Plajmandali.com Privacy Policy

Last Updated: August 3, 2023

Welcome to Plajmandali.com Privacy Policy!

1. Please read carefully!

Plajmandali.com values the privacy of its visitors and users. In this Privacy Policy ("Policy"), along with its affiliates worldwide, Frater Home Ltd. ("Frater Home," “Plajmandali.com,” "we," "us," "our," or "ours") explains how it collects, uses, and shares your Personal Data, as well as the rights you have as a data subject. This Privacy Policy applies to all Frater Home users, including unregistered users, registered users, and premium users (collectively, "Users," "you," "your," or "yours"), as well as our websites (www.plajmandali.com and all subdomains, collectively, the "Website"), web applications ("Frater Home Applications"), mobile applications ("Mobile Applications"), and all Frater Home services, including the Website and Applications (collectively, the "Services"). This Privacy Policy is not intended to supersede any terms of any agreement you have with us or any rights you may have under the Personal Data Protection Law and/or other applicable laws

Please read this Policy carefully before accessing our Services and ensure that you fully understand our practices regarding your Personal Data. If you read and fully understand this Privacy Policy and do not agree with our practices, you must immediately leave all of our Services and cease all use of our Services. If you have any questions or concerns about this Privacy Policy, please contact us here.

2. What Personal Data do we collect?

2.1. User Data:

We need to collect Personal Data ("Personal Data") belonging to a real person who is determined or can be determined to provide you with the Services. We collect Personal Data from you, your use of the Services, and other sources. The types of Personal Data we collect from you include:

Data you provide to us. When you register for our Services, use any of our Services, and/or contact us through any communication channel (such as Frater Home's contact forms, email addresses), you may provide us with your Personal Data, such as your name, surname, email address, phone number, and any other Personal Data you include in your communications with us.
Data we collect when you use the Services. When you visit, download, and/or use any of our Services, for example, the Visitor or User's device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring and visited pages, date and time stamps, etc. Non-identifying aggregated usage data, including the browsing and clicking activities of Visitors and Users on the Services, session heatmaps, and scrolls, may be collected.
Data we collect from other sources. For example, i) security service providers that help us identify Users engaged in fraudulent activities, providers of fraud detection and prevention services; ii) social media platforms - when you log in or register with your social media account, we may obtain your Personal Data from that service (such as your username, basic profile information) - and in some cases, companies that provide customer prospecting services to help us improve our services; iii) third parties such as our advertising and marketing partners with whom we collaborate to track, manage, and measure our advertising campaigns.

2.2. End-user data

Additionally, we may collect the Personal Data of the visitors and users of our Users' websites or services ("End-users") on behalf of and for our Users (as detailed further in Section 6 below).

3. How do we use this Personal Data?

We use this Personal Data for various purposes, including:

Provide and operate the Services,
Improve, customize, expand, and enhance our Services based on user preferences, experiences, and issues encountered by users,
Provide uninterrupted customer and technical support to our users,
Update, expand, and analyze our records to identify potential new customers,
Enable and sponsor specific contests, events, and promotions, verify participant eligibility, monitor performance, contact winners, and provide prizes and awards,
Generate aggregate statistical data and other aggregated and/or inferred Personal Data that we or our partners may use to provide and improve our services,
Create aggregated statistical data and other aggregated and/or inferred Personal Data that we or our partners may use to provide and improve our services,
Provide professional support to you only upon request,
Enhance data security and fraud prevention capabilities,
Comply with all applicable laws and regulations, including the Personal Data Protection Law.

To improve our services, we may use techniques such as "machine learning" (referred to as "automated decision-making" in European law). When we employ machine learning, it either involves (i) human participation in the process (thus it's not completely automated); or (ii) we use machine learning in ways that do not have significant privacy implications. We may also use machine learning to help monitor, identify, and suspend accounts involved in spam-sending or other abusive or fraudulent activities.

In the following situations, we use your Personal Data for the purposes outlined in Section 3:"

We use your Data when it is necessary for the performance of a contract with you or to take steps at your request before entering into a contract (for example, to provide you with customer or technical support).
We use your Data when it's necessary to fulfill a legal obligation or a duty imposed by a regulatory authority.
We use your Personal Data, provided it is done proportionally and does not violate your privacy rights, when necessary to support our legitimate interests and business purposes (such as maintaining and improving our services and the effectiveness of Frater Home by identifying technical issues).

4. How do we share your Personal Data?

We may share your Personal Data with service providers and others in the following ways and circumstances (or otherwise allow them access to this information):

Third-Party Service Providers: Frater Home partners with a select group of service providers whose services and solutions complement, facilitate, and support our own. These services and solutions include hosting and server co-location services, communication and content delivery networks (CDNs), data and cybersecurity services, billing and payment processing services, domain name registration, fraud detection and prevention services, web analytics, email distribution and tracking services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, "Third-Party Service Provider/Providers").

Frater Home may share Personal Data in the following categories with Third-Party Service Providers for a business purpose:

Name and surname, other names, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, and other similar data identifying or related to the identification of a real person.
Commercial Personal Data, for example, Personal Data related to products and services purchased, obtained, or considered for purchase.

4.1. Law Enforcement, Legal Requests, and Duties: Frater Home may disclose or otherwise allow access to any category of your Personal Information described in this Privacy Policy, with or without notice to you, in compliance with a legal request such as a subpoena, legal proceedings, search warrant, or court order, or as per applicable laws, if we believe that the law requires it.

4.2. Protection of Rights and Security: Frater Home may share any category of your Personal Information described in the Privacy Policy, with or without notice to you, if we believe it's necessary to protect the rights, property, or personal safety of Frater Home, any of our users, their users, or any member of the public.

4.3. In connection with a change in corporate control: Additionally, if Frater Home or any of its affiliates undergoes any change of control, including a merger, acquisition, or sale of all or substantially all of its assets, your Personal Information may be shared with the parties involved in such an event.

4.4. Upon Your Further Instructions: Frater Home Services allow you to use and procure various third-party services, products, and tools to enhance your web or mobile sites, including but not limited to applications and widgets offered by third parties through the Frater Home Website, e-commerce payment providers, third-party designers who may assist with your website, etc. (collectively "Third-Party Services"). If you choose to interact with such Third-Party Services, they may access and process the Personal Information of End Users collected through your web or mobile sites. For example:

a) Framed Pages: Our services may allow you to directly integrate Third-Party Services into your web or mobile sites using methods like page framing techniques to present content from Third-Party Services or other parties ("Frames"). In such cases, Third-Party Services may collect Personal Information from End Users.

b) Developers: We allow third-party developers ("Third-Party Developer(s)") to develop and offer their applications to users through the Frater Home Application Market ("Third-Party Application(s)") that can be integrated into your web or mobile sites. Each Third-Party Developer is subject to the Frater Home Application Market Partner Agreement, which among other things, restricts their methods of accessing, storing, sharing, and using Personal Information provided to them by you and/or End Users.

c) Social Media Features: Our services may enable you to integrate certain social media features, widgets, and single sign-on features, like "Facebook Connect" or "Google Sign-in" ("Social Media Features"), into your web or mobile sites. These Social Media Features may collect certain Personal Information from End Users, including identifiers such as name, nickname, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers. Social Media Features are either hosted by a third party or hosted directly on our Services.

4.5. In the examples listed above in the section, please note that Frater Home acts only as an intermediary platform enabling you to purchase services of Third-Party Services (including but not limited to Third-Party Developers, Third-Party Applications, and Social Media Features) that you choose to interact with directly and at your discretion. In this context, Frater Home acts as a service provider disclosing information to Third-Party Services on your behalf. Frater Home will share the Personal Information of your Users with Third-Party Services only upon your instruction or permission and will not be responsible in any way for the processing of such Personal Information by these Third-Party Services.

Frater Home does not control the actions or policies of any Third-Party Service and is not responsible for them. The risk associated with using any Third-Party Service is solely yours. We recommend that you review all privacy policies accompanying a Third-Party Service and request any necessary disclosures from the respective Third-Party Service before deciding to install and/or use their services.

4.6. In the event of a change in control of the company: Additionally, in the event of any change in control of Frater Home or any of its affiliates, including changes resulting from a merger, acquisition, or purchase of substantially all of its assets, your Personal Data may also be shared with the parties involved in such an event.

5. Where do we store your Data?

Frater Home processes data about individuals worldwide and may transfer your Personal Information outside of your country. Your security, privacy, and confidentiality are our priorities. Therefore, Frater Home conducts a review process that includes an assessment of the privacy laws in these countries to ensure they have robust data protection laws.

5.1. The user's personal information is stored on the infrastructure of Wix.com Ltd. in Israel, a country recognized by the European Commission as providing an adequate level of protection for the Personal Information of residents of EU Member States (see here).

5.2. If you are located in Europe, the United Kingdom, or Switzerland when we transfer your Personal Information outside of Europe, we will ensure that (i) there is an adequate level of protection recognized by the European Commission, or (ii) the relevant Standard Contractual Clauses are in effect. For instance, we will adhere to the applicable module of the Standard Contractual Clauses for the transfer of personal data to third countries per Regulation (EU) 2016/679 of the European Parliament and Council dated June 4, 2021 (accessible here), and the version of the EU Commission's Standard Contractual Clauses in effect from March 21, 2022, as revised under Section 18 of the ICO's Mandatory Clauses, which includes Appendix B1.0 for International Data Transfer.

Frater Home guarantees that it has taken additional measures to comply with European data protection laws when it transfers EU Personal Data to a third country that the European Commission does not deem to provide adequate protection for your information.

6. End Users' Data

Frater Home may collect, store, and process certain Personal Data of End Users ("Data of End Users") only on behalf of our users and according to the instructions of our users. For example, each of our users can import their contacts from third-party services like Gmail or otherwise collect and manage contacts through their User Site. Subsequently, these contacts are stored by Frater Home on behalf of the user.

For these purposes, Frater Home is considered and will act as a "Data Processor" and not a "Data Controller" for the Data of End Users, as these terms are defined in the Personal Data Protection Law and the General Data Protection Regulation of the European Union (“GDPR”).

Users who own and operate these User Sites will be considered the "Data Controller" of the Data of End Users and are responsible for complying with all applicable privacy and data protection laws in their jurisdictions, including the Personal Data Protection Law, regarding the collection and handling of the Data of End Users.

The processing and transfer of Users' Personal Information will take place by the "Data Processing Addendum – Users" ("DPA"). This applies to processing and transfers within the European Union, Israel, or any third country or region that the European Commission has determined provides an adequate level of protection. For transfers to third countries outside the European Union, which do not provide a level of protection deemed adequate by the European Commission, such transfers and processing will be conducted under an approved transfer mechanism as detailed in the DPA (Data Processing Agreement).

The security, integrity, authorized use of End Users' Personal Data, and obtaining the necessary explicit consent and permissions for the collection and use of these Personal Data, along with disclosing relevant individual rights and providing fair processing notices, are your responsibilities.

Frater Home cannot provide legal advice to Users and End Users. However, we strongly recommend that all Users publish and maintain clear and comprehensive privacy policies on their User Sites in accordance with the Personal Data Protection Law and/or other relevant laws and regulations. It's also advised that all End Users carefully read these policies, ensure they understand them, and provide their explicit consent as required by the Personal Data Protection Law and/or other relevant laws to the extent mandated.

For more information on how Frater Home handles the Personal Data of End Users (which may be important for the specific notifications you provide to End Users and/or the explicit consents you obtain from them), please refer to Sections 4, 12, and 13.

If you are a visitor, user, or customer of any of our Users, please read this paragraph: Frater Home has no direct relationship with the End Users whose Personal Data it processes. If you are a visitor, user, or customer of any of our Users and wish to make a request or inquire about your Personal Data, please contact the relevant User/Users directly. For instance, if you wish to access, correct, amend, or delete incorrect Personal Data processed on behalf of our Users by Frater Home, please direct your request to the relevant User (the "Data Controller" of this data). If any of our Users request Frater Home to remove any Personal Data of End Users, we will respond to such requests promptly and by the Personal Data Protection Law and/or other relevant laws after verifying the request (e.g., within thirty (30) days under GDPR). Unless instructed otherwise by our User, we will retain the Data of End Users for the period stated in Section 12 below.

7. Use of Cookies and Other Third-Party Technologies" in English.

We and our Third-Party Service Providers use cookies and similar technologies ("Cookies") to deliver and ensure the proper functioning of our services, to evaluate our performance and marketing activities, and to personalize your experience.

You can find more information on how we use cookies and how you can manage them in our Cookie Policy.

Please note that our applications do not change in response to a "Do Not Track" signal in the HTTP header of a browser or mobile application. However, many browsers allow you to manage cookies, including whether or not to accept them and how to remove them. You can set your browser to notify you when a cookie is placed or choose to block cookies in your browser settings.

8. Communications sent by Frater Home

8.1. Promotional Messages:

We may use your personal data to send you promotional content and messages from Frater Home or our partners (acting on behalf of Frater Home) through email, SMS, notifications on our platform, marketing calls, and similar communication methods.

If you do not wish to receive such promotional messages and calls, you can inform Frater Home at any time or follow the "unsubscribe" or STOP instructions included in the promotional messages you receive.

8.2. Service and Billing Messages

Frater Home may also contact you to convey information related to their services or your use of their services. For instance, they might notify you if a specific service is temporarily unavailable due to maintenance, respond to your support ticket or email, send reminders or warnings about upcoming or overdue payments for your current or upcoming subscriptions, communicate complaints about inappropriate use of your User Site, or inform you about significant changes in their services. These notifications could be sent through any of the communication methods available to them.

It's important for you to always receive these types of messages. Therefore, unless you decide to stop being a Frater Home User (which you can do by deactivating your account), you cannot opt out of receiving these Service and Billing Messages.

9. Your rights regarding Personal Data (Rights of the Data Subject)

Frater Home believes it's essential for all of its users to have control over their personal information. Depending on how you use Frater Home services, you may have the right to access, obtain a copy, update, modify, or delete your personal information, transfer certain personal information to another service, and restrict or object to certain uses of your personal information (such as for direct marketing). Furthermore, when the processing of your personal information is contingent on your consent (for example, for direct marketing), you can withdraw this consent at any time, and this withdrawal will be effective immediately.

Using any of these rights will not incur additional fees from Frater Home, and the company will continue to provide you with the same level of service.

If you are a Frater Home user, you can directly access and correct most of your personal information through your account or via online forms provided by Frater Home. You can also exercise your rights by emailing your request to info@frater.com.tr or sending a postal mail to Merkez Mah. Bağlar Cad. No: 52/A Gop, Istanbul, Turkey. Upon receiving your request, Frater Home may take steps to verify your identity to protect your privacy and security before fulfilling the request.

Before fulfilling your request, Frater Home may ask for additional information for security purposes and to verify your identity. There may be a fee for these requests in certain circumstances allowed under the Personal Data Protection Law and/or other relevant laws (for instance, if your request is unfounded or excessive).

You have the right to complain to the Personal Data Protection Board or the regulatory authority in your location (although it is recommended to contact Frater Home first). As a Frater Home user, if you want to obtain a copy of your data (or that of End Users) stored by Frater Home, access these personal data, request corrections, or request a list of your data disclosed to third parties for direct marketing purposes (if any), you can send your request by mail to Plajmandali.com, Merkez Mah. Bağlar Cad. No: 52/A Gop, Istanbul, Turkey. Depending on legal and other permissible considerations, Frater Home will make every reasonable effort to fulfill your request promptly, unless additional information is required to fulfill your request.

Please note that if you permanently delete your Frater Home account, all of your data will be removed from Frater Home's databases. Once this process is completed, you will no longer be able to use any Frater Home Services. Your account and all data in it will be permanently removed; Frater Home cannot restore your account or retrieve your data in the future. If you contact our support channels later, the system will not recognize your account, and support representatives will not be able to find the deleted account.

10. California Residents: Additional Information

If you are a Service user residing in California, you have certain rights under the California Consumer Privacy Act ("CCPA") regarding the Personal Information collected by Frater Home about you. These rights include the right to access your Personal Information, request its deletion, and request information on how we collect, use, and share your Personal Information.

Personal Information is not sold. Frater Home does not SELL your Personal Information or the Personal Information of your customers (Users' Users) to third parties (this term is defined as such in the CCPA). Furthermore, Frater Home has not sold Personal Information within the twelve months preceding the effective date of this Privacy Policy.

There is no discrimination. Frater Home does not discriminate against any User for exercising their rights under the CCPA.

California consumers can exercise their CCPA rights directly or through an authorized agent by signing into their registered Frater Home accounts at Plajmandali.com and following the instructions provided below. Please note that to protect the security of your account, Personal Information, and privacy rights, we will verify your delete and access requests. In this context, we may request additional information or documentation, such as your account-related information, invoice details used for purchasing paid Services, and copies of documents that can help verify your identity, as applicable.

Any such identity documents, if requested, will be used solely for verification purposes and will be deleted after your request has been processed.

The following instructions apply to the Personal Information we may collect on our Services or through our Services from California residents.

Right to Know: If you wish to exercise your right to know or request a copy of the Personal Information we have about you, please follow these instructions: You can send an email to info@frater.com.tr or mail to Plajmandali.com, Merkez Mah. Bağlar Cad. No: 52/A Gop İstanbul, Türkiye.

Right to Delete: If you want to exercise your right to have your Personal Information deleted that we have stored, you can send your request via email to info@frater.com.tr or mail it to Plajmandali.com, Merkez Mah. Bağlar Cad. No: 52/A Gop İstanbul, Türkiye.

Upon receipt and verification of your consumer request, we will delete your Personal Information from our records unless an exception applies, and we will make a reasonable effort to comply with your request promptly and consistent with applicable laws.

Please note that permanently deleting your Frater Home account removes all your Personal Information from Frater Home's databases. After completing this process, you will no longer have access to any Frater Home Services, your account will be permanently deleted, and all data will be removed, and Frater Home will not be able to restore your account or retrieve your data in the future. Additionally, if you contact our support channels in the future, the system will not recognize your account, and support representatives will not be able to identify the deleted account.

If you are unable to access your Frater Home account or wish to exercise your CCPA rights through an authorized agent acting on your behalf, you or your authorized agent can submit a request (as appropriate) to info@frater.com.tr. To process your request, we may require you or your authorized agent to provide verification information, as detailed above, depending on the nature of the request. Authorized agents will also be required to provide a signed copy of a power of attorney confirming that the consumer has appointed them as an authorized agent.

The rights described in this section may also apply to residents of other U.S. states under current laws and regulations.

11. Questions and Complaints

If you have any questions or concerns regarding the collection, use, or disclosure of Personal Data, or if you believe that we have violated this Privacy Policy or the Data Protection Law or other relevant data protection laws, please contact us - our contact information is provided at the end of this Privacy Policy.

Our Data Protection Officers team will review your complaint, determine whether a breach has occurred, and if so, decide on the measures to be taken. We take all privacy-related complaints seriously and will make every reasonable effort to resolve your complaint as soon as possible and by the Data Protection Law and/or other relevant laws.

You may also file a complaint with the Data Protection Authority or the supervisory authority in your jurisdiction at any time, but we recommend that you contact us first to address your complaint.

12. Data Storage

As stated in this Privacy Policy, we may retain your Data (and Personal Data of End Users) for as long as your User Account is active or as long as necessary to provide you with the Services.

Even after you deactivate your User Account and/or cease using certain Services, we may continue to retain your Data for a reasonable period as required to fulfill our legal obligations, resolve disputes related to our Users or End Users, prevent fraud and improper usage, perform our contracts, and/or protect our legitimate interests.

When determining the appropriate retention period for Personal Data, we consider factors such as the quantity, nature, and sensitivity of such data, the risk of harm from unauthorized use or disclosure of it, our purposes for processing it, and applicable legal requirements.

13. Security

Frater Home has implemented security measures designed to protect the Personal Data you share with us, including physical, electronic, and application-related safeguards. Among others, we provide secure access with HTTPS in most areas of our services; sensitive payment information transmitted through our secure purchase forms (e.g., credit card numbers) is protected using industry-standard SSL/TLS encrypted connections, and we maintain a PCI DSS (Payment Card Industry Data Security Standard) certificate on an ongoing basis. Additionally, we continuously monitor our systems for potential security vulnerabilities and attacks, and we are constantly exploring new ways to enhance the security of our services and protect the privacy of our Visitors and Users.

Despite all the precautions and efforts taken by Frater Home, we cannot and do not guarantee that your Personal Data, the Personal Data of Ultimate Users, and all other information you upload, publish, or otherwise share with Frater Home or others will be absolutely secure and safe. We strongly recommend that you set strong passwords for your User Account and User Site and refrain from providing us or others with Personal Data that you believe is important or may cause irreparable harm if disclosed.

Furthermore, because some areas of our services are less secure than others (e.g., when you specify your Support Forum ticket as "Public" instead of "Private" or when you visit a page without SSL), and email and instant messaging are not considered secure forms of communication, we kindly request and strongly recommend that you do not share any Personal Data in any of these areas or using any of these methods.

If you have any questions about the security of our services, you can contact us here.

14. Third-Party Websites

Our services may include links to other websites and services. We are not responsible for the privacy practices of these websites and services. We strongly recommend that you exercise caution when leaving our services and that you read the privacy statements of each website and service you visit before providing any Personal Data. This Privacy Policy does not apply to such third-party websites and services linked to.

15. Public forums and user-generated content

Our services provide public blogs, communities, and support forums. Please be aware that all Personal Data you provide in these areas may be read, collected, and used by individuals who access these areas. You can request the removal of your Personal Data from our blogs, communities, or forums by contacting us here. In some cases, we may not be able to remove your Personal Data from these areas. For example, if you logged in to your profile with a third-party application (e.g., Facebook social plugin application) to post a comment, and you wish to have the Personal Data you posted removed from that platform, you must log in to the relevant application or contact the provider of that application.

In any case, we recommend not posting Personal Data that you do not want to be publicly available in any way.

Any risk associated with uploading your User Content to your User Account, posting it on your User Site, or otherwise providing it in connection with your use of any Service is yours. We have taken sufficient security measures to protect your Personal Data. However, we cannot control the actions of other Users or members of the public who may access your User Content, and we cannot be held responsible for the circumvention of any privacy settings or security measures (e.g., password-protected areas on your User Site). Even after being removed by you or us, copies of a User Content may remain viewable in cached or archived pages, or if other Users (including any Ultimate Users) have copied or stored that User Content. We recommend not uploading and posting data that you do not want to be public.

16. Updates and Comments

This Privacy Policy may be updated to reflect changes in our practices of collecting, using, and storing Personal Data in accordance with the Personal Data Protection Law and/or other relevant laws. If we make any changes that we consider "significant" (entirely at our sole discretion), we will inform you before the relevant change takes effect (using one of the notification methods specified in Article 15.3 of the Terms of Use). When the Privacy Policy is updated, we will notify you as required by the Personal Data Protection Law and/or other relevant laws, request your explicit consent, and fulfill all other obligations. We strongly recommend that you regularly review this page for the most up-to-date information on our privacy practices. Unless otherwise stated, the most current version of our Privacy Policy applies to all data we hold for you and End Users in the context of our Website, Frater Home Applications, Mobile Applications, and other Services.

All headings, subheadings, section titles, and all explanations and summaries in this Privacy Policy are provided for convenience purposes only and do not define, explain, or legally bind us in any way.

This Privacy Policy is written in Turkish and may be translated into other languages for your convenience. By changing the language settings on the Frater Home website, you can access and view versions in other languages. In the event that a translated (non-Turkish) version of this Privacy Policy conflicts with the Turkish version in any way, the provisions in the Turkish version will prevail.

17. Contact Information

If you have any questions about this Privacy Policy or if you want to exercise any of your rights described in Sections 9 and 10, please refer to the relevant sections or contact our Data Protection Officers team here. We will attempt to resolve any complaints regarding the use of your Personal Data in accordance with this Privacy Policy.

You can reach us by mail at the following addresses:

Merkez Mah. Bağlar Cad. No: 52/A Gop İstanbul, Türkiye