PRIVACY NOTICE

Rival Dijital Yayıncılık ve Pazarlama Ticaret A.Ş. “Socrates App” is an all-around sports content platform that heavily focuses on user experience. Socrates App is born with the idea to address the lack of user input as well as to challenge the dull and unprogressive interfaces in the current sports media landscape. Our vision is to challenge & change the current way of sports content consumption & creation, in other words, we are here to rival the conventional sports media. As a user, you can reach various services such as sports contents from basketball to cycling, post your comments all about them, and have the opportunity to become a sports content creator yourself! hereafter “Services”.

This Privacy Notice applies whenever your personal data is processed as part of our Services. It describes how we process your personal data when providing these Services to you, and your rights and choices concerning your personal data. Socrates App is the “data controller” of your personal data unless otherwise stated below.

  1. Which of Your Personal Data is Processed and What are the Purposes of Processing Your Personal Data?
  2. Personal Data That You Share with Us directly without Logging-in

When you use our Services without logging-in, you may give us personal data (for example, when uploading our application), and we will store that personal data on our systems and process it for the purposes described in this Privacy Notice.

Depending on the Services, the personal data that we collect will be relevant to providing that Services and include the following:

Personal Data Legal Basis Purposes of Processing Your Personal Data
transaction security information (IP address, device ID) details about the platforms that you use (Apple Store, Google Play) Necessary for performance of the contract Provide our Services to our users Protecting Socrates App’s rights, including compliance with applicable legal obligations, resolving any disputes we may have, and to administer our agreements with third parties Ensuring the security of data controller operations and protecting the safety of our users For security purposes and to prevent fraud or potentially illegal activities, and to enforce the applicable Terms of Service
Socrates App’s legal obligations, in particular relating to security, fraud detection and management Cooperating with public authorities and law enforcement where lawfully permitted or required

Personal Data That You Share with Us directly by Logging-in

Personal Data Legal Basis Purposes of Processing Your Personal Data
transaction security information (IP address, device ID, user ID) details about the platforms that you use (Apple Store, Google Play, social media) identification data (name, surname, username, birth date and profile picture) communication data (e-mail address, phone number) information related to any purchases you make in our Services Necessary for performance of the contract Provide our Services to our users  Communication activities with the users Protecting Socrates App’s rights, including compliance with applicable legal obligations, resolving any disputes we may have, and to administer our agreements with third parties Ensuring the security of data controller operations and protecting the safety of our users For security purposes and to prevent fraud or potentially illegal activities, and to enforce the applicable Terms of Service Execution of activities for ensuring business continuity
Socrates App’s legal obligations, in particular relating to security, fraud detection and management Cooperating with public authorities and law enforcement where lawfully permitted or required

Personal Data That You Generate Using Our Services

When you use our Services, we will collect personal data about the ways in which you use and interact with our Services.

Personal Data Legal Basis Purposes of Processing Your Personal Data
when and for how long you are in the Services service activities in which you participate transaction security information (IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID) descriptions of your in-Socrates App’s platform activity Socrates App's legitimate interest in improving its Services and its website Tracking users’ habits and preferences Execution of activities for user's Services satisfaction Execution of activities for ensuring business continuity

If you choose to use communication features in Socrates App’s Services to share information in public via your comments to the contents, then we’ll collect data on what is shared. This includes:

Personal Data Legal Basis Purposes of Processing Your Personal Data
your comments in public to the contents in Socrates App’s Services Necessary for performance of the contract Protecting Socrates App’s rights, including compliance with applicable legal obligations, resolving any disputes we may have, and to administer our agreements with third parties For security purposes and to prevent fraud or potentially illegal activities and protecting the safety of our users
Socrates App's legitimate interest in improving its Services and its website Execution of activities for user's Services satisfaction Execution of activities for ensuring business continuity
Socrates App’s legal obligations, in particular relating to security, fraud detection and management Cooperating with public authorities and law enforcement where lawfully permitted or required

Information We Get About You from Connected Third-Party Platforms

If you log-in Socrates App’s platform or access any of our Services on social networks like Facebook, Google or other connected third-party platforms, Socrates App may receive your certain personal data from that third-party platform.

Depending on the third-party application, your privacy settings, Socrates App may collect and store some or all of the following from the third-party platform:

Personal Data Legal Basis Purposes of Processing Your Personal Data
identification data (name and surname); transaction security information (IP address, device ID, your social network ID number, which may be linked to publicly available information like your profile); communication data (e-mail address, phone number) Necessary for performance of the contract For security purposes and to prevent fraud or potentially illegal activities, and protecting the safety of our users Protecting Socrates App’s rights, including compliance with applicable legal obligations, resolving any disputes we may have, and to administer our agreements with third parties
Socrates App's legitimate interest in improving its Services and its website Execution of activities for user's Services satisfaction Execution of activities for ensuring business continuity
Socrates App’ legal obligations, in particular relating to security, fraud detection and management Cooperating with public authorities and law enforcement where lawfully permitted or required

If you access our Services from a third-party platform or connect our Services to a third-party account, you should also read that platform’s terms of service and privacy policy.

If you are unclear about what information a third-party platform is sharing with us, please go to that platform to find out more about their privacy practices and any options available to you regarding such sharing.

Cookies and Other Automated Information Collection

We use cookies and other similar technologies (e.g. device identifiers) to recognize you and/or your device(s) across different services (both Socrates App’s Services and third-party services), including for advertising purposes. We explain why we do this, and how to control cookies and similar technologies, in the applicable Cookie Notice.

We use these cookies and other similar technologies to process personal data, including:

Personal Data Legal Basis Purposes of Processing Your Personal Data
transaction security information (IP address, the type of device you are using, platform type (like Apple iOS or Android), your operating system version, your mobile device’s identifiers, like your MAC Address, Apple Identifier For Advertising (IDFA), and/or Android Advertising ID (AAID), your browser type and language, referring and exit pages, and URLs, the number of clicks on an app feature or website, the amount of time spent on an app feature or web page, domain names, landing pages, pages viewed and the order of those pages, what your current progress is in our Services and the date and time of activity) Necessary for performance of the contract Conducting business activities Ensuring the security of data controller operations For security purposes and to prevent fraud or potentially illegal activities
Socrates App’ legal obligations, in particular relating to security, fraud detection and management Cooperating with public authorities and law enforcement where lawfully permitted or required
Consent Personalizing our Services and our users’ experiences
Socrates App's legitimate interest in improving its Services and its website Improving, optimizing our Services and our users’ experiences

In some cases, we will connect personal data by using cookies and similar technologies with your social network ID or Socrates App user ID.

If you log-in Socrates App’s platform on a mobile device, in addition to the data we collect using cookies and similar technologies depending on same purposes listed table above, we may also collect:

Personal Data Legal Basis Purposes of Processing Your Personal Data
information about the Socrates App’s Services and about other third-party applications with embedded Services you have on your device. Socrates App’s legitimate interest in improving its Services and its website Improve, optimize our Services and our users’ experiences Ensuring the security of data controller operations

If you have questions, need further information about the purposes and legal grounds for processing your personal data, or want to withdraw your consent please see the Contact Us section below.

How We Transfer Your Personal Data

When we transfer your personal data internationally, we treat your personal data securely, lawfully, and in accordance with privacy obligations. Please note that the privacy laws vary from jurisdiction to jurisdiction when transferring personal data internationally, so the privacy laws applicable to the places where your information is processed may be different from the privacy laws applicable to the place where you are resident.

Authorized Persons, Institutions and Organizations

Depending on compliance with a legal obligation, or legal demands of authorized persons, institutions and organizations, we may share your personal data with the public authorities.

Personal Data Legal Basis Purposes of Processing Your Personal Data
identification data  transaction security information  details about the platforms that you use links to your profiles on various social networks and social network ID number information related to any purchases you make in our Services Socrates App’s legal obligations, in particular relating to provide information to authorized persons, institutions and organizations Providing information to authorized persons, institutions and organizations Execution of activities in compliance with the legislation

Third-Party Service Providers

We will share your personal data with third parties who perform services on our behalf, for hosting services, and security of our Services, and our third-party business partners who assist us in delivering and optimizing our Services.

Your Rights

Your rights on data protection are explained below. These rights apply to information about you, and their scope and applicability can vary across different regions. For example, they could extend to your household or a legal entity or could be exercised by a legal representative on your behalf. We will comply with applicable privacy laws, including any required response times.

Subject to certain exemptions, you have the right to:

U.S. Privacy Laws

If you are a California resident, you may be able to exercise additional rights granted by California law in relation to your personal data that we process (subject to certain limitations). For more information, please review our California Notice .

If you are a Nevada resident, you may be able to exercise additional rights to opt out of future sales of certain covered information that a website operator has collected or will collect about you. If you are a Nevada resident, you may exercise this right by submitting a request by using the Contact Us channels below. Please include sufficient information for us to identify you, such as your account information including Socrates App’s ID. Please note we may take reasonable steps to verify your identity and the authenticity of the request.

Security of Your Personal Data

We implement reasonable and appropriate security measures in order to preserve the security, integrity and confidentiality of your personal data, and, in particular, to protect such data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to it in accordance with this Privacy Notice.

Where you access our Services through another account (for example, a social network) please keep that account information secure as well.

How Long We Keep Your Personal Data

Socrates App undertakes not to keep your personal data beyond the period strictly necessary for the purposes for which it was collected, and in accordance with the applicable regulations, as well as any laws and regulations, including taxing and accounting.

Socrates App undertakes to anonymize or delete your personal data as soon as the purpose and/or the duration of their established retention expire.

After having served its main purpose, personal data may be archived for auxiliary purposes, such as of researching, investigating and prosecuting criminal offenses, ligation, or accounting and tax purposes. Archiving implies that this personal data will be subject to limited access restrictions.

Contact Us

If you wish you can deliver your requests about processing your personal data,

  1. By applying to Socrates App with a valid identity card directly,
  2. By sending to Socrates App address “Maslak Mah. Aos 55. Sk. 42 Maslak B Blok Sitesi No: 4 İç Kapı No: 582 Sarıyer / İstanbul” together with wet signature and ID photocopy,
  3. By sending via e-mail address (privacy@socratesapp.info) which belongs to Socrates App with the petition signed by secure e-signature or mobile signature.

You should express in a clear and understandable way what is requested in the application, which you will make to practice rights mentioned above. Information and documents related to the application should be attached to the application. Although the subject of the request must be related to the person of the applicant, if acting on behalf of data subject, the applicant must be specifically authorized in this regard and this authority must be documented (special power of attorney). Requests made by unauthorized third parties on behalf of data subject shall not be valid.

Changes to Our Privacy Notice

We may update our Privacy Notice from time to time. When we do, we will revise the “last updated” date at the top of the policy. If we make changes that we deem material, we will use reasonable efforts to notify (such as by placing a notice in Services or on Socrates App, or by sending you a notice to the e-mail address you have registered with us, if any). We encourage you to periodically check Socrates App and this Privacy Notice for updates. If you would like a copy of earlier policies, please get in touch using the Contact Us information above.