Security and Privacy Policy
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Introduction
Here Joy Refund (“JR”, “it”, “its”) explains in detail what information it collects in the provision of tax free shopping services, how JR uses that information and what choices you have.
In this Privacy Policy, the term “Personal Data” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, JR’s possession, and includes personal data as described in Data Protection Legislation.
By sharing your personal data with JR either on its website, on mobile app, at airport offices or airport kiosks or by completing a Joy Refund paper voucher, you are indicating that you have reviewed this Privacy Policy and have agreed to be bound by it. If you do not agree to these terms JR will not be able to provide the Services.
JR will handle your Personal Data in accordance with Data Protection Legislation. Please visit www.kvkk.gov.tr/en/ for further information.
Information JR Collects and receives
JR fully respects your right to privacy in relation to your interactions with the Services and endeavor to be transparent in its dealings with you as to what information JR will collect and how it will use your information. Also, JR only collect and use individual’s information where it is legally entitled to do so. Please visit www.kvkk.gov.tr/en/ for further information.
Customer Data
Personal Data submitted by users to the Services (the “Customers”) is referred to in this Privacy Policy as “Customer Data”. Where JR collects or processes Customer Data, it does so on behalf of the Customer.
JR endeavors to keep Customer Data accurate and up-to-date. As such, you must tell JR about any changes to such information that you are aware of as soon as possible. You can update your personal information held on our mobile app, website page or by sending an e-mail to info@joyrefund.com or by calling us from 0850 606 26 86 customer relations line at any time and whether or not you wish to receive correspondence from JR.
Other Information
JR also collects and receives the following information:
Identity Data:In order for JR to provide the Services it requires the Customer’s full name, residential address and passport number.
Billing and Other information: For Customers using Services, they must provide their credit card details including the long credit card number.
Mobile app account creation information: Users provide their email address to create a Mobile app account.
Services usage information: This is information about how you are accessing and using the Services, which may include administrative and support communications with JR and information about the Services.
Cookies
A cookie is a small text file that is placed on your device by a web server which enables a website and/or app to recognise repeat users, facilitate the user’s ongoing access to and use of a website and/or app and allows the website and/or app to track usage behavior and compile aggregate data that will allow content improvements and targeted advertising. JR collates information only in relation to its website and app which is represented in aggregate format through cookies. They help JR to improve its Services, website and app and to deliver many of the functions that make your browser experience more user friendly.
By using JR’s website and/or app and accepting the terms of this Privacy Policy you are consenting to the use of cookies as described in this Privacy Policy and Cookies Policy (i.e. you are agreeing to the placement of cookies on your device unless you specifically choose not to receive cookies).
The ‘Help Menu’ on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can also disable or delete similar data used by browser add-ons, such as flash cookies, by changing the add-on’s settings or visiting the website of its manufacturer.
For more information about cookies and managing them including how to turn them off, please visit www.cookiecentral.com. However, because cookies allow you to take advantage of some of JR’s website and app’s essential features, JR recommends you leave them turned on as otherwise you may not be able to fully experience the interactive features of the website, app or other related websites which you visit.
Aggregated Data
This Privacy Policy is not intended to place any limits on what JR does with data that is aggregated and/or de-identified so that it is no longer associated with an identifiable user or Customer of the Services. JR may disclose or use aggregate or de-identified information for any purpose. For example, JR may share aggregated or de-identified information with its partners or others for business or research purposes.
Why JR Needs Customer Data
JR needs Customer Data in order to provide the Services you have engaged JR to provide and to protect against fraudulent use of the Tax Free Service. If you do not provide the Customer Data, then JR will be unable to provide the Services you have requested. JR will not collect any Personal Data from you that JR does not need in order to provide and oversee the Services it has agreed to provide you with.
How JR Uses Your Info
JR uses your information to provide and improve the Services. JR will only process your Personal Data where it has a legal basis to do so. In general, JR’s legal basis for processing your Personal Data will be in furtherance of the contract(s) that it has with you and/or where you have provided your consent.
Customer Data
JR may access and use Customer Data as reasonably necessary to: (a) provide, maintain and improve the Services; (b) to prevent or address service, security, technical issues or at a Customer’s request in connection with customer support matters; (c) as required by law and (d) as set forth in its agreement with the Customer or as expressly permitted in writing by the Customer in accordance with Customer’s instructions.
Other Info
JR uses other kinds of information in providing the Services. Specifically:
- To understand and improve its Services. JR carry out research and analyze trends to better understand how users are using the Services and improve them.
- To communicate with you by:
- Responding to your requests. If you contact JR with a problem or question, JR will use your information to respond.
- Sending electronic communications. JR may send you administrative electronic communications relating to the Services. JR may also contact you to inform you about changes in our Services, and important Service-related notices, such as security and fraud notices. These electronic communications are considered part of the Services and are made in our legitimate interest in accordance with Data Protection Legislation.
- To communicate with you by:
- Billing and account management. Jr uses account data to administer payments, refunds and charge administration fees.
- Communicating with you. JR may need to contact you regarding compliance requirements with the Retail Export Schemes, refunds and charges.
- Protecting Customer Data. JR works hard to keep the Services secure and to prevent abuse and fraud, and may contact you in this respect as necessary.
How long we keep your customer data for
JR keeps Customer Data for six years, after which time it will be destroyed if it is no longer required for the lawful purpose for which it was obtained. If you consent to marketing, any information JR uses for this purpose will be kept with JR until you notify JR that you no longer wish to receive this information
- Your rights
As a data subject, you have the following rights under Data Protection Legislation and JR, as data controller in respect of Customer Data, will comply with such rights in respect of Customer Data:
- the right of access to Personal Data relating to you;
- the right to correct any mistakes in your Personal Data;
- the right to ask us to stop contacting you with direct marketing;
- rights in relation to automated decision taking;
- the right to restrict or prevent your Personal Data being processed;
- the right to have your Personal Data ported to another data controller;
- the right to erasure; and
- the right to complain to the DPC if you believe we have not handled your Personal Data in accordance with Data Protection Legislation.
These rights are explained in more detail on www.kvkk.gov.tr/en/, but if you have any comments, concerns or complaints about our use of your Personal Data, please Contact JR. JR will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex or cumbersome, in which case JR will respond within three months. Where a response is required from JR within a particular time period pursuant to Data Protection Legislation, it will respond within that time period.
If you no longer consent to JR’s processing of Customer Data, you may request that it cease such processing by contacting JR. Please note that if you withdraw your consent to such processing, it may not be possible for JR to provide all/part of the Service to you.
There are times when information described in this Privacy Policy may be shared by JR. This section discusses only how JR may share such information. JR may share with third parties certain pieces of aggregated, non-personal information. Such information does not identify you individually. JR restricts access to Customer Data to employees, contractors, and agents who need to know that information in order to operate, develop, or improve its Services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, civil litigation and/or criminal prosecution, if they fail to meet these obligations.
Customer Data may be transferred to, stored at, or accessed from a destination outside Turkiye for the purposes of its providing the Services. It may also be processed by staff operating outside the Turkey who work for JR, its Affiliates, or any of its suppliers. By submitting Customer Data, you explicitly consent to this transfer, storing or processing. JR will take all steps reasonably necessary to ensure that Customer Data is treated securely and in accordance with this Privacy Policy. The safeguards in place with regard to the transfer of Customer Data outside of Turkiye are the entry by JR into appropriate contracts with all transferees of such data.
All information you provide to JR is stored on its secure servers. Where JR has given you (or where you have chosen) a password which enables you to access the Services, you are responsible for keeping this password confidential. JR asks you not to share a password with any person not authorised to use the Service.
In particular:
JR may share Customer Data in accordance with its agreement with the Customer and the Customer’s instructions, including:
With third party service providers and agents. Merchants with whom JR have a tax free shopping agreement to enable Customers to avail of the Services and from whom Customers purchase Tax Free legislation qualifying goods will act as data processors of the Customer Data on behalf of JR.
With the Revenue Commissioners (in compliance with our obligations under the Tax Free legislation).
With Affiliates – Related Parties. The following Affiliates are engaged by JR to process Customer Data to enable JR to process and make its Services related refund payments to the Customers:
- Setcard Kurumsal Hizmetler A.S. and its affiliates and suppliers; and
- Codevisor Bilisim Cozumleri and its affiliates and suppliers
JR may share or disclose Customer Data and other information as follows:
- During changes to our business structure. If JR engages in a merger, acquisition, bankruptcy, dissolution, reorganisation, sale of some or all of JR’s assets, financing, acquisition of all or a portion of its business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence).
- To comply with laws.To comply with legal or regulatory requirements and to respond to lawful requests, court orders and legal process.
- To enforce its rights, prevent fraud and for safety. To protect and defend the rights, property, or safety of JR or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud.
This Privacy Policy applies to websites and services that are owned and operated by JR. It does not exercise control over the sites/applications that may be linked from our website. These other sites/applications may place their own cookies or other files on your computer, collect data or solicit personal information from you. You acknowledge that the Services that JR provides may enable or assist you to access the website content of, correspond with, and purchase products and services from, third parties via third-party websites and that you do so solely at your own risk. JR makes no representation or commitment and shall has no liability or obligation whatsoever in relation to the content or use of, or correspondence with, any such third-party website, or any transactions completed, and any contract entered into by you, with any such third party and the use by any such third-party of your Customer Data. JR does not endorse or approve any third-party website nor the content of any of the third-party website made available via the Service. JR encourages you to carefully familiarize yourself with the terms of use and privacy policies applicable to any websites and/or services operated by third parties. Please be aware that JR is not responsible for the privacy practices of any third parties.
JR does its utmost to protect user privacy through the appropriate use of security technology. It restricts access to Customer Data to employees, contractors and agents who need to know such Customer Data in order to operate, develop or improve the services that it provides. JR ensures that it has appropriate physical and technological security measures to protect your information; and it ensures that when it outsources any processes that the service provider has appropriate security measures in place. However, the Services may contain hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, including cookies. JR does not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
JR will implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks that are presented by the processing of Customer Data. In particular, it will consider the risks presented by accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Customer Data transmitted, stored or otherwise processed.
Unfortunately, the transmission of information via the internet is not completely secure. Although JR will do its best to protect Customer Data, it cannot guarantee the security of any data transmitted JR and any such transmission is at your own risk. Once it has received your information, it will use strict and security features to try to prevent unauthorised access. To the extent permitted by law, JR is not responsible for any delays, delivery failures, or any other loss or damage resulting from (i) the transfer of data over communications networks and facilities, including the internet, or (ii) any delay or delivery failure on the part of any other service provider not contracted by JR, and you acknowledge that the Services may be subject to limitations, delays and other problems inherent in the use of such communications facilities. You will appreciate that JR cannot guarantee the absolute prevention of cyber-attacks such as hacking, spyware and viruses. Accordingly, you will not hold JR liable for any unauthorized disclosure, loss or destruction of Customer Data arising from such risks.
JR will notify serious data breaches in respect of Customer Data to the DPC without undue delay, and where feasible, not later than 72 hours after having become aware of same. If notification is not made after 72 hours, it will record a reasoned justification for the delay; however, it is not necessary to notify the DPC where the Personal Data breach is unlikely to result in a risk to the rights and freedoms of natural persons. A Personal Data breach in this context means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.
JR will keep a record of any data breaches, including their effects and the remedial action taken, and will notify you of any data breach affecting your Personal Data (which poses a high risk to you) when it is required to do so under Data Protection Legislation. JR will not be required to notify you of a data breach where:
- JR has implemented appropriate technical and organisational measures that render the Personal Data unintelligible to anyone not authorised to access it, such as encryption; or
- it has taken subsequent measures which ensure that the high risk to data subjects is not likely to materialise; or
- it would involve disproportionate effort, in which case it may make a public communication instead.
JR’s Services are not directed to children under 16. If you learn that a child under 13 has provided JR with personal information without consent, please contact JR.
JR may change this Privacy Policy from time to time, and if it does it will post any changes on this page. If you continue to use the Services after those changes are in effect, you agree to the revised Privacy Policy.
If you have any questions about this Privacy Policy, your information, our use of this information, or your rights when it comes to Customer Data, please feel free to contact us by emailing info@joyrefund.com or by writing to us at JR, Data Protection Team, Icerenkoy Mah. Engin Sok, 4/13 Atasehir-Istanbul, Turkiye.
Schedule A – Data Subject rights under Data Protection Legislation
Right of access to Personal Data relating to you
You may ask to see what Personal Data JR holds about you and be provided with:
- a summary of such Personal Data and the categories of Personal Data held (see Sections 1 and 2 above);
- details of the purpose for which it is being or is to be processed;
- details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those oversea transfers;
- details of the period for which it is held or the criteria we use to determine how long it is held;
- details of your rights, including the rights to rectification, erasure, restriction or objection to the processing;
- any information available about the source of that data;
- whether JR carries out automated decision-making, or profiling, and where it does, information about the logic involved and the envisaged outcome or consequences of that decision making or profiling; and
- where your Personal Data are transferred out of Turkiye, what safeguards are in place.
Requests for your Personal Data must be made to JR specifying what Personal Data you need access to, and a copy of such request may be kept by JR for its legitimate purposes in managing the Service. To help JR find the information easily, please give as much information as possible about the type of information you would like to see. If, to comply with your request, JR would have to disclose information relating to or identifying another person, it may need to obtain the consent of that person, if possible. If JR cannot obtain consent, it may need to withhold that information or edit the data to remove the identity of that person, if possible.
There are certain types of data which JR is not obliged to disclose to you, which include Personal Data which records our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations. JR is also entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if JR decides to provide you with the Personal Date requested, it may charge you a reasonable fee to account for administrative costs of doing so), or (ii) JR is entitled to do so pursuant to Data Protection Legislation.
Right to update your Personal Data or correct any mistakes in your Personal Data
You can require JR to correct any mistakes in your Personal Data which it holds free of charge. If you would like to do this, please:
- email or write to JR
- let JR has enough information to identify you (e.g. name, registration details); and
- let JR know the information that is incorrect and what it should be replaced with.
If JR is required to update your Personal Data, it will inform recipients to whom that Personal Data have been disclosed (if any), unless this proves impossible or has a disproportionate effort.
It is your responsibility that all of the Personal Data provided to JR is accurate and complete. If any information you have given JR changes, please let it know as soon as possible.
Right to ask JR to stop contacting you with direct marketing
JR has a legitimate interest to send you electronic communications/direct marketing in connection with the Service and related matters (which may include but shall not be limited to newsletters, announcement of new features etc.). JR may also ask you different questions for different services, including competitions. JR may also ask you to complete surveys that it uses for research purposes, although you do not have to respond to them.
You can ask JR to stop contacting you for direct marketing purposes. If you would like to do this, please:
- email or write to JR. You can also click on the ‘unsubscribe’ button at the bottom of the electronic communication. It may take up to 15 days for this to take place; and
- let JR know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for JR to contact you by email but not by telephone).
JR will provide you with information on action taken on a request to stop direct marketing – this may be in the form of a response email confirming that you have ‘unsubscribed’.
Rights in relation to automated decision taking (if applicable)
You may ask JR to ensure that, if it is evaluating you, JR doesn’t base any decisions solely on an automated process and has any decision reviewed by a member of staff. Profiling may occur in relation to your Personal Data for the purposes of targeted advertising and de-targeting you from specified advertising. This allows JR to tailor our advertising to the appropriate customers and helps to minimise the risk of you receiving unwanted advertising. These rights will not apply in all circumstances, for example where the decision is (i) authorised or required by law, (ii) necessary for the performance of a contract between you and JR, or (iii) is based on your explicit consent. In all cases, JR will endeavour that steps have been taken to safeguard your interests.
Right to restrict or prevent processing of Personal Data
In accordance with Data Processing Legislation, you may request that JR stops processing your Personal Data temporarily if:
- you do not think that your Personal Data is accurate;
- the processing is unlawful but you do not want JR to erase your Personal Data;
- JR no longer needs the Personal Data for its processing, but you need the Personal Data to establish, exercise or defend legal claims; or
- you have objected to processing because you believe that your interests should override the basis upon which JR processes your Personal Data.
If you exercise your right to restrict JR from processing your Personal Data, it will continue to process the Personal Data if:
- you consent to such processing;
- the processing is necessary for the exercise or defence of legal claims;
- the processing is necessary for the protection of the rights of other individuals or legal persons; or
- the processing is necessary for public interest reasons.
In accordance with Data Protection Legislation, you may ask for an electronic copy of your Personal Data that you have provided to JR and which it holds electronically, or for JR to provide this directly to another party. This right only applies to Personal Data that you have provided to JR – it does not extend to data generated by JR. In addition, the right to data portability also only applies where:
- the processing is based on your consent or for the performance of a contract; and
- the processing is carried out by automated means.
In accordance with Data Protection Legislation, you can ask JR to erase your Personal Data where:
- you do not believe that JR needs your Personal Data in order to process it for the purposes set out in this Privacy Policy;
- if you had given JR consent to process your Personal Data, you withdraw that consent and JR cannot otherwise legally process your Personal Data;
- you object to our processing and we do not have any legal basis for continuing to process your Personal Data;
- your Personal Data has been processed unlawfully or have not been erased when it should have been; or
- the Personal Data have to be erased to comply with law.
JR may continue to process your Personal Data in certain circumstances in accordance with Data Protection Legislation (i.e. where JR has a legal justification to continue to hold such Personal Data). Where you have requested the erasure of your Personal Data, JR will inform recipients to whom that Personal Data have been disclosed, unless this proves impossible or involves disproportionate effort. JR will also inform you about those recipients if you request it.
If you do not think that JR has processed your Personal Data in accordance with this Privacy Policy, please contact JR in the first instance. If you are not satisfied, you can complain to the DPC or exercise any of your other rights pursuant to Data Protection Legislation. Information about how to do this is available on the DPC website at www.kvkk.gov.tr/en/