Privacy Policy

Effective Date: 04.08.2025

INTERSYS SANAYI TICARET ANONIM SIRKETI ("we", "us", or "our") values your privacy and is dedicated to protecting the personal information you share while using our application. The app is designed primarily for network access and management. This Privacy Policy outlines the types of data we collect, how we use it, and your rights concerning your information. By using this app, you agree to the practices outlined below.

1. Who We Are

Company Name: INTERSYS SANAYI TICARET ANONIM SIRKETI

Purpose of the App: The app is designed to provide network access and management functionalities. It allows users to manage their network activities securely.

Purpose of This Policy: The purpose of this Privacy Policy is to inform users about how their personal and non-personal information is collected, used, and protected. It outlines how we handle user data to ensure compliance with relevant laws and provide transparency on our practices.

2. Data We Collect

We may collect both personal and non-personal data to facilitate the functionality of our app.

Personal Data

Personal data refers to information that can identify you as an individual. We may collect the following personal data:

• Birth Year: To verify your age and compliance with age restrictions.
• First Name and Last Name: To identify you and create your user profile.
• Identity Number (T.C. Kimlik Numarası): Required for identity verification purposes via the official Turkish Government API.
• Phone Number: Used for verification through OTP (One-Time Password) sent via SMS.

Non-Personal Data

Non-personal data is information that cannot be used to identify you individually. This data helps us improve the app’s performance and functionality:

• SecNAP Server IP Address and Port: These are used to identify the server where the app communicates for network access.
• Firewall User IP Address: This data helps us track users who interact with our firewall services.

3. How We Collect Data

We collect data in the following ways:

Identity Verification Form

Upon registration, users enter personal information such as their full name, identity number, and date of birth. If the verification process via the official Turkish Government API is successful, this information is securely stored in Firebase. If the verification fails, the data is discarded to maintain your privacy.

Phone Verification

Users provide their phone number, which triggers an OTP SMS. If the OTP verification is successful, the phone number is securely stored in Firebase. If the verification is unsuccessful, the phone number is discarded, and no further action is taken.

No Cookies or Trackers

We do not use cookies, advertising trackers, or analytics tools that collect user behavior data. Your privacy is our priority, and we strive to minimize unnecessary data collection.

4. Why We Collect Data (Legal Basis)

We collect personal data for the following reasons, which are essential to the functionality of the app:

• To Enable Portal Login: The identity verification process is necessary to grant access to the portal login feature. This feature is linked to the external SecNAP web platform, where users can manage network settings. Without successful verification, users cannot access the portal login.
• Not Required for All App Features: It’s important to note that submitting personal data is not mandatory to use most parts of the application. You can still use the app for non-restricted functions, such as managing network settings or viewing basic information, without providing personal data.

Legal Basis under GDPR

Under the General Data Protection Regulation (GDPR), the legal basis for processing your personal data includes:

• User Consent: You give consent by agreeing to provide your personal data for identity and phone verification.
• Compliance with Legal Obligations: We process your data to comply with applicable laws and regulations.

5. How We Use the Data

The data we collect is used to ensure smooth operation and enhanced functionality of the app:

• If phone and identity verification are successful, we store a flag (either true or false) in the database to indicate the verification status.
• Users are only granted access to the portal login feature if their verification status is marked as true.

Your data is stored securely and is never shared without your consent.

6. Data Storage and Retention

All collected data is securely stored in Google Firebase, a reputable cloud-based platform known for its security infrastructure.

Retention Period

Data is retained until the user decides to delete their account. If a user chooses to delete their account, all associated personal data will also be permanently deleted from our servers.

7. Data Security

We prioritize the protection of your personal data. To ensure the security of your information:

• We use Firebase’s security infrastructure to store and protect your data.
• We implement industry-standard encryption and authentication mechanisms to safeguard your data from unauthorized access.
• Access to personal data is restricted to authorized personnel only and is managed with strict security protocols.

8. Data Sharing with Third Parties

We do not share your personal or non-personal data with any third parties, except in the following cases:

• Identity Verification: We use the official Turkish Government API for identity verification. This service is only accessed during the verification process and does not store or share your data beyond that point.
• Service Providers: We may share data with third-party service providers (like Firebase) that help facilitate the app's operation. These providers are bound by data protection agreements and only process data on our behalf.

9. Your Rights

As a user, you have certain rights regarding your personal data under applicable data protection laws. These rights include:

• Access: You can request a copy of your personal data that we have stored.
• Deletion: You can delete your account and all associated data through the app by going to Settings > Delete Account.
• Correction: If any of your personal data is inaccurate, you can request its correction.
• Objection: You can object to the processing of your data under certain circumstances.

For any other requests or inquiries regarding your personal data, please contact us via email at support@intersys.com.tr.

10. International Data Transfers

Your personal data is stored in Firebase, whose servers may be located outside of your country, including in the United States. While we do not control the server locations of Firebase, we ensure that any data transfers comply with applicable data protection regulations.

11. Cookies and Trackers

We do not use cookies, advertising trackers, or analytics tools to collect user behavior data. Your privacy is important to us, and we do not engage in practices that would track or collect your browsing activities.

12. Privacy Policy Updates

We may update this Privacy Policy from time to time. Any changes will be posted in this section with an updated "Effective Date." We recommend you review this policy periodically for any updates.

13. Contact Us

If you have any questions or concerns about this Privacy Policy or how we handle your data, please contact us:

• Email: support@intersys.com.tr