PharusApp Privacy Policy

Interpretation and Definitions

In this Privacy Policy:

• "Application" means PharusApp, the mobile application provided by the Company.
• "Company" ("We", "Us" or "Our") means PHARUS TECH MÜHENDİSLİK VE TEKNOLOJİ ANONİM ŞİRKETİ, İvedikköy Mah. Melih Gökçek Blv. Bina No 140 (OSBTürk Plaza), Ofis 45, Yenimahalle — Ankara, Türkiye.
• "Personal Data" means any information relating to an identified or identifiable individual.
• "Service" means the Application.
• "You" means the individual using the Service, or the company or other legal entity on behalf of which that individual uses the Service.

Types of Data Collected

The Application asks You to provide only the following personal information, which You use to sign in:

• Email address

We also collect technical information automatically when You use the Application, including the version of the Application, Your device model, and Your operating system and its version.

When the Application does not work correctly, We collect diagnostic information describing the error so that We can identify and fix it.

We record information about the equipment You configure or test using the Application, together with Your account, so that We can support that equipment.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain Our Service, including to monitor the usage of Our Service.
• To manage Your Account and Your access to the Service.
• To perform Our contract with You.
• To contact You by email regarding updates or informative communications related to the functionality of the Service, including security updates, when necessary or reasonable for their implementation.
• To provide support, to respond to Your enquiries and requests, and to support the equipment You use with the Service.
• To keep the Service reliable and secure, including to detect, prevent and address technical problems and misuse.

Legal Basis for Processing

We process Your Personal Data on the following legal bases under the EU General Data Protection Regulation (GDPR) and the Turkish Personal Data Protection Law (KVKK):

• Performance of a contract — to provide Your account and the Service and to support the equipment You use with it (GDPR Art. 6(1)(b); KVKK Art. 5(2)(c)).
• Our legitimate interests — to keep the Service working, reliable and secure, and to diagnose faults (GDPR Art. 6(1)(f); KVKK Art. 5(2)(f)).
• Compliance with a legal obligation — where the law requires Us to retain or disclose information (GDPR Art. 6(1)(c); KVKK Art. 5(2)(ç)).

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy, and for as long as We are required to retain it in order to comply with Our legal obligations, resolve disputes and enforce Our agreements.

Records relating to the servicing of safety equipment are retained for as long as We need them to support that equipment and to meet Our obligations in relation to it.

When We no longer need Your Personal Data, We delete it or make it anonymous.

Transfer of Your Personal Data

Your Personal Data is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. Personal Data may be stored or processed outside Türkiye.

Where We transfer Personal Data abroad, We do so only where the conditions set out in the KVKK and the GDPR are met.

Delete Your Personal Data

You have the right to request deletion of the Personal Data that We have collected about You.

Accounts cannot be created in the Application. The Application contains no registration or sign-up function; accounts are issued by Us by invitation. For that reason the Application does not provide an in-app account deletion function either.

To request deletion of Your account or Your Personal Data, contact Us at [email protected] from the email address associated with Your account. We will close the account and delete it.

Please note that We may need to retain certain information where We have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

We may share Your Personal Data in the following situations:

• Service Providers — We may share Your Personal Data with service providers who perform services on Our behalf, such as hosting Our systems and providing technical support. They may process Your Personal Data only on Our instructions and not for their own purposes.
• Business transfers — if the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data becomes subject to a different privacy policy.
• Law enforcement — under certain circumstances the Company may be required to disclose Your Personal Data if required to do so by law, or in response to valid requests by public authorities.
• Other legal requirements — to comply with a legal obligation, to protect and defend the rights or property of the Company, to prevent or investigate possible wrongdoing in connection with the Service, to protect the personal safety of users of the Service or the public, or to protect against legal liability.

We do not sell Your Personal Data. We do not use it for advertising, and We do not share it with advertising networks.

Cookies and Tracking Technologies

The Application does not use cookies. It does not use tracking technologies, it does not access Your device's advertising identifier, and it does not track You across other companies' applications or websites. We do not use analytics services in the Application.

Security of Your Personal Data

The security of Your Personal Data is important to Us. We use appropriate technical and organisational measures to protect it, including encrypted connections to Our systems and limiting access to personnel who need it for their work.

No method of transmission over the Internet and no method of electronic storage is completely secure, and We cannot guarantee absolute security. If We become aware of a breach affecting Your Personal Data, We will notify You and the competent authority where the law requires it.

Your Rights

Under the GDPR and the KVKK, You may ask Us to:

• confirm whether We process Your Personal Data and provide You with a copy of it;
• correct Personal Data that is inaccurate or incomplete;
• delete Your Personal Data, where We are not required to retain it;
• restrict or object to Our processing of Your Personal Data, including where We rely on Our legitimate interests;
• provide Your Personal Data in a portable format, or transmit it to another provider;
• withdraw any consent You have given, without affecting processing carried out before the withdrawal.

To exercise any of these rights, contact Us at [email protected]. We will respond within the time limits set by the GDPR and the KVKK.

If You are not satisfied with Our response, You may lodge a complaint with a supervisory authority — in Türkiye, the Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu); in the European Union, the data protection authority of the country where You live or work.

Children's Privacy

The Application is a professional tool for dealers and service technicians and is not directed at children. Accounts are issued by Us by invitation only.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the privacy policy of every site You visit. We have no control over, and assume no responsibility for, the content, privacy policies or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If You have any questions about this Privacy Policy, You can contact Us:

• By email: [email protected]
• By post: İvedikköy Mah. Melih Gökçek Blv. Bina No 140 (OSBTürk Plaza), Ofis 45, Yenimahalle — Ankara, Türkiye