Belgrade E-pass Privacy Policy

PRIVACY POLICY

Last Updated February 19, 2024

This privacy notice for Varol Grup Turizm Seyahat ve Teknoloji San. Tic. Ltd. Şti. (operating as Istanbul E-pass) ("we", "us", or "our"), outlines how we collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as:

Visiting our website at https://belgradeepass.com/privacy-policy.html or any of our websites linking to this notice
Engaging with us in related ways, such as through sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you disagree with our policies and practices, please refrain from using our Services. For any questions or concerns, contact us at belgrade@belgradeepass.com.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice. For more details, click the link following each key point or refer to our table of contents below.

Personal information processed: When using our Services, we may process personal information depending on your interactions, choices, and the features you use. Learn more about the personal information you disclose to us.
Sensitive personal information: We do not process sensitive personal information.
Third-party information: We do not receive any information from third parties.
How we process your information: We process your information to provide, improve, and administer our Services, communicate with you, ensure security and fraud prevention, and comply with the law. We also process your information for other purposes with your consent. Learn more about how we process your information.
Sharing personal information: We may share information in specific situations with specific third parties. Learn more about when and with whom we share your personal information.
Keeping your information safe: We use organizational and technical measures to protect your personal information. However, no internet or storage technology can guarantee 100% security. Learn more about how we keep your information safe.
Your rights: Depending on your location, you may have certain rights regarding your personal information. Learn more about your privacy rights.
Exercising your rights: The easiest way to exercise your rights is by submitting a data subject access request or contacting us. We will respond to requests in accordance with data protection laws.

Want to learn more about our information practices? Review the full privacy notice.

WHAT INFORMATION DO WE COLLECT?
HOW DO WE PROCESS YOUR INFORMATION?
WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
HOW LONG DO WE KEEP YOUR INFORMATION?
HOW DO WE KEEP YOUR INFORMATION SAFE?
DO WE COLLECT INFORMATION FROM MINORS?
WHAT ARE YOUR PRIVACY RIGHTS?
CONTROLS FOR DO-NOT-TRACK FEATURES
DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
DO WE MAKE UPDATES TO THIS NOTICE?
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you provide: We collect the personal information you voluntarily provide when you express interest in our products and Services, participate in activities on our Services, or contact us. This may include:

Names
Email addresses
Phone numbers
Mailing addresses
Billing addresses

Sensitive Information: We do not process sensitive information.

Payment Data: If you make purchases, we may collect payment data such as your payment instrument number and security code. This data is stored by Yapı Kredi, İş Bankası, and Stripe. Their privacy notices are available at Yapı Kredi, İş Bankası, and Stripe.

Accuracy: All personal information provided must be true, complete, and accurate. Notify us of any changes.

Automatically collected information: Some information, like IP address and browser characteristics, is automatically collected when you visit our Services. This information, needed for security and analytics, may include:

Log and Usage Data: Service-related, diagnostic, and usage information recorded in log files.
Device Data: Information about your device, such as IP address, browser type, and operating system.
Location Data: Information about your device’s location, collected with your permission. You can opt out by disabling your location settings.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your information to provide, improve, and administer our Services, communicate with you, ensure security and fraud prevention, and comply with the law. Additional purposes include:

Delivering services
Responding to inquiries and offering support
Sending administrative information
Fulfilling and managing orders
Enabling user-to-user communications
Requesting feedback
Sending marketing and promotional communications
Determining marketing campaign effectiveness
Protecting vital interests

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

We process personal information based on valid legal reasons under applicable law, including:

Consent: With your permission, which can be withdrawn at any time.
Performance of a Contract: To fulfill contractual obligations.
Legitimate Interests: For business interests that do not override your rights and freedoms.
Legal Obligations: To comply with legal requirements.
Vital Interests: To protect vital interests.

For individuals in Canada, processing may also occur under implied consent or certain exceptional circumstances

4. When and With Whom Do We Share Your Personal Information?

Summary: We may share your personal information in specific situations outlined in this section and with the third parties listed.

We might share your personal information in the following scenarios:

Business Transfers: During negotiations or in connection with a merger, sale of company assets, financing, or acquisition of our business by another company, we may share or transfer your information.
Google Analytics: We may share your information with Google Analytics to track and analyze the usage of our Services. This includes features like Remarketing with Google Analytics, Google Display Network Impressions Reporting, and Google Analytics Demographics and Interests Reporting. To opt out of Google Analytics tracking, visit here and for Google Analytics Advertising Features, use Ads Settings and Ad Settings for mobile apps. Other opt-out options include optout.networkadvertising.org and networkadvertising.org/mobile-choice. For Google's privacy practices, visit the Google Privacy & Terms page.
Affiliates: We may share your information with our affiliates, requiring them to honor this privacy notice. Affiliates include our parent company, subsidiaries, joint venture partners, or other companies we control or that are under common control with us.

5. Do We Use Cookies and Other Tracking Technologies?

Summary: We may use cookies and similar tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (such as web beacons and pixels) to access or store information. Details on how we use these technologies and how you can refuse certain cookies are in our Cookie Notice: https://belgradeepass.com/privacy-policy.html

6. How Long Do We Keep Your Information?

Summary: We retain your information as long as necessary to fulfill the purposes outlined in this privacy notice unless a longer retention period is required by law.

We keep your personal information only as long as it is necessary for the purposes stated in this privacy notice, unless a longer retention period is required or permitted by law (e.g., tax, accounting, or other legal requirements). When there is no ongoing legitimate business need to process your personal information, we will either delete or anonymize it. If this isn't possible (for instance, because your personal information is stored in backup archives), we will securely store your information and isolate it from further processing until deletion is possible.

7. How Do We Keep Your Information Safe?

Summary: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. Therefore, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. You should access the Services within a secure environment and understand that the transmission of personal information to and from our Services is at your own risk.

8. Do We Collect Information From Minors?

Summary: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years old. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of a minor and consent to the minor’s use of the Services. If we learn that personal information from users under 18 has been collected, we will deactivate the account and promptly delete such data from our records. If you become aware of any data we may have collected from children under 18, please contact us at belgrade@belgradeepass.com

9. What Are Your Privacy Rights?

Summary: In certain regions, such as the EEA, UK, Switzerland, and Canada, you have rights that provide you with greater access to and control over your personal information. You can review, change, or terminate your account at any time.

In some regions (like the EEA, UK, Switzerland, and Canada), you have specific rights under applicable data protection laws. These rights may include:

The right to request access and obtain a copy of your personal information.
The right to request rectification or erasure.
The right to restrict the processing of your personal information.
The right to data portability.
The right not to be subject to automated decision-making.

In certain circumstances, you may also have the right to object to the processing of your personal information. To exercise these rights, contact us using the contact details provided in the section 'How Can You Contact Us About This Notice?' below. We will consider and act upon any request in accordance with applicable data protection laws.

If you are in the EEA or UK and believe we are unlawfully processing your personal information, you have the right to complain to your Member State data protection authority or UK data protection authority. If you are in Switzerland, you can contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we rely on your consent to process your personal information, you can withdraw it at any time by contacting us using the contact details provided in the section 'How Can You Contact Us About This Notice?' below. Note that withdrawing your consent does not affect the lawfulness of the processing before its withdrawal and, where applicable law allows, does not affect processing conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from marketing and promotional communications at any time by clicking the unsubscribe link in our emails, replying 'STOP' or 'UNSUBSCRIBE' to our SMS messages, or contacting us using the details provided in the section 'How Can You Contact Us About This Notice?' below. We may still send you service-related messages necessary for the administration and use of your account or other non-marketing purposes.

Cookies and similar technologies: Most web browsers accept cookies by default. You can set your browser to remove or reject cookies, but this may affect certain features or services of our Services. For more information, see our Cookie Notice: https://belgradeepass.com/privacy-policy.html

If you have questions or comments about your privacy rights, email us at belgrade@belgradeepass.com.

10. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systesm and app include a DO-NOT-TRACK (-DNT) feature or setting to signal your privacy preference not to have your online browsing activities monitored and collected. No uniform technologhy standard for recognizing and implementing DNT signals has been finalized. Therefore, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If an online tracking standard we must follow is adopted in the future, we w,ll inform you in a revised version of this privacy notice.

11. Do United States Residents Have Specific Privacy Rights?

Summary: If you are a resident of Utah, you have specific rights regarding access to your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months.

12.DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights depending on your country of residence.

Australia and New Zealand

We collect and process your personal information in compliance with Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This privacy notice meets the notice requirements of both Privacy Acts, specifically detailing what personal information we collect from you, the sources of this information, the purposes for which it is collected, and the recipients of your personal information.

If you choose not to provide the necessary personal information, it may affect our ability to:

Offer you the products or services you desire Respond to or assist with your requests You have the right to request access to or correction of your personal information at any time. You can make such a request by contacting us using the details provided in the section 'HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?'

If you believe we are unlawfully processing your personal information, you have the right to lodge a complaint about a breach of the Australian Privacy Principles with the Office of the Australian Information Commissioner or a breach of New Zealand's Privacy Principles with the Office of the New Zealand Privacy Commissioner.

Republic of South Africa

You have the right to request access to or correction of your personal information at any time. You can make such a request by contacting us using the details provided in the section

'HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?'

If you are dissatisfied with our response to any complaint regarding our processing of your personal information, you can contact the Information Regulator (South Africa) using the following details:

General enquiries: enquiries@inforegulator.org.za Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

13.DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as needed to comply with relevant laws.

We may periodically update this privacy notice. The updated version will be indicated by an updated 'Revised' date and will become effective as soon as it is accessible. If we make significant changes to this notice, we may notify you by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice regularly to stay informed about how we are protecting your information.

14.HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have any questions or comments about this notice, you can email us at belgrade@belgradeepass.com or contact us by mail at:

Varol Grup Turizm Seyahat ve Teknoloji San. Tic. Ltd. Şti. Mecidiyeköy, Özçelik İş Merkezi, Atakan Sk. No:1 D:24 İstanbul, Şişli 34387 Turkey

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Depending on your country's laws, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.

Please click here to change your Consent Preferences settings.

B. Protected classification characteristics under state or federal law	Gender and date of birth	NO
C. Commercial information	Transaction information, purchase history, financial details, and payment information	YES
D. Biometric information	Fingerprints and voiceprints	NO
E. Internet or other similar network activity	Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements	NO
F. Geolocation data	Device location	NO
G. Audio, electronic, visual, thermal, olfactory, or similar information	Images and audio, video or call recordings created in connection with our business activities	NO
H. Professional or employment-related information	Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us	NO
I. Education Information	Student records and directory information	NO
J. Inferences drawn from collected personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	NO
K. Sensitive personal Information		NO