Update Date: 10 Nov. 2023
1. Objective
moonTV LTD ("moonTV" or "the Company") is committed to adhering to privacy principles and relevant data protection laws, such as the Personal Data Protection Law No. 6698 and other applicable laws, when it comes to handling user's personal information. The Company ensures that all user data is processed in accordance with these laws and regulations. Please read and understand this "Privacy Policy" (referred to as "this policy" hereinafter) carefully to gain a comprehensive understanding of how we collect, use (including commercial cooperation use), store, and share information. This will enable you to make informed choices and have a better understanding of our services. By using the moonTV service, you agree to the contents of this policy. If you do not consent to your personal information being processed in accordance with this privacy policy, please refrain from providing your personal information when requesting on moonTV and discontinue using moonTV.
If you have any inquiries, please contact us using the contact information provided in the main text of this policy.
As the "Data Controller," our company may process the personal information that you have provided or will provide to us, as well as any data obtained from external sources. The processing of your personal data will be limited and proportionate to its purpose, and we will ensure the accuracy and currency of the information provided to us. This data may be recorded, stored, preserved, reorganized, and transferred to authorized institutions as required by law. Additionally, it may be shared with third parties domestically or internationally in accordance with legislation and with your explicit consent if necessary. Furthermore, it may be processed using other methods listed in legislation and subject to other procedures outlined in the legislation.
This Privacy Policy has been created to ensure that moonTV complies with the principles outlined in the PDP Law and continues to enhance its activities. Our Privacy Policy outlines the data we collect, how we intend to use it, how we plan to store, protect, and share this data, as well as how you can withdraw your consent for processing the data and correct any inaccuracies. Any capitalized terms used in this Policy are defined in the Terms and Conditions, unless separately defined in this Policy.
2. Purposes of Processing Personal Data and Legal Reasons
Your personal data will be processed in accordance with applicable laws and Articles 5 and 6 of the PDP Law, using automated or non-automated methods, for the purposes outlined below. Processing is allowed when explicitly permitted by law, necessary for the establishment or performance of a contract or direct relationship, or for the legitimate interests of moonTV, provided that your fundamental rights and freedoms are protected.
a) Purposes of Personal Data Processing
Your personal data is processed for the following purposes, in line with the aforementioned general conditions:
Security of Processes:
●Carrying out activities in compliance with the law
●Executing company/product/service commitment operations
●Conducting communication activities
●Executing/auditing business activities
●Providing after-sales support services for goods/services
●Executing goods/services sales processes
●Carrying out storage and archiving activities
●Executing agreement processes
●Implementing information security processes
●Conducting audit/ethical activities
●Executing/auditing business activities
●Conducting activities to ensure business continuity
●Providing information to authorized individuals, institutions, and organizations
Customer Transactions:
●Executing/auditing business activities
●Providing after-sales support services for goods/services
●Executing goods/services sales processes
●Conducting activities for customer satisfaction
●Executing agreement processes
Marketing Data:
●Conducting marketing analysis studies
●Executing advertising/campaign/promotion processes
The purposes of processing personal data may be revised in accordance with our obligations arising from company policies and legislation, including creating user accounts, customizing our services, informing about new products, services, and applications, conducting digital subscriptions and in-app purchase processes, performing auto-renewable subscriptions, carrying out information security processes, fulfilling the demands of competent authorities, conducting financial and accounting transactions, engaging in communication activities, executing contract processes, conducting strategic planning activities, and addressing requests and complaints.
b) Legal Basis
Customer Transactions:
●Processing your personal data is necessary for establishing a contractual relationship with you or for fulfilling our contractual obligations arising from the said contract.
●We are required to process data in order to establish, exercise, or defend your legal rights.
Process Security:
●The law explicitly specifies the process through which we process your personal data.
●Processing is necessary to fulfill our legal obligations.
●Processing your personal data is necessary for establishing a contractual relationship with you or for fulfilling our contractual obligations arising from the said contract.
Marketing Data:
●Processing of your personal data requires your explicit consent, which is obtained through Apple platforms.
Third Party Websites and Applications
We may display, include or make available third-party content (including data, information, applications and other products services) or provide links to third-party websites or services ("Third-Party Services").
You acknowledge and agree that moonTV shall not be responsible for any Third-Party Services, including their accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other aspect thereof. moonTV does not assume and shall not have any liability or responsibility to you or any other person or entity for any Third-Party Services.
Third-Party Services and links thereto are provided solely as a convenience to you and you access and use them entirely at your own risk and subject to such third parties' terms and conditions.
Automatic Data Collection
When you use our Services, we automatically collect certain information, including your IP address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information, and internet service provider. Additionally, we track your usage of our Services, such as the pages you visit, links you click, types of content you interact with, and the duration of your activities. Other users of our Services may also provide information about you through tagging. It is important to note that we prioritize the protection of your privacy and handle your information with the utmost care. The collected information is comprehensive in nature and does not include personally identifiable information, unless explicitly permitted by the customer.
Cookies
moonTV uses "Cookies" to identify the areas of our website that you have visited. A Cookie is a small piece of data stored on your computer or mobile device by your web browser. We use Cookies to enhance the performance and functionality of our app but are non-essential to their use. However, without these cookies, certain functionality like videos may become unavailable or you would be required to enter your login details every time you visit the app as we would not be able to remember that you had logged in previously. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access functionality on our website correctly or at all. We never place Personally Identifiable Information in Cookies.
Technical and Administrative Measures
moonTV ensures that the personal data it processes is stored in accordance with relevant legislation for the specified durations or as necessary for the processing purposes. We are committed to implementing all necessary technical and administrative measures to maintain the confidentiality, integrity, and security of personal data. Various measures are taken to prevent unauthorized access, unlawful disclosure, modification, or destruction of data, as well as unlawful processing of personal data. These measures include:
●Regularly updating anti-virus applications on all computers and servers in moonTV's information technology infrastructure.
●Implementing periodically updated software-loaded firewalls to protect the data center and disaster recovery centers hosting moonTV servers, providing internet connection control and protection against viruses and similar threats.
●Allowing suppliers to access moonTV servers or systems through SSL-VPN defined on firewalls, with separate SSL-VPN identifications for each supplier to ensure authorized access.
●Limiting moonTV employees' authorization to the systems based on job descriptions, updating systemic authorizations when there are changes in authority or duty.
●Utilizing an Information Security Threat and Event Management system to transfer events occurring on moonTV servers and firewalls, alerting responsible staff to security threats and enabling immediate response.
●Storing sensitive data with cryptographic methods, encrypting data transfers when required, and storing cryptographic keys in secure environments.
●Securely logging all transaction records related to sensitive data.
●Enabling remote access to sensitive data through at least two-factor authentication.
●Conducting periodic penetration tests on moonTV servers, closing any identified security gaps, and recording test results.
●Auditing topics contained in the control forum at Information Security Management System meetings, conducted by the director of information technology and the director of financial operations.
●Providing regular training to increase awareness among moonTV employees regarding information security violations and minimize the impact of human factors.
●Implementing physical data security measures such as storing personal data on paper in lockers and restricting access to authorized personnel.
●Periodically backing up the stored data using backup facilities provided by cloud infrastructure providers or backup solutions developed by Mini TV, in compliance with relevant legislation and policy provisions.
●Concluding non-disclosure agreements with employees involved in the processing of sensitive personal data.
●Transferring sensitive personal data through encrypted corporate email or Registered E-mail if necessary.
●In the event of a data breach or unauthorized access to personal data despite implemented security measures, promptly informing users and, if required, the relevant data protection authority, and taking appropriate measures.
3.Transferring Personal Data to Third Parties
The transfer of personal data is subject to regulations outlined in Articles 8 and 9 of the PDP Law. As moonTV may utilize servers and cloud systems located outside the country, personal and sensitive data may be transferred domestically and internationally to third parties. The transfer of your personal data overseas may be necessary for purposes such as storage and archive activities, business activities, after-sales support services for goods and services, and customer relationship management processes. moonTV may also transfer your personal data to service providers and third parties embedded into our service, such as Facebook SDK, Adjust, and Firebase Analytics, for authorized activities in compliance with legislation, monitoring and executing legal affairs, and informing authorized persons, institutions, and organizations.
4.Your Rights as the Data Subject
According to Article 11 of the PDP Law, you have the right to request the following regarding your personal data by contacting moonTV:
●To know whether your personal data has been processed.
●To request information on whether your personal data has been processed and used in compliance with its purpose.
●To know the third parties, both in the country and abroad, to whom your personal data has been transferred.
●To request notification of incomplete or inaccurate processing of your personal data to third parties it has been transferred to.
●To request deletion, destruction, or anonymization of personal data and notification of these actions to relevant third parties if the reasons for processing have disappeared.
●To object to any adverse result caused by the analysis of personal data exclusively through automated systems.
●To request compensation for damages incurred due to unlawful processing of your personal data.
If the General Data Protection Regulation (GDPR) applies, data subjects have additional rights, including the right of access, right to correction, right to deletion, right to restrict processing, right to object to processing, right to data portability, and right to object to automated decision-making.
To exercise your rights as a data subject, you must provide a clear and understandable request, accompanied by appropriate documentation if acting on behalf of someone else. The request should include your identity and address information and be submitted through the "Data Subject Application Form" at [email protected]. moonTV will process your request free of charge within a maximum of 30 days, as per Article 13 of the PDP Law, depending on the nature of the request. In case your request is denied, a written or electronic explanation along with a justification for the decision will be provided. If you believe your rights are being violated, you can file a complaint with the data protection authority in your country and other competent supervisory authorities.
5.IN-APP PURCHASE AND PAYMENT
5.1. The moonTV Apps are globally released and distributed through the Apple App Store. Certain features and limitations of the moonTV Apps are available as paid features through in-app purchase. To access these paid features, payment must be made before accessing them.
This Privacy Policy may be revised by our company when necessary. Continuing to access and use moonTV without opting out of the services after the notification period will be deemed acceptance of the changes in this Privacy Policy.