Privacy Policy

Monetari Tokenizasyon Altyapı Teknolojileri Anonim Şirketi ("Monetari", "we", "our", or "us") recognizes the importance of safeguarding the personal information of individuals who access and interact with its website. This Privacy Policy outlines the principles governing the collection, processing, storage, disclosure, and protection of personal data obtained through the use of our website. It also explains the rights available to users regarding their personal information and the measures implemented by Monetari to ensure that such information is handled securely and in accordance with applicable data protection laws.

1. About Us and Our Role as Data Controller

For the purposes of applicable data protection legislation, Monetari Tokenizasyon Altyapı Teknolojileri A.Ş. ("Monetari", "we", "our", or "us") acts as the data controller in relation to the personal data processed through this website.

Our corporate details are as follows:

If you have any questions regarding this Privacy Policy or the manner in which your personal data is processed, you may contact us using the details provided above.

2. Personal Data We Collect

The categories of personal data we process depend on how you interact with our website and services.

2.1. Information You Voluntarily Provide

If you contact Monetari through our website, request information, submit an inquiry, or communicate with us by email, we may collect the personal information you choose to provide. This may include your name, email address, company or organization, job title, telephone number, and the contents of your communication, together with any additional information you voluntarily share with us.

2.2. Information Collected Automatically

When you access or browse our website, certain information is collected automatically to help us operate, maintain, and improve our services. Such information may include your IP address, browser type and version, operating system, device characteristics, language preferences, pages visited, date and time of access, referring website, and other technical information relating to your interaction with the website.

We may also use cookies and similar technologies to enable essential website functionality, maintain security, remember user preferences, and better understand how visitors use our website. Further information regarding our use of cookies is available in our Cookie Policy.

2.3. Sensitive Personal Data

Our website is not intended to collect or process special categories of personal data (such as information concerning health, biometric identifiers, racial or ethnic origin, religious beliefs, political opinions, trade union membership, or sexual orientation). We kindly ask users not to submit such information through our website, contact forms, or email communications unless specifically requested or otherwise required by applicable law.

3. Purposes of Processing Your Personal Data

Monetari processes personal data only where it is necessary for legitimate business purposes or to comply with applicable legal requirements. Depending on your interaction with our website, your personal data may be used for the following purposes:

• To respond to your requests, questions, or other communications and provide the information or assistance you have requested.
• To communicate with you regarding our products, services, business activities, updates, events, or other information that may be relevant to your interests, where permitted by applicable law.
• To administer, maintain, monitor, and improve the functionality, performance, and security of our website and related systems.
• To analyze website usage, diagnose technical issues, and enhance the overall user experience.
• To detect, investigate, and prevent fraud, unauthorized access, cybersecurity incidents, or other unlawful activities.
• To comply with applicable laws, regulatory requirements, judicial orders, and other legal obligations, and to protect the rights, property, and legitimate interests of Monetari and its users.

4. Legal Basis for Processing

Monetari processes personal data only where there is a lawful basis to do so under the data protection laws applicable in the relevant jurisdiction. The legal basis relied upon will depend on the nature of the processing activity and the relationship between Monetari and the individual concerned.

Where required by law, Monetari will rely on an individual's consent before carrying out certain processing activities, such as the use of non-essential cookies, the delivery of marketing communications, or other activities requiring prior authorization. Individuals may withdraw their consent at any time, although such withdrawal will not affect the lawfulness of any processing carried out before the consent was withdrawn.

In many cases, Monetari processes personal data because it is necessary to take steps at an individual's request before entering into a contract or to perform obligations arising under an existing contractual relationship. This includes responding to business inquiries, providing requested services, onboarding customers, and administering contractual arrangements.

Monetari may also process personal data where it is necessary for its legitimate business interests, provided that such interests are not overridden by the rights and freedoms of the individuals concerned. These legitimate interests include operating and improving the website and services, ensuring the security and integrity of our systems, communicating with customers and prospective clients, preventing fraud and misuse, protecting our legal rights, and supporting the efficient operation of our business.

In certain circumstances, Monetari is required to process personal data in order to comply with applicable legal obligations, regulations, judicial decisions, regulatory requirements, or lawful requests from competent authorities. Where such legal obligations apply, the processing of personal data will be carried out only to the extent necessary to satisfy those obligations.

Where the processing of personal data is subject to the requirements of the EU General Data Protection Regulation (GDPR), the UK GDPR, the Turkish Personal Data Protection Law No. 6698 (KVKK), or other applicable data protection legislation, Monetari will ensure that the processing is conducted in accordance with the relevant legal basis and the principles established under those laws.

5. Cookies and Similar Technologies

Monetari uses cookies and similar tracking technologies to ensure the proper operation of its website, enhance user experience, analyze website performance, and maintain the security of its online services. Certain cookies are essential for the functionality of the website and are automatically enabled, while optional cookies, including those used for analytics or marketing purposes, will only be placed on your device where your consent is required under applicable law.

You may manage your cookie preferences or withdraw your consent at any time through our cookie settings or your browser configuration. Additional information regarding the types of cookies we use, their purposes, retention periods, and the choices available to you can be found in our Cookie Policy.

6. Disclosure of Personal Data

Monetari does not sell, rent, or otherwise commercially exploit personal data provided by its users.

Where necessary and in accordance with applicable law, personal data may be disclosed to carefully selected third parties that support our business operations. These recipients may include technology infrastructure providers, cloud hosting providers, website and cybersecurity service providers, payment service providers, customer support platforms, and other vendors that process personal data solely on Monetari's behalf and under appropriate contractual and confidentiality obligations.

Personal data may also be shared with our professional advisers, including legal counsel, auditors, consultants, accountants, and other independent professionals where such disclosure is necessary to obtain professional services or protect Monetari's legitimate interests.

Where required by applicable law or in response to a valid legal process, Monetari may disclose personal data to courts, regulatory authorities, law enforcement agencies, governmental bodies, or other competent public authorities.

In the event of a corporate transaction, including a merger, acquisition, restructuring, financing, or the sale of all or part of Monetari's business or assets, personal data may be transferred to the relevant successor entity or prospective purchaser, provided that appropriate safeguards are implemented to protect such data in accordance with applicable data protection laws.

7. International Data Transfers and Data Storage

Monetari may store and process personal data using secure information systems, cloud infrastructure, and service providers located in different jurisdictions, depending on the nature of the services provided and our operational requirements. As a result, personal data may be transferred to, stored in, or accessed from countries other than the country in which it was originally collected.

Whenever personal data is transferred internationally, Monetari implements appropriate technical, organizational, and contractual safeguards to ensure that such transfers are conducted securely and in compliance with applicable data protection laws.

Where required under applicable law, Monetari relies on legally recognized data transfer mechanisms, including the European Commission's Standard Contractual Clauses (SCCs), the UK International Data Transfer Addendum, adequacy decisions adopted by competent authorities, the EU–US Data Privacy Framework where applicable, and, where relevant, the cross-border data transfer mechanisms permitted under the Turkish Personal Data Protection Law No. 6698 (KVKK), as well as any other lawful international data transfer mechanisms recognized by the applicable data protection authorities.

Regardless of where personal data is processed or stored, Monetari applies appropriate administrative, technical, and organizational security measures designed to protect personal data against unauthorized access, disclosure, alteration, loss, destruction, or any other form of unlawful or unauthorized processing.

8. Data Retention

Monetari retains personal data only for as long as it is necessary to fulfill the purposes for which it was collected, including providing our services, responding to inquiries, maintaining business records, complying with legal and regulatory obligations, resolving disputes, and enforcing our contractual rights.

The retention period applicable to personal data may vary depending on the nature of the information, the purpose of processing, and the legal requirements of the jurisdictions in which Monetari operates. Once personal data is no longer required for these purposes, it will be securely deleted, anonymized, or otherwise disposed of in accordance with applicable laws and Monetari's internal data retention and disposal procedures.

Where applicable law requires Monetari to retain certain records for a specified period, such personal data will be retained only for the duration required by the relevant legal or regulatory obligations.

9. Individual Privacy Rights

Depending on your country of residence and the data protection laws applicable to you, you may have certain rights regarding the personal data that Monetari processes about you. These rights may include:

• The right to request access to your personal data.
• The right to request correction of inaccurate or incomplete information.
• The right to request the deletion of your personal data.
• The right to restrict or object to certain processing activities.
• The right to request the portability of your personal data.
• The right to withdraw your consent where processing is based on consent.

If you are located in the European Economic Area (EEA) or the United Kingdom, you may exercise the rights available under the General Data Protection Regulation (GDPR) or the UK GDPR and may also lodge a complaint with the competent supervisory authority in your jurisdiction.

If you are located in Türkiye, you may exercise your rights under the Turkish Personal Data Protection Law No. 6698 ("KVKK"), including the right to submit requests directly to Monetari and, where applicable, to file a complaint with the Turkish Personal Data Protection Authority.

If you are located in the United States or another jurisdiction with applicable privacy legislation, you may also benefit from additional rights provided under the relevant laws, including, where applicable, the right to know what personal data is collected, request access to or deletion of personal data, correct inaccurate information, or opt out of certain processing activities.

To exercise any of your privacy rights or to submit a request regarding the processing of your personal data, you may contact Monetari using the contact details provided in this Privacy Policy. For your protection, Monetari may request additional information to verify your identity before processing your request. We will respond to all legitimate requests within the timeframes required by the applicable laws.

10. Data Security

Monetari is committed to maintaining the confidentiality, integrity, and availability of the personal data it processes. We implement appropriate administrative, technical, organizational, and physical security measures designed to protect personal data against unauthorized or unlawful access, disclosure, alteration, destruction, loss, or other forms of misuse.

These safeguards are regularly reviewed and updated to address evolving security risks, technological developments, and applicable legal and regulatory requirements. Although no method of transmitting or storing information electronically can be guaranteed to be completely secure, Monetari continuously works to maintain security measures that are appropriate to the nature and sensitivity of the personal data processed.

11. Privacy of Minors

Monetari's website, products, and services are intended for businesses and individuals who are legally capable of entering into binding agreements and are not directed toward minors.

Monetari does not knowingly collect or process personal data relating to minors. If we become aware that personal data relating to a minor has been collected without the necessary legal basis or parental authorization where required, we will take appropriate steps to delete such information without undue delay.

12. External Services and Third-Party Websites

Monetari's website may contain links to third-party websites or services that are not owned or controlled by Monetari. This Privacy Policy does not apply to such third-party websites or services. We encourage you to review their respective privacy policies before providing any personal data.

13. Changes to This Privacy Policy

Monetari may revise or update this Privacy Policy from time to time to reflect changes in applicable laws, regulatory requirements, our business operations, or the way we process personal data. Any amendments will become effective upon publication of the updated Privacy Policy on our website, unless otherwise required by applicable law.

Where the changes are material or where notification is required by applicable law, Monetari will take appropriate steps to inform users through the website or by other reasonable means. We encourage you to review this Privacy Policy periodically to remain informed about how we collect, use, and protect your personal data.