal data internationally we use tools to:

  • make sure the data transfer complies with applicable law

  • help to give your data the same level of protection as it has in the EUROPE

We do this using a variety of protections as appropriate for each data transfer. For example, we use:

  • legal tool to require the third party to protect your data and to provide you with EU -level rights and protections

  • technical protections such as encryption and pseudonymisation

  • policies and processes to challenge disproportionate or unlawful government authority requests



  1. Keeping your personal data safe

We're committed to protecting our users personal data. We implement appropriate technical and organizational measures to help protect the security of your personal data. However, be aware that no system is ever completely secure.

We have implemented various safeguards including pseudonymisation, encryption, access, and retention policies to guard against unauthorized access and unnecessary retention of personal data in our systems.

To protect your user account we encourage you to:

  • use a strong password that is unique to your COCRM account

  • never share your password with anyone

  • limit access to your computer and browser

  • log out once you have finished using the COCRM Service on a shared device

It's your responsibility to only provide individuals with permission to use your account where you're comfortable sharing this personal data with them. Anyone else's use of your COCRM account may impact your personalized recommendations and be included in your data download.





  1. Changes to this Policy

We may update this Privacy Policy, if needed. If we make any material changes we will notify you by email, by posting a notice on the Services or as required by law. We also include a summary of important changes. Unless otherwise stated changes take effect on the day they are posted.

As permitted by applicable law, if you continue to use the Services after the effective date of any change your access and/or use constitutes your acceptance of (and consent to abide by and be bound by) the revised Privacy Policy. The revised Privacy Policy replaces all previous Privacy Policies.



  1. How to contact us

For any questions or concerns about this Policy contact us any one of these ways:

  • Use our Contact Us

  • Gülbahçe Mah. İçmeler Cad. No:14/1 İç Kapı No: B05 Urla / İzmir

  • Email info@cocrm.co

Last Updated: 13 11 2024
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