La traducción al español de este documento está en preparación. El texto siguiente es la versión inglesa, que es la vinculante.
1. Who is responsible for your data
The controller of your personal data is Netmar LLC, 112 Capitol Trail, Suite A3703, Newark, DE 19711, USA (“NetmarPlus”, “we”, “us”). Contact for all privacy matters: info@netmarpazarlama.com.
For users in Türkiye, Netmar Pazarlama Turizm Ticaret İthalat İhracat Limited Şirketi (tax number 6310784792), our authorized distributor, is the data controller (veri sorumlusu) under Turkish Law No. 6698 on the Protection of Personal Data (KVKK) for the bank-transfer purchases of NetmarPlus Gift Cards it handles and the related customer checks, and it acts together with us for the verification of Turkish accounts. Its KVKK notice is published in the KVKK Aydınlatma Metni. Contact: info@netmarpazarlama.com.
This policy applies to the NetmarPlus website, your Account and Wallet, and our communications with you. It is written to meet the EU General Data Protection Regulation (GDPR), the UK GDPR, the California Consumer Privacy Act as amended by the CPRA (CCPA) and other U.S. state privacy laws.
2. Summary
- We collect only what we need to run your Account, deliver codes, prevent fraud and meet legal duties.
- We do not collect or store bank card details. Online top-ups (outside Türkiye) are processed by Stripe, which receives your payment details directly; we only receive the payment status, amount, method type and a reference.
- We do not sell your personal information, “share” it for cross-context behavioural advertising, or use advertising cookies.
- You can download your data and delete your Account yourself in Wallet → Privacy & data.
3. What we collect
| Category | Examples | Source |
|---|---|---|
| Account data | User name (public, see below), account type (individual or business), e-mail address, mobile phone number, country and region, password (stored only as a salted PBKDF2 hash), account creation date, e-mail and phone verification dates | You |
| Identity verification data (individuals) | Full name, date of birth, address, the type and number of your identity document (for residents of Türkiye: T.C. Kimlik No), images of your identity document and a selfie holding it | You |
| Business verification data | Legal name, registration and tax numbers, registered address, company documents listed in the Account Verification Policy, and the name, role and identity document of the authorized person | You |
| Review data | Approval or rejection of your application, the reason, the date and the reviewing staff member | Us |
| Bank-transfer notices (Türkiye) | Amount, date, sender name and bank you report when you buy NetmarPlus Gift Cards from our distributor by bank transfer | You |
| Consent and compliance records | Version and time of the Terms you accepted, your age confirmation, your immediate-delivery consent for each order, cookie choices | You / generated |
| Wallet and transaction data | NetmarPlus Gift Card codes you redeem and their value, Wallet Balance, orders, products and codes delivered to you, withdrawal requests | You / generated |
| Support data | Messages you send us and our replies | You |
| Community content | Chat messages, posts, photos, #tags and comments you share; who you follow, your friends, the posts you hide, the members you block and reports you send. Photos are resized in your browser before upload, which removes hidden photo data such as GPS location. | You |
| Support requests | If you use the contact form: your name, e-mail, topic, optional order reference, your message, language and country (from your connection). Used only to answer your request (contract / legitimate interest). A copy is sent by e-mail to our support team. | |
| Seller applications | If you apply to sell NetmarPlus Gift Cards: business name and type, your name, e-mail, phone or Telegram user name, country, city and your message. Used only to assess the application and contact you (legitimate interest / steps before a contract). | |
| Technical and security data | IP address, browser and device information, time of requests, failed code attempts, security signals from our hosting provider | Automatically |
| Preferences | Language and display currency (stored in your browser only with your consent) | You |
We do not intentionally collect special categories of personal data (such as health data) and ask you not to send them to us.
Community. What you share in the community chat and on the community page is visible to all signed-in members under your user name. Do not share personal data there. We use community content to run the community, to enforce our rules (legitimate interest) and to comply with legal obligations to remove illegal content.
4. Why we use your data and our legal bases
| Purpose | Legal basis (GDPR / UK GDPR) |
|---|---|
| Creating and running your Account and Wallet, redeeming NetmarPlus Gift Cards, selling and delivering Products, customer support | Performance of a contract (Art. 6(1)(b)) |
| Keeping records of orders, consents and withdrawal requests; tax, accounting and consumer-law obligations; responding to authorities | Legal obligation (Art. 6(1)(c)) |
| Verifying your e-mail address and mobile number, verifying your identity or business and reviewing your application before your Account is activated | Legitimate interests (Art. 6(1)(f)) in preventing fraud, account takeover, stolen-card laundering and sales to minors; legal obligation (Art. 6(1)(c)) where a law of your country requires it; performance of a contract (Art. 6(1)(b)) |
| Fraud prevention, rate-limiting of code attempts, security of the Service, enforcing our Terms, defending legal claims | Legitimate interests (Art. 6(1)(f)) in a secure and lawful service |
| Service messages such as order confirmations and important changes | Contract (Art. 6(1)(b)) and legal obligation (Art. 6(1)(c)) |
| Remembering your language and currency | Consent (Art. 6(1)(a)); you can withdraw it at any time in Cookie settings |
| Marketing e-mails (only if we introduce them) | Consent (Art. 6(1)(a)); we do not send marketing at present |
Providing your e-mail address, mobile number, password and the verification information for your account type and country is necessary to open an Account; without it we cannot activate the Wallet or sell Products to you.
Your selfie and document images are compared with each other by a member of our staff. We do not use automated face recognition and do not create biometric templates.
We do not make decisions based solely on automated processing that produce legal or similarly significant effects on you. Automated security measures, such as temporarily blocking code entry after repeated wrong attempts, can be reviewed by a person on request.
6. International transfers
We are based in the United States, and our providers may process data in the United States and other countries. When we transfer personal data from the EU, EEA, UK or Switzerland to a country without an adequacy decision, we rely on the EU–U.S. Data Privacy Framework (and its UK and Swiss extensions) where the recipient is certified, or on the European Commission’s Standard Contractual Clauses and the UK International Data Transfer Addendum, together with appropriate supplementary measures. You can request a copy of the relevant safeguards from us.
7. How long we keep data
| Data | Retention |
|---|---|
| Account data | Until you delete your Account; then removed or anonymised, except as below |
| Public user name and the "recent purchases" strip | Shown while your Account is open. Your user name, the product name and the time of a purchase may appear in the "recent purchases" strip on the website; prices, codes and your real or company name are never shown. You can turn this off at any time in Account → Settings. |
| Orders, transaction and Wallet records | Up to 10 years after the end of the year of the transaction, as required by tax and VAT rules (including EU One-Stop-Shop record-keeping) |
| Consent records (Terms, immediate-delivery consent) and withdrawal requests | For the duration of the contract plus the applicable limitation period, generally up to 6 years |
| Identity and business verification documents and selfies | For as long as your Account is open and up to 5 years after it is closed, to prevent repeat fraud and to defend legal claims. Documents of rejected or abandoned applications are deleted 6 months after the decision or last activity |
| Verification codes | Stored only as hashes and deleted after use or expiry (10 minutes) |
| Sign-in sessions | 30 days or until you sign out |
| Failed code attempts | Deleted on a rolling basis; only the last hour is used for blocking |
| Support messages | Up to 3 years after the case is closed |
| Support requests | Up to 2 years after the request is closed, longer if needed for a dispute or legal claim |
| Seller applications | Up to 2 years after the last contact, or for the duration of the seller agreement and the statutory retention period afterwards |
| Community chat messages | 30 days, then deleted automatically |
| Community posts, photos and comments; follows, friends and blocks | Until you delete them or your Account. Content removed by our moderators and the related reports are kept for up to 1 year to handle complaints and repeated abuse. |
| Security logs at our hosting provider | As set by the provider, typically a few days to weeks |
When you delete your Account, we remove your e-mail address and password and keep only anonymised order records that we must retain by law.
8. Security
We protect your data with encrypted connections (TLS), salted password hashing, HttpOnly and Secure session cookies, server-side price checks, rate-limiting and restricted administrative access. No system is completely secure; if a personal data breach is likely to result in a risk to you, we will notify you and the competent authorities as required by law.
9. Your rights (EU, EEA, UK and Switzerland)
You have the right to:
- access your personal data and receive a copy;
- have inaccurate data corrected;
- have your data erased, subject to our legal retention duties;
- restrict processing in certain cases;
- data portability: receive the data you gave us in a structured, machine-readable format;
- object to processing based on legitimate interests, and to direct marketing at any time;
- withdraw consent at any time, without affecting the lawfulness of processing before withdrawal;
- lodge a complaint with a data protection supervisory authority, in particular in your country of residence or work. In the UK this is the Information Commissioner’s Office (ICO).
You can use “Download my data” and “Delete my account” in Wallet → Privacy & data, or write to info@netmarpazarlama.com. We respond within one month; this can be extended by two further months for complex requests, in which case we will tell you. We may need to verify your identity.
10. Your rights (United States)
Depending on your state of residence (including California, Colorado, Connecticut, Virginia, Utah, Texas, Oregon and other states with comprehensive privacy laws), you may have the right to:
- know / access the categories and specific pieces of personal information we hold about you;
- delete personal information we collected from you;
- correct inaccurate personal information;
- data portability;
- opt out of the sale of personal information, “sharing” for cross-context behavioural advertising, targeted advertising and profiling with significant effects. We do not do any of these.
- limit the use of sensitive personal information. We use your log-in credentials and your identity document only to authenticate and verify you and to prevent fraud, which are permitted purposes, so this right does not require any action;
- non-discrimination for exercising your rights;
- appeal our decision on your request by replying to our decision e-mail with the subject “Privacy appeal”. If you are not satisfied with the outcome of the appeal, you may contact your state Attorney General.
Submit requests through the tools in your Account or to info@netmarpazarlama.com. You may use an authorized agent; we may ask for proof of authorization and verify your identity. We respond within 45 days, extendable by a further 45 days where permitted.
Notice at collection (California)
| CCPA category | Collected | Purpose | Sold / shared |
|---|---|---|---|
| Identifiers (name, e-mail, mobile number, postal address, IP address, account ID) | Yes | Account, verification, delivery, security | No |
| Personal records (identity document details, date of birth; business records for business accounts) | Yes | Identity and business verification, fraud prevention | No |
| Commercial information (orders, Wallet records) | Yes | Contract, legal records | No |
| Internet or network activity (request logs, security signals) | Yes | Security, fraud prevention | No |
| Sensitive personal information (account log-in and password; government identity document number and image) | Yes | Authentication, identity verification | No |
| Precise geolocation, biometric identifiers (we do not run face recognition), inferences, protected characteristics | No | – | – |
Retention periods are listed in section 7. In the past 12 months we have not sold or shared personal information, and we have no actual knowledge of selling or sharing data of consumers under 16.
11. Your privacy choices
- Cookies and storage: change your choices at any time via “Cookie settings” in the footer.
- Global Privacy Control (GPC): we treat a GPC signal as a valid request to opt out of sale and sharing for that browser. Because we do not sell or share personal information, no further change is needed.
- Do Not Track: we do not track you across third-party websites.
- Account tools: download your data or delete your Account in Wallet → Privacy & data.
12. Children
The Service is intended for adults. We do not knowingly collect personal data from anyone under 18. If we learn that we have collected data from a child, we will delete it. Parents or guardians who believe their child has given us personal data can contact us.
13. Changes to this policy
We may update this policy. We will post the new version with a new effective date and, for material changes, notify you by e-mail or in your Account before the change takes effect.
14. Contact
Netmar LLC, 112 Capitol Trail, Suite A3703, Newark, DE 19711, USA
Privacy: info@netmarpazarlama.com
Datos de la empresa
Titular del sitio y vendedor
Netmar LLC
Sociedad de responsabilidad limitada (LLC) constituida según las leyes del Estado de Delaware (EE. UU.)
112 Capitol Trail, Suite A3703, Newark, DE 19711, USA
Distribuidor autorizado en Turquía
Netmar Pazarlama Turizm Ticaret İthalat İhracat Limited Şirketi
Oficina tributaria: Marmaris Vergi Dairesi Müdürlüğü · VKN: 6310784792
E-mail: info@netmarpazarlama.com
NetmarPlus es una marca de Netmar LLC. En Turquía, las NetmarPlus Gift Cards las vende al por mayor y al por menor Netmar Pazarlama Ltd. Şti..