1. Introduction

The purpose of this Privacy and Personal Data Protection Policy ("Policy") is to determine the terms and conditions regarding the use of personal data provided by users and members of the website on (“Platform” or “Mindturtle”) and/or obtained during the use of Mindturtle's all kinds of applications, products and services (“Services”). 

The scope of this Policy consists of explanations regarding the processing of personal data such as the collection, use, sharing, preservation and protection of personal data with third-parties and explanations regarding the rights that are owned by them.

This Policy can be modified at any time. Important changes that will take effect immediately upon publication on the Mindturtle website will also be posted via email.

2. Collection of Personal Data

When you use our Services, create an account, fill out a form on the Platform, update or add information to your account, or purchase or sell products and / or services, participate in a dispute resolution, contact us or other users about our Services, and visit our Platform, we collect, process and maintain your personal data. The main personal data we collect, including those obtained from other sources, are listed below.

2.1. Personal data you provide to us when you create an account and use our services:
  • When you create an account; when you add your profile information, your resume information such as your name, location, title, experience, education, projects, and descriptive information such as your phone and e-mail address.
  • Information you produce, photos, videos and files you add when you create solutions, events or companies,
  • Proposals you offer or request, purchases or service sales, scoring and evaluations you submit.
  • During the execution of a transaction (requesting/sending a proposal, purchasing/selling services, etc.), the information you share and data you produce about these transactions, or the data associated with your account due to your being a party to the transaction
  • Other data that you produce or are linked to your account, such as adding products and services to an easily accessible tracking list (“MindList”), following solutions, events, or consultants.
  • Financial information related to your transactions, such as billing information and bank account numbers,
  • Email and telephone information used for the purpose of selling the product / service, including the purchase or listing of the products / services, invoice information, including tax identification number and other identification numbers, tracking numbers required for cargo / postal operations, and current tracking information, and other related information such as this.
  • In some cases, information about the age, gender, interests and likes you provided to us when creating an account or using our Services (if you have sign in with your Facebook, Google or Linkedin account, your profile information that you have allowed Facebook, Google and Linkedin to share with us, including your friends list, birthday, likes and email address)
  • Other information that you provide by updating or adding information about your user account created for Platform membership, by participating in the dispute resolution, or by purchasing or selling products and / or services, or by contacting us otherwise in relation to our Services, through forms available on the Platform. All kinds of interview / correspondence contents and records related to them, including users who are included in the scope.
  • Other information that we need to collect and process in accordance with applicable laws to verify or identify your identity.
  • Messaging and other correspondence content we have reviewed in order to (1) evaluate complaints from our users or third parties regarding illegal, threatening, insulting and other unwanted messages, and (2) detect spam, viruses, password stealing and other malicious acts, illegal or prohibited content, or situations that violate our Terms of Use, Privacy and Personal Data Protection Policy or other contract and policies.

2.2. Personal data we collect automatically when you use our Services or create an account
  • We collect information about your use of our Services and your advertising preferences as well as the subjects you communicate with us. This information is the information we obtain from the devices you use to access our Services, including mobile devices. This information consists of the device ID or unique identifier, device type, ad identifier, and unique device icon.
  • Geolocation information, including location information obtained from your mobile device. We would like to remind you that most mobile devices allow you to control or disable location services with an application in the device settings menu of the mobile device.
  • Computer and connection information such as page view statistics, page inbound and outbound traffic information, referrer URL, ad data, IP address, browsing history and web log information.

2.3. Cookies, personal information we collect using web beacons:
  • When you visit our Platform or use or interact with our Services, applications, tools and messaging, technologies such as cookies and web beacons are used to provide you with a better, faster, safer experience, and for information and advertising and marketing purposes,
  • For more detailed information about our use of these technologies and how you can control them, see our Cookies Policy.

2.4. Personal data we collect from other sources:
  • We may combine the data we collect with the data we receive from third parties and add it to your account information. For example, we may collect and use demographic and other information, additional contact information, credit information, and information received from the credit registry office and similar institutions, as permitted by applicable law.
  • We may allow you to share information with social media sites or to use your social media sites to create your account or link your account to related social media sites. These social media sites can give us automatic access to a number of personal data they hold (such as the content you view, the content you like, and the ads you may have shown or clicked on). You have the right to make changes to your personal data, which we can access through the privacy settings on the relevant social media site, and to change the permissions you give us, so that we can access your personal data on the relevant social media site. By associating an account managed by a social media site with your account in Mindturtle and allowing us to access this information, you agree that we may collect, use and maintain the information provided by these social media sites in accordance with this Policy. We can use plug-ins (social media plug in) or other technologies through various social media sites. When you click on a link provided through social media plugins, you will be able to connect with your own will social media site.
  • You may share personal data of others (delivery address belonging to another person, information about the holder of another card you use for transactions and similar information), only if they have explicit consent from those persons. You should also inform these people about how we collect, use, share and maintain their personal data in accordance with our Privacy and Personal Data Protection Policy.

3. Use and Storage of Your Personal Data

We use your personal data we collect for many purposes based on different legal reasons. Information about how we use your personal data and for what legal reason is given below.

We use your personal data based on the relevant provisions of the European Union General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”) and legal reasons foreseen in the Article 5(2)(a) of the Personal Data Protection Law no.6698 (“KVKK”)it is expressly provided for by the laws.”, Article 5(2)(c) “necessity to the establishment or performance of the contract”, Article (5)(2)(ç) “necessity for compliance with a legal obligation to which the data controller is subject”, Article 5(2)(e) “necessity of the data processing for the establishment, exercise or protection of any right.” and Article 5(2)(f) “necessity of the data processing for the legitimate interests pursued by the data controller”  to comply with a clear provision of the Law, to fulfill a legal obligation, to establish, use or protect a right, to protect your life and bodily integrity if necessary, to perform our rights and obligations arising from an agreement and to provide you with our services. Our activities within this framework include the following transactions: Mediate the realization of your payment transactions and to collect the payments, manage your account, ensure that our services are provided, measured and developed, ensure safe and secure access to and use of our Services and to provide a Platform content containing products and services you may like based on the transactions you carry out.
  • Notify about your account, fix problems with your account, resolve disputes, collect the fees or amounts owed or provide other services that may be required within the scope of customer service activities. For these purposes, we can contact you by mail, e-mail, phone, webpush, SMS. When communicating with you, we can use methods such as an automatic dialer or a pre-recorded call or sending SMS to ensure effectiveness. In this context, we would like to remind you that SMS and other data transmission fees may apply.
  • Provide these services if you request the services we have specified while collecting your information.
  • Prevent, detect, minimize and investigate activities that cause fraud or fraud, compromise security, or are suspicious or illegal.
  • Ensure the enforcement of our Privacy and Data Protection Policy or other policies and execute Terms of Use and any other agreement we have signed with you

We use your personal data to reach our legitimate interests, provided that they do not harm your fundamental rights and freedoms. Our activities within this framework include the following transactions:
  • Customize, measure and improve our Platform and Services
  • Personalize our advertising and marketing communications and ensure and develop more relevant to you. For this purpose, follow your use of the Platform, the information at the MindList, MyOffice and Payment Tracking pages on the Platform.
  • In cases where you are signed up with Linkedin, Google and Facebook, send commercial messages or advertisements to you using your profile information, friends list, birthday, likes, and e-mail address that you allow Linkedin, Google, and Facebook to share with us.
  • If you give consent to send commercial electronic messages, to contact you by e-mail, phone, SMS or mail to offer coupons, discounts, and special promotions taking into account your communication preferences and to learn your opinions with surveys or questionnaires.
  • If you give consent to send commercial electronic messages, to offer targeted marketing, service updates and marketing and promotional offers based on your communication preferences.
  • Measure the performance of our marketing campaigns through e-mail using methods such as analyzing e-mail opening and clicking rates.
  • Measure the performance of our seller members in a variety of ways.
  • Monitor and improve the information security of the Platform and our mobile applications.
  • Ensure that you see advertisements related to our Platform and Services on third-party websites

We can also use your personal data if you give your express consent. Our activities within this framework include the following transactions:
  • Provide offers and deals on available campaigns on behalf of Mindosphere Inc. or Mindturtle licensed company members,
  • Enable marketing activities by third parties.
  • Enable you to see advertisements about third parties especially for you on third party websites.
  • Precisely locate your geographic location to provide location-based services.
  • Use your special quality data in order to perform transactions in certain categories.
  • Use systems that automatically analyze your data. However, we do not use these systems to make decisions that may have a significant impact on you, provided that we are required by law, we expressly give consent, or we need to use it for the enforcement of an agreement we have made with you.
In cases where you have given your explicit consent, you can revoke your explicit consent at any time.

4. Your Choices Regarding the Use of Your Personal Data

You can choose from your Settings page to contact you or to inform you about marketing.
4.1. Notifications

You can manage your notification options regarding your account, shares, purchase or sale activities and your communication preferences with other members on your Settings page.


If you do not want to receive marketing communications from us, you can change your preferences in your Settings page even if you approve sending commercial electronic messages to you. We would like to remind you that we do not share your personal data with third parties for their own marketing purposes without your explicit consent.
4.3. Ads

If you give consent to sending commercial electronic messages but you do not want to take advantage of our personalized advertising services, you can contact us and change your approval status. This will prevent you from continuing to receive personalized advertising, but it will not prevent us from continuing to process your personal data regarding other issues specified in our Privacy and Personal Data Protection Policy. We would like to remind you that we do not allow your personal data to be tracked and collected by third parties for our own advertising purposes through our Platform unless you have your express consent.

4.4. Sign in

When you sign in to your account, your account remains open for a certain period of time. If you use a public or shared computer, we recommend that you do not leave your session open. During your session, you will be able to view, access, and take action on your account without any other permission. Other users of the computers/browsers you are logged into will be able to do these operations as long as you are signed in. Transaction and account activities that may be performed by you or other users of these computers/browsers include, but are not limited to, the following transactions:
  • Complete the proposal and payment process
  • View payment information,
  • View the profile page,
  • View and edit the "MindList" and “MyOffice”,
  • View and change settings page,
  • Send a message to other members,
  • Make a review
  • Engage in post-sales activities such as stopping, canceling, or requesting a refund.
You can end your session by closing the session and / or clearing your cookies. If your browser privacy settings are properly enabled, your session will be terminated only by closing your browser. If you use a public or shared computer, you must sign out and / or clear cookies by following the instructions provided in the "help" file of your internet browser to protect your account and personal information when you are using our Services.

5. Control and Correction of Your Personal Data with Access to Your Personal Data

We take appropriate measures, including the following, to ensure that the personal data we collect is accurate and up-to-date, accessed, and corrected as necessary. In case your personal data changes or is not correct, we ask you to update.

We respect your legal rights regarding access to your personal data, modification, or deletion of your personal data. In order to exercise your rights regarding your personal data, you can contact via our Contact us page. When you have made a request regarding access to your personal data or the modification or deletion of your personal data based on your rights set forth in the law, your request will finalize within 30 days at the latest after conditions of personal data processing are completely extinguished. In case that all of the personal data processing conditions are not eliminated, we may disable your right to access or not comply with your request for replacement or deletion with the justifications in accordance with the legislation in force.
In cases where you request the partial or complete termination of your personal data or withdraw your consent, we may not be able to offer our Services or customer support as specified in the Privacy and Personal Data Protection Policy and Terms of Use.

Upon your request, we will close your account and terminate the display of your account activity and personal data as soon as reasonably possible in accordance with the applicable legislation.

If you choose to close your Mindturtle account, your personal data will not be visible to others within 24 hours on our Services. We will delete closed account information within 30 days of closing the account.

We keep your personal data to fulfill our legal obligations (including legal sanction requests), to meet legal requirements, to resolve disputes, to ensure security, to prevent fraud and abuse, and to enforce our Terms of Use, even after closing your account. We will keep your non-personal information after your account is closed.

The information you’ve shared with others (for example, messages, reviews, blog, or discussion posts) will remain visible to them after you close your account or delete the information from your own profile or message box. We do not control the data that other members have copied out of our Services. Groups content and ratings or review content associated with closed accounts will show an unknown user as the source. Your profile may continue to appear in other services (e.g. search engines) until you update its caches.

6. Duration of Processing Your Personal Data

Your personal data will be processed if there is a period foreseen for the storage of this data in the GDPR, CCPA, KVKK, or other relevant legislation, or if it is not determined in this way, for the period required for processing purposes. In the event that the relevant periods expire, your personal data will be deleted, destroyed or anonymized immediately or upon your request in accordance with the rules in the relevant legislation.
7. Sharing Personal Data

We may share your personal data based on the relevant provisions of the European Union General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”) and legal reasons foreseen in the Article 5(2)(a) of the Personal Data Protection Law no.6698 (“KVKK”) it is expressly provided for by the laws.”, Article 5(2)(c) “necessity to the establishment or performance of the contract”, Article (5)(2)(ç) “necessity for compliance with a legal obligation to which the data controller is subject” and Article 5(2)(f) “necessity of the data processing for the legitimate interests pursued by the data controller” with the persons listed below for the following purposes.

Mindosphere Inc. or Mindturtle licensed company members, subject to the following objectives and subject to the terms of the relevant legislation.
  • Provide content and services such as registration, transaction, and customer support.
  • Help detect and prevent suspicious transactions, illegal transactions, violations of our Terms of Use, and data security violations that constitute fraud or fraud.
  • Serve to you personalized and more relevant ads.
  • Guide decisions about Products, Platform, applications, Services, and marketing communications
  • Mindosphere Inc. or Mindturtle licensed company members will use your personal data to send you marketing communications about a product, marketing, advertising, etc. only if you have given their consent for communication to the relevant group company or the relevant platform.
7.2. Service providers and financial institution partners
  • Your data may be shared with our third-party service providers at local or abroad to assist us with preventing, detecting, minimizing and investigating transactions that may be illegal, violations of our Terms of Use, and/or security violations and/or security violations, member and reward programs, co-branded credit cards, personal ad presentation, payment processing services delivery, and other business operations.
  • Your data may also be shared with third-party financial institutions that can offer you financial products to provide common content and services such as registration, transaction, and customer support. These third-party financial institution partners will be able to use your personal data to send you marketing communications only if you have requested and approved their services.
  • Your data may be shared with third-party websites, applications, services, and tool providers with whom we collaborate to publish and advertise your products and their content on their websites or applications, services, and tools. If we will share your personal data, together with the content of the products you offer for sale, with these third-party service providers, this sharing will only limit third-party service providers' processing activities to the extent necessary to perform their contractual obligations with us and require them to take necessary security measures for relevant data. will be carried out on the basis of. In such a case, third-party service providers are not permitted to sell, rent, or otherwise transfer your personal data that they receive with the products you are selling.
7.3. Law enforcement, legal proceedings, officials and legal authorities
  • We may share to comply with legal requirements, to enforce our Terms of Use, to interfere with allegations that any content infringes the rights of others, or to protect the rights or safety of anyone.
  • Data may be shared with law enforcement or government agencies or authorized third parties in response to a verified request regarding the criminal investigation or suspected illegal activities and other activities that may expose us, you, or any other user, to legal liability. In this context, we will only disclose information that we think is relevant to the investigation or related review, such as name, city, zip code, phone number, email address, user ID history, IP address, complaints of fraud, shopping history, and listing history.
  • Accepting the necessary commitments and contracts to the participants (right holders) of the program within the scope of the Rights Holders Protection Program, whenever we deem necessary to prevent or stop the investigation of suspicious transactions, intellectual or industrial rights violations, confidentiality or other unlawful transactions. we can share the information of the relevant users (city, postal code, phone number, e-mail address, user identity history, IP address)
  • We may share personal data with third-parties involved in legal proceedings if a subpoena, court order, or substantially similar decision exists, or if we believe it is necessary for good faith to prevent possible physical harm or financial loss or report a suspected illegal activity.
  • We would like to remind you that we are obliged to share your personal data with the envisaged authorities in accordance with the legal regulations in force, especially in the Law No. 5651 on the Arrangement of Broadcasts on the Internet and the Fight against Crimes Committed Through These Publications.
7.4. Other Mindosphere Inc. or Mindturtle licensed company users that you authorize directly or through our Services
  • When you make transactions with other users at local or abroad, your name, account number, e-mail address, contact information, shipping, and billing address are required for the delivery, invoicing of the products you buy/sell from our Platform, and to support the reliability and security of the transaction when necessary. The information required to complete transactions such as your information will be requested by other users. In such cases, we transmit the information to be transmitted on our platform to other users only in relation to the aforementioned purposes and limited.
  • In the event that any transaction is blocked, failed, or subsequently overridden, we may share details of the failed transactions with other users.
  • Other users who receive your information are not permitted to use this information for non-transactional purposes, such as contacting you for marketing purposes, without your explicit consent.
  • Contacting users with unwanted or threatening messages constitutes a violation of our Terms of Use.
7.5. Data and IT companies, server hosting service providers, data centers, cloud platforms where services are provided or cooperated

The information that your browser automatically transfers to us in our server log files is also stored by us. These are browser type/version, operating system used, referrer URL (the previous page visited), hostname (IP address) of the computer making access, time of the server query. These data are not stored in association with the person. At the same time, this data is not combined with other data sources. Your IP address will be deleted immediately after your visit.

8. Changes

If we merge with or acquire any other company, we may share information with these companies in accordance with our global privacy standards. In such a case, we will require that the merged new legal entity complies with this Privacy and Personal Data Protection Policy regarding your personal data. If your personal data is collected, used, disclosed or stored for any purpose not covered by this Privacy and Personal Data Protection Policy, you will be informed in advance of the processing of your personal data for new purposes.

9. Third-Party Privacy Practices

This Policy concerns the use of personal data we collect from you only by us. If you share your personal data with others or are directed to third party websites, their privacy policies and practices will apply.

If you share your personal data with third parties, we cannot guarantee the privacy and security of your personal data, and we recommend that you evaluate the privacy and security policies of the person you share before taking any action and sharing your personal data. This also applies if third parties to whom you share your personal data are members, buyers, or sellers on our Platform.

10. Unsolicited or Threatening Emails and SMS

We do not tolerate abuse of our Services. You do not have permission to add themselves to the list of e-mails or mailing addresses, to search for commercial purposes, or to send SMS to them without their explicit consent, even if users have purchased products from you. Sending unsolicited or threatening e-mails and SMS is against our Terms of Use. You can report spam or fake emails and SMS senders about Mindturtle by contacting Customer Service.

11. Your Rights

Within the framework of KVKK, GDPR, CCPA and other relevant international legislation in force, regarding the data we collect, your rights are as below;
  • Learn whether it is processed or not,
  • Request information about these, if processed,
  • Learn the purpose of processing and whether it is used in accordance with its purpose,
  • Know who they are, if shared with third parties at home or abroad,
  • Request correction in case of incomplete or incorrect processing,
  • Request the erasure or destruction of your processed data in case the reasons requiring its processing disappear,
  • Request that the transactions be notified to the third parties to whom the personal data is transferred if your data is deleted or corrected upon your request,
  • Object to the emergence of a result against you, when analyzed exclusively through automated systems,
  • Request the compensation of the damage if you suffer damage due to illegal processing.

12. Data Controllers and Contact Information
For Users in Turkey:

ude Kurumsal ve Bireysel Gelişim Hizmetleri Ulus.Tic.Ltd.Şti
Nidakule Göztepe, Merdivenköy Mh. Bora Sk. No:1 Kat:7 Kadıköy İstanbul
For the United States and unlicensed countries:
Mindosphere Inc.
16520 Bake Parkway, Suite 230 Irvine, CA 92618 

If you have questions or complaints about this Privacy and Personal Data Protection Policy or want to exercise your rights, you can contact us on our Contact us page. You can also reach us via physical mail by writing the “Information Request under the Legislations on Protection of Personal Data” on the envelope and sent it to "Nidakule Göztepe, Merdivenköy Mh. Bora Sk. No:1 Kat:7 Kadıköy İstanbul".

You can visit our Corporate Information page to access the information of Mindosphere Inc. and licensed companies.