Privacy Policy

Updated on: 22/01/01

Your privacy is important to us. Xolvie (the "Site") has created this Privacy Policy to explain how your information is protected, collected, and used. This Privacy Policy may be updated from time to time. You can always review the most current version here.

By using the Site, you consent to the terms and conditions of this Privacy Policy and are aware that our policies may evolve in the future. If there is a conflict between our Terms of Use governing your use of the Site and this Privacy Policy, the Terms of Use control.

Here at Xolvie, we believe strongly in openness and trust. The more we trust each other by being open and honest, the more we all can benefit from our collective experiences. We hope this is reflected in our Privacy Policy below. We also believe our users are entitled to be in control of their Personal Data (as defined below).

When you open a Case on Xolvie or otherwise use our Site, we collect and process personal data about you. This document helps you understand what personal information we collect about you, how we collect it, what we use it for, and what rights you have regarding your personal data.

When we talk about “Xolvie,” “we,” “us” or “our,” we mean Xolvie (Xolvie.com) and our affiliates. We also use “Policy” to refer to this Privacy Policy and “Site” to refer to our applications and all of Xolvie’s websites.

Xolvie is the entity responsible for processing your personal data. Please follow the information on what we collect and what we use it for in the terms below.

1. Personal Data

For the purpose of this Privacy Policy, "Personal Data" means any information relating to an identified or identifiable natural person (or household as applicable); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.


1.1. Master Data

When you create a profile or open your first Case on the Site, we will automatically generate a personal account for you on Xolvie (“Account”) and collect the following personal data about you (the “Master Data”):

• Your username, which is usually your email address,

• Your name (this will be public) and family name

• Your Transaction Security Information: IP address information, password and your securely encrypted password, cookie information,

• Phone number, which is usually the fastest way to resolve a case

• Other information provided by the login method you choose.

This information is mandatory, so it will not be possible to start a Case on the Site without it.

You can choose to add further personal data to your profile, some of which may help us resolve your complaints with different businesses, and to get your refunds to you more quickly. This additional information will be part of your public profile and will also be part of the Master Data.

1.2. Information in Your Case

When you open a Case on our Site, we collect the information you put in your Case. This includes:

• Which company/companies is involved

• The type of buying or service concerns or issues you had

• The headline and content of your Case

• Your rating of the resolution of your Case with the company (1-5 stars)

• Your answer to the question: “Would you do business again with this company”

• The date of your Case and its resolution

• A reference number or Case ID (if you or the company provides one)

• Audio Data: Call center call recordings.

If we ask you to provide information or documentation verifying your Service Experience and you send us such documentation, we will collect and process the documentation for the purpose(s) stated in the request.

We may find it necessary to add to the information collected in order to improve your experience, the resolution time, or other aspects of the Site’s operations. Please don’t share any unnecessary sensitive personal documents or information with us, either concerning yourself or others.


1.3. Information about Views, Likes And How Useful Your Case Is For Others

When you start a Case on our Site, people can show that they find the progress or resolution of your Case useful, and we collect this information. We also collect information about how many people followed your Case. We don’t track the identities of people who aren’t logged in and look at the Cases, but we do collect data on the number of consumers and companies who follow your Case. If you follow another person’s Case we will also collect that information.


1.4. Notifications

If you notify us about a Case that you believe violates our User Guidelines, then we collect the information you provide in your notification to us. This can include which Case you notified us about, the reason for your notification, the date of your notification, etc.


1.5. Information from Other Services, Including Social Networks

You can connect your Xolvie profile with your profile on Social Networks, in particular Facebook, and/or Google account and it makes it easier for us to contact you quickly about your Case. When you use this option, we automatically collect selected information about you from your Social Networks. The information we collect depends on what information you have made available on those Social Networks and your privacy settings for sharing such information on Social Networks. Depending on your settings and selection, we will collect the information needed to resolve your Case as quickly and as completely as possible.

When you request to connect your Xolvie profile with a Social Network profile, we will do our best to inform you about which information we will collect from the Social Network in question. We can’t promise this will happen in every case, as this feature comes from the given Social Network, and we may not be able to provide you with that information all the time. You will receive this information before your request is carried out. You can choose to disconnect your Social Network profile from your Xolvie profile via your Social Media Account. At this point, Xolvie will remove your Social Network unique ID and disconnect/revoke Xolvie from your Social Network. Your profile picture from your Social Network profile will remain on your Xolvie profile.


1.6. Cookies

Like many websites, Xolvie uses a standard technology called "cookies." A cookie is a small text file stored on your computer's hard drive that a specific website can access to make your experience quicker and more convenient. Cookies allow our users to log in without entering their ID and password when they use Xolvie. Cookies also help us understand how our users use the Site, which allows us to improve the service. We do not use cookies to retrieve any information from your computer other than the information we provide, such as a user code.


1.7. Your IP Address, Browser Settings, and Location

When you visit the Site, we register your computer’s IP address and browser settings. The IP address is the numerical address of the computer used to visit the Site. Browser settings can include the type of browser you use, browser language, and time zone. We collect this information so that we can trace the computer used in cases of misuse or unlawful actions in connection with visits to or use of the Site. We also use the IP address to approximate your location (at city level) so that we know which sets of our Terms & Conditions apply to your use of our Site.


1.8. Newsletters and Digest Emails

We collect the information you provide us with when you receive our newsletters, digest emails, or similar (we collect your name, email address, and newsletter preferences). If you no longer wish to receive our newsletters, digest emails, or similar, you can unsubscribe by logging into your Account and changing your settings.


1.9. For What Purposes Do We Use Your Personal Information?

We will use the information you provide to us to:

• Provide our services to you, including resolving your Case, and providing you with access to your profile and our Site

• Identify you as a registered user when you log in to the Site and re-visit the Site

• Verify the details of your Case

• Improve the Site and our services

• Invite you to initiate more Cases

• Respond to your questions and provide related customer service

• Pass on messages from the company in your Case

• Contact you if there are questions about your Case from other users or companies and, if necessary, ask you to provide documentation to verify your experience

• Send you our newsletters

• Inform you when other users follow the progress of your Case or otherwise provide feedback

• Facilitate the social sharing function, including giving you the option to connect with members of your network who are both users of Xolvie and users of one or more Social Networks

• Display which members of your Social Networks are users of Xolvie to increase confidence in our process and to create a better user experience on our Site

• Engage in various internal business purposes, i.e. data analysis, audits, fraud monitoring, and prevention, developing new products and services, improving or modifying the Site, or our services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities

• Comply with legal requirements and legal process, requests from public and governmental authorities, relevant industry standards, and our internal policies

• Enforce our Terms & Conditions

• Protect our operations or those of any of our affiliates

• Protect our rights, privacy, safety or property and/or that of our affiliates, you, or others

• Allow us to pursue available remedies or limit any damages that we sustain

We will also use the information in other ways for which we provide specific notice at the time of collection.


2. Disclosure of Personal Information

2.1. Disclosure of Personal Information on the Site

We are an open platform, and we share your Case on our Site so that others can read about your experience with a specific company. When you open a Case, we will disclose your Case, your real name (only the first name as provided by you), your profile photo on the Social Network you have used for login, and other information you have chosen to connect with your public profile. Remember that because part of our credibility is based on real solutions to real Cases for real people, the information disclosed about your Case can reveal your identity in full or in part. We recommend that you exercise care in deciding which information to make available for disclosing on the Site, and be aware that depending on the level of information provided, you may or may not be anonymous.

Master Data and other information When you post a Case on our Site and create an Account, your name, Case(s), photo, location, and the number of Cases you have opened may be visible on the Site. The companies in your Cases will also receive information about the Case. Geo-location When you open a Case on the Site, we use your computer’s IP address (see 1.7 of this Policy, above) to approximate your location to the nearest city. This information may be made available to other users of the Site.

Cases you found useful When you see other Cases that are important to you, other users of our Site can see that you found those Cases useful and can see your likes, comments, upvotes, flags, and any other indication of your views.

Social Networks If you connect to a Social Network, information such as your profile photo, your name, birth year, and approximate location will be collected from your Social Network profile and used to identify you on the Site. Subject to your privacy settings and the level of information available from the Social Network, users of the Site can use this information to identify which Cases you have initiated. If your contacts or friends (referred to as “Connections”) on the Social Network have also connected with Xolvie, may be displayed on the Site how you are connected to these Connections through the Social Network. This is only visible to you. Other people on Xolvie cannot see your Connections from Social Networks.


2.2. Disclosure on Services to Which You Connect Your Profile

If you choose to connect your Xolvie profile with your profile on a Social Network, information, and Cases initiated by you on the Site or data compiled by us about your use of the service on the Site (e.g., the number of Cases you have initiated) will be shared with and displayed in connection with your profile on the Social Network and will be subject to the privacy policy of the Social Network.


2.3. Disclosure to Other Services, Websites, and Companies

One of Xolvie's main goals is to increase the impact of Cases on the Site. We, therefore, permit other services to show Cases on the Site. This increases the potential impact of your Cases. The categories of third party services and companies who can show your Case(s) together with your public user profile are:

• Search engines, including, but limited to, Google and Bing

• Companies who have had Cases on Xolvie

• Consumer portals and business portals

Application partners and platforms

• Other similar websites where, in Xolvie’s judgment, it will be relevant for users to search for Cases.

• Facebook, particularly if your Case has been shared on it

Once you submit your Case, it is published on the Site. This means that the following information is disclosed: • Your Case(s), (see 1.2, above)

• Your name (only your first name in the format you have provided) and the additional data you choose to add to your profile, a profile description, photo, gender, city, country, and language.

If we need to verify your Case, we will contact you and ask for documentation that shows that you have had a Service Experience with the company that you have opened a Case about.


2.4. Other Disclosures

In addition to the above, we disclose your personal information to the following parties and in the following circumstances:

• To allow third-party vendors, consultants, and other service providers to perform services on our behalf

• To Xolvie subsidiaries and other companies within the Xolvie group of companies

• To comply with laws or to respond to claims, legal process (including but not limited to subpoenas and court orders), and requests from public and government authorities

• To cooperate with regulatory bodies and government authorities

• To third parties in connection with the enforcement of our Terms & Conditions and other relevant documents

• To third parties in order for us to protect our operations or those of our affiliates

• To third parties in order for us to display advertisements in line with user preferences,

• To third parties in order for us to profile, analyze, customize services, marketing, and advertising,

• To third parties in order for us to manage marketing processes,

• To third parties in order for us to pursue available remedies or limit damages that we may sustain

• To third parties in order for us to investigate, prevent or take action regarding suspected or actual prohibited activities, including but not limited to fraud and misuse of our Site

• To a third party in the event of any reorganization, merger, acquisition, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business or assets (including in connection with any bankruptcy or similar proceedings).


3. Data Controller

3.1. Information for Which We Are the Data Controller

We are the data controller of the Master Data you enter to create and maintain your profile, which includes but is not limited to your name, password, and email address, as well as the registration of your IP address. We are also the data controller of the information disclosed to other services (see 2.3). Turkey’s data protection laws govern our collection of your data.


3.2. Information for Which You Are the Data Controller

You are the data controller for the content you choose to disclose on the Site and for the personal data disclosed when you connect your Social Network profile(s) with your profile on the Site.


4. Links to Websites

Our Site contains links to other websites. Our inclusion of such links does not imply that we endorse those websites. We do not control the content of those third-party websites' content and assume no responsibility for the third party or their policies or practices. We encourage you to review the privacy policies for these third-party websites because their procedures for collecting, handling, and processing personal data will be different from ours.


5. Video Reviews

Videos submitted on Xolvie may be published to YouTube using YouTube API Services. When creating and submitting a video, you are subject to the YouTube Terms of Service. Please also refer to Google's Privacy Policy to understand how your personal information is handled and protected regarding their services.


6. Third Party Advertising

Advertisements that appear on Xolvie are sometimes delivered (or "served") directly to you by third-party advertisers. They automatically receive your IP address when this happens. These third-party advertisers may also download cookies to your computer or use other technologies such as JavaScript and "web beacons" (also known as "1x1 gifs") to measure the effectiveness of their ads and to personalize advertising content. Such activities allow the advertisers to recognize your computer each time they send you an advertisement in order to measure the effectiveness of their ads and to personalize advertising content. In this way, they may compile information about where individuals using your computer or browser saw their advertisements and determine which advertisements are clicked. Xolvie does not have access to or control of the cookies that the third-party advertisers may place. Third-party advertisers have no access to your contact information stored on Xolvie unless you choose to share it with them. This Privacy Policy covers the use of cookies by Xolvie and does not cover the use of cookies or other tracking technologies by any of its advertisers. Xolvie uses Google Analytics, Google Analytics Demographics, and Interest Reporting, Remarketing with Google Analytics, Google Display Network Impression Reporting, DoubleClick Platform integrations, and Google Ads to collect data via Google advertising cookies and anonymous identifiers, in addition to data collected through a standard Google Analytics implementation. You may be able to opt-out of some of the advertisers' practices by visiting the following links: Network Advertising Initiative, Omniture, Digital Advertising Alliance, Google Analytics, and Privacy Choice. Please note that opting out does not prevent the display of advertisements to you.


7. Data Retention

We keep the Master Data and other personal data you provide, including your Cases, for as long as you have an Account or as needed to provide you with our services. If you choose to delete your Account, please note that all your Cases may also be deleted, or the information about the person who opened the Case may be deleted, or that person may be made anonymous. We will delete this information upon your request, and we will only save a log with the following information (Turkey’s data protection laws):

Call Center voice recordings: 3 years

Membership records: 10 years

All records related to accounting and financial transactions: 10 years

Cookies: 2 years

Commercial electronic message approval records: 1 year from the date of withdrawal of the approval

Traffic information for online visitors: 2 years

In the event that these periods expire, all relevant data will be deleted, destroyed, or anonymized under the applicable legislation. If you use our Site only for searching for companies that have Cases about them, we will retain your information and keep your Account open until you decide to close your Account. In some cases, even if you close your account, we then choose to retain certain information (e.g., visits to our Site) in an anonymized or aggregated form.


8. Security Measures

We use reasonable organizational, technical, and administrative measures to protect your personal information within our organization, and we regularly audit our system for vulnerabilities. However, since the internet is not a 100% secure environment, we cannot ensure or warrant the security of the information you transmit to us. Emails sent via the Site may not be encrypted, and we, therefore, advise you not to include any confidential information in your emails to us. To learn more about our current practices and policies regarding security and other information, please get in touch with us at [email protected] We are constantly working to improve our security practices and expect to update our practices as they evolve.


9. Access and Insights into the Personal Data We Have About You

You can email [email protected] and request information about your personal data. Upon receiving your request, we will let you know what personal information we have about you, how we collect the data, the purpose for which we process your personal data, and with who we share your personal information.


10. Correction and Deletion of Your Personal Data

If any of the Master Data or other personal information that we have about you in our capacity as a data controller is incorrect or misleading, you can contact us at [email protected] to correct it. You may at any time correct or delete any content and personal information on the Site for which you are the data controller (see 3.2). If your personal information changes or you no longer wish to appear on the Site, you can update or delete information by contacting us via email: [email protected]

If your Account is deleted, all the data associated with your Account will be deleted, including your Master Data and Cases on the Site. We reserve the right to block access to your Account and/or delete it if the Account or the content associated with your Account or your Case(s) on the Site is, in our assessment, discriminating, racist, sexually-oriented, unethical, threatening, offensive, harassing or otherwise violates applicable laws, third party rights or our User Guidelines, or is inconsistent with the purpose of the Site. If we block access to or delete your Account, we will inform you of the reason for blocking or deleting your Account by sending an email to the address you provided when you created your Account.


11. Other Rights

In addition to the rights set out above concerning your personal data, you also have the following rights:

• You also have the right to object to the processing of your personal data and have the processing of your personal data restricted.

• In particular, you have an unconditional right to object to the processing of your personal data for direct marketing purposes.

• If our processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of data processing carried out before you withdraw your consent. You may withdraw your consent by emailing us at [email protected] In some circumstances, these rights may be limited or conditional. For example, whether or not you have the right to data portability in a particular case depends on the specific circumstances of the processing activity.


12. Children’s Information

12.1. Children under Age 13

Xolvie does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register. If you are under 13, please do not attempt to register for Xolvie or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 may provide any personal information to or on Xolvie. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at [email protected]

12.2. Children between the ages of 13 and 18

We recommend that minors over the age of 13 ask their parents for permission before sending any information about themselves to anyone over the Internet.


13. Our Data Protection Officer

We have a Data Protection Officer (DPO). If you have any questions about the data processing activities performed by us, you are welcome to contact our DPO by email at: [email protected]


14. Changes to This Policy

We reserve the right to make changes to this Policy. The date shown at the start of this Policy indicates when it was last revised. If we make material changes to it, we will provide notice through our Site or other means to give you the opportunity to review the changes before they come into effect. If you object to our changes, you can close your account. Your continued use of our Site after we publish or send a notice about the changes to the Policy will mean that you accept and agree to the updated Policy.


15. Contact Information and Where to Send Questions or Complaints

If you have questions or concerns about our Policy, how we process your personal information, or would like us to correct your personal information, please get in touch with us at: [email protected] You can also reach us by post. If contacting us does not resolve your complaint, you have further options; for example, you may always lodge a complaint with a data protection supervisory authority. Our contact details are:


Xolvie

Söğütözü, Yaşam Cd. No:7,

06560 Çankaya/Ankara - Turkey

+90 (312) 219 40 04

Email to: [email protected]