Privacy Policy

1. Introduction

1.1 VISUAL MH BİLİŞİM SİSTEMLERİ LTD. ŞTİ (“VisualAds”, “we”, “us”, or “our”) is a Google MCM (Multiple Customer Management) partner operating under the brand VisualAds, providing monetization services to websites and mobile applications. We are committed to safeguarding the privacy of our website visitors, service users, individual customers, and customer representatives.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

2. What personal data do we collect?

2.1 In this Section 2, we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data. The definition of personal data depends on the laws where you are located and can be broadly defined in the European Economic Area, the United Kingdom, and Brazil. In these regions, personal data would include pseudonymous identifiers such as your IP address, Google Advertising ID, or Apple Identifier for Advertisers.

2.2 We may process data enabling us to get in touch with you (“contact data”). The contact data may include your name, email address, telephone number, postal address, and/or social media account identifiers. Please see the privacy policy of your social media account provider for more information about how your personal data is processed in such cases. The source of the contact data is you and/or your employer.

2.3 We may process your website user account data (“account data”). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings, bank account details, and marketing preferences. The primary source of the account data is you and/or your employer, although some elements of the account data may be generated by our website.

2.4 When we provide Google MCM services, we may process your Google account data (“Google Account Data”), including your Google Ad Manager Network ID and Google Ad Manager email address. In such cases, Google acts as the data controller. Please see Google’s privacy policy for more information. The source of the contact data is you and/or your employer.

2.5 We may process information contained in, or relating to, any communication that you send to us or that we send to you (“communication data”). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The source of the communication data is you and/or your employer.

2.6 We may process data about your use of our website and services (“usage data”). The usage data may include your Internet Protocol (IP) address, network routing data, system configuration information, and other information about traffic to and from our websites and/or platform. The source of the usage data is our website security system, Cloudflare.

2.7 We do not knowingly process the personal data of children under the age of 13. If we are made aware that we have received personal data from someone under the age of 13, we will use our reasonable efforts to remove that information from our records. Where applicable law raises the age of children higher than 13, we will do the same.

2.8 We do not knowingly collect or process sensitive data, that is, personal data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, as well as genetic data, biometric data, data concerning health, sex life, or sexual orientation. If we are made aware that we have received sensitive personal data from someone, we will use our reasonable efforts to remove that information from our records.

2.9 Cookies – Our website sets a small number of first-party cookies that are strictly necessary for it to work: a session cookie and a security (CSRF) token, both of which expire when you close your browser, and a cookie named va_lang that remembers the language you chose (or the language selected for you on your first visit, based on your country). The va_lang cookie is kept for 1 year, is set only by visualads.com, is not used for tracking or advertising, and is not shared with anyone. You can delete it at any time from your browser settings; the site will then fall back to English or to the language for your country.

3. How do we use the collected personal data?

3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.

3.2 Operations – We may process your personal data for the purposes of operating our website, processing and fulfilling orders, providing our services, generating invoices, bills, and other payment-related documentation, and for credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services, and business, or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.3 Access to our services – We may process your account data to enable you to access our extended services on our website/platform. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.4 Relationships and communications – We may process contact data, account data, transaction data, and/or communication data for the purposes of managing our relationships, communicating with you (excluding communications for the purposes of direct marketing) by email, SMS, social media direct messages, post, fax, and/or telephone, providing support services, and handling complaints. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers, and customer representatives, the maintenance of relationships, and the proper administration of our website, services, and business.

3.5 Direct marketing – We may process contact data, account data, and/or transaction data for the purposes of creating, targeting, and sending direct marketing communications by email, SMS, social media direct messages, post, and/or fax, and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent, or, if you are already a customer, our legitimate interests, namely promoting our business and communicating marketing messages and offers to you. You can opt out of our direct marketing messages at any time.

3.6 Research and analysis – We may process usage data for the purposes of researching and analyzing the use of our website and services, as well as other interactions with our business. The legal basis for this processing is consent, or our legitimate interests in monitoring, supporting, and improving the security of our website, services, and business in general.

3.7 Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases, and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

3.8 Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services, and business, and the protection of others.

3.9 Insurance and risk management – We may process your personal data where necessary for obtaining or maintaining insurance coverage, managing risks, and obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.10 Legal claims – We may process your personal data where necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others.

3.11 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.

4. How and when do we share your personal data?

4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, and obtaining professional advice.

4.2 Your personal data held in our website database will be stored on the servers of our hosting services provider, namely Hetzner Online GmbH (https://www.hetzner.com/legal/legal-notice), which are located in Germany.

4.3 To ensure the security of our website, we use a website security system named Cloudflare. In accordance with Section 3.8 of this policy, we may disclose log files including network routing data, system configuration information, and other information about traffic to and from our website to Cloudflare, Inc. identified at https://www.cloudflare.com/privacypolicy/ insofar as reasonably necessary for the security of our website. The servers used to process your personal data will depend on your location. The complete list of the servers’ locations can be obtained from https://www.cloudflare.com/network/.

4.4 We use Google Workspace (https://workspace.google.com/intl/en_uk/business/) for the operation of our administration, including Google Forms, Google Sheets, Gmail, and Google Calendar. As such, your personal data will be processed by Google and stored on Google servers primarily in Europe and possibly in countries outside the European Economic Area. For more information about Google’s data centers for Google Workspace, please visit https://www.google.com/about/datacenters/locations/. You can also find information about Google’s privacy policy and practices at https://policies.google.com/privacy.

4.5 Financial transactions relating to our services will be handled by our bank, Türkiye İş Bankası. We will share transaction data with our bank only to the extent necessary for processing your payments, invoices, and credit notes, refunding any payments, and handling complaints and queries relating to such payments and refunds. You can find information about the bank’s privacy policies and practices at https://www.isbank.com.tr/en/privacy-policy.

4.6 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to a country different from the one where you are located.

5.2 We may process your personal data from any country where we operate and may permit our suppliers and subcontractors to do so from the countries where they operate. Please see the following sections for more details. Except if you are located in the European Economic Area or in the UK, by providing us with your personal data, you consent to the transfer of your personal data to the countries where we and our suppliers and subcontractors operate, in accordance with this Privacy Policy.

5.3 The hosting facilities for our website and platform are situated in Germany. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of Germany.

5.4 The hosting of our Cloudflare, Inc. website security services is situated in the United States of America. Transfers to this country are protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities and incorporated in the Data Processing Addendum that we have entered into with Cloudflare, Inc., a copy of which can be obtained from https://www.cloudflare.com/en-gb/cloudflare-customer-dpa.

5.5 The hosting of Google Workspace is situated in Europe and in the United States of America (see https://www.google.com/about/datacenters/locations/). Transfers to countries outside of the European Economic Area and the UK are protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities and incorporated in the Data Processing Addendum that we have entered into with Google, a copy of which can be obtained from https://cloud.google.com/terms/data-processing-addendum.

5.6 The hosting of your personal data processed by our bank is primarily in Turkey. Since the bank acts as a data controller, you can find more information on how your personal data is processed at https://www.isbank.com.tr/en/privacy-policy.

5.7 You acknowledge that personal data you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations regarding the retention and deletion of personal data.

6.2 Personal data that we process for any purpose shall not be kept longer than necessary for that purpose.

6.3 We will retain your personal data as follows:

• (a) Contact data will be retained for a minimum period of 1 year following the most recent contact between you and us, and for a maximum period of 3 years thereafter.
• (b) Account data will be retained for a period of 1 year following the closure of the relevant account.
• (c) Communication data will be retained for a period of 3 years following the date of the communication in question.
• (d) Usage data will be retained for a maximum period of 2 years following the date of collection.

6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation, the establishment, exercise, or defense of legal claims, or to protect your vital interests or those of another natural person.

7. Your rights

7.1 In this Section 7, we have listed the rights that you have under data protection laws, specifically under the data protection laws of the European Economic Area, Switzerland, the United Kingdom, and Brazil. If you are a data subject from California, please see Section 7.6.

• (a) the right to access – you can ask for copies of your personal data;
• (b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
• (c) the right to erasure – you can ask us to erase your personal data;
• (d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
• (e) the right to object to processing – you can object to the processing of your personal data;
• (f) the right to data portability – you can ask that we transfer your personal data to another organization or to you;
• (g) the right to complain to a supervisory authority – you can complain about our processing of your personal data;
• (h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

7.3 These rights are subject to certain limitations and exceptions.

7.4 You may exercise any of your rights in relation to your personal data by emailing us at [email protected]. Depending on the type of request and in accordance with applicable law, we may take up to 30 days to respond. Please also note that, in accordance with applicable law, we may verify your identity before fulfilling your request, as a security measure.

7.5 If you are a publisher or a customer with an account, you can access your personal data at any time, update or delete it, and change your communication preferences by logging into your account or emailing [email protected].

7.6 If you are located in California, you have the following rights:

• (a) The right to access the personal data we hold about you;
• (b) The right to know what personal data we collect from you before the point of collection;
• (c) The right to opt in or out of marketing, analytics, and other similar activities;
• (d) The right to equal services without discrimination;
• (e) The right to request deletion of personal data.

8. Our details

8.1 You can contact us:

• (a) using our website contact form;
• (b) by email, at [email protected].

9. Amendments

9.1 We may update this policy from time to time by publishing a new version on our website.

9.2 You should check this page periodically to ensure that you are satisfied with any changes to this policy.