PRIVACY POLICY

Last modified August 25th, 2023

INTRODUCTION

Somera Sosyal Medya Araştırma Ölçümleme ve Analiz AŞ is committed to protecting the privacy of all individuals who:

- visit Somera's website located at somera.com.tr which includes all subdomains, present and future (the "Website" or the "Site");

- use the system that Somera makes available from time to time (the "Dashboard" or the "Application").

- to make this policy easier to read, we call the Website and the Dashboard, "Services".

Somera'­s Privacy Policy is designed to assist you in understanding how we collect, use and safeguard the information you provide to us and in making informed decisions when using our Website. This Privacy Policy will be continuously reviewed as new technologies and business methods .

It is Somera's policy to respect your privacy and the privacy of all users of the Services. This Privacy Policy has been established to help you understand our commitment to protecting your privacy and personal data, and the steps we take to ensure it. By visiting and/or using any of the Services, you agree to be bound by the terms of the present Privacy Policy (the "Privacy Policy"). Where the present Privacy Policy refers to "Somera", it may refer to the Services or to Somera Sosyal Medya Araştırma Ölçümleme ve Analiz AŞ, depending on the context.

Somera reserves the right, at any time, to modify or replace the Privacy Policy. The most recent version of the Privacy Policy is available at https://policy.somera.com.tr/privacypolicy. Please check the Privacy Policy periodically for changes, though we will also notify you via email or other direct electronic communication method of any changes that, in our sole discretion, materially impact your use of the Services or the treatment of your Personal Information. Your use of the Services following the posting of any changes to the Privacy Policy constitutes acceptance of those changes. By using the Site, you signify your agreement to our Privacy Policy. If you disagree with this Privacy Policy, please do not use our Site. Your continued use of this Site following posting of changes to these terms will mean you accept those changes.

By using this Site, you consent to the processing of data about you in the manner and for the purposes set out in this Privacy Policy and also this Privacy Policy, located in https://policy.somera.com.tr/privacypolicy

Somera's Privacy Policy forms part of its wider Terms of Service. If you are a visitor to the Website or if you are a user of Somera's services, these terms of service are available at http://policy.somera.com.tr/termsofservice . Both the Terms of Service and Privacy Policy apply to your use of the Services.

ABOUT THIS PRIVACY POLICY

This Privacy Policy covers the treatment of personally identifiable information ("Personal Information") and other non-identifiable information gathered by Somera when you are using or accessing the Services.

This Privacy Policy is in compliance with the practices of any third-party services such as Google (https://policies.google.com/privacy?hl=en-US), Facebook (https://www.facebook.com/policy.php), Twitter (https://twitter.com/en/privacy) or LinkedIn (https://www.linkedin.com/legal/privacy-policy) that you elect to use through the Somera Services.

PERSONAL INFORMATION WE MAY COLLECT AND USE

i) Registration and Logged-in Users

When you first register for a Somera app we collect some personal information about you such as:

- your email address

- social network account username

- social network account access tokens

As a registered user of Somera's Services, we may also collect the following:

- information you post in the form of messages, conversations, or contributions to discussions exchanged over the Supported Platforms

- information we may receive relating to communications you send us, such as queries or comments concerning our Services

Somera uses the collected information for the following general purposes:

- to identify you when you log in to your account

- to enable us to provide the Services to you

- to verify transactions you make and for billing, security, and authentication (including security tokens for communication with installed Third-Party Apps)

- to analyze the Website, or the other Services and information about our visitors, including research into our user demographics and user behaviour in order to improve our content and Services

- to contact you about your account and provide support

- to keep you informed of information about our Services we think you may find useful or which you have requested from us, provided you have indicated you would like to be contacted for these purposes

By submitting information to Somera when registering, you consent to the use of your information for these purposes.

ii) Collection of Personal Information Submitted Voluntarily

For Somera Services users only, Somera may gather Personal Information about organizational representatives via various methods (phone, email, online forms, in-person meetings) but only if such Personal Information is submitted voluntarily. Somera may use such Personal Information for sales, marketing, and support of the Services. This Personal Information is never shared with third parties.

SYSTEM AND DEVICE INFORMATION

Somera automatically collects and receives certain information from your computer or mobile device, including the activities you perform on our Website, the Services, the type of hardware and software you are using (for example, your operating system or browser), and information obtained from cookies (see "Cookies and Related Technologies" below). For example, each time you visit the Website or otherwise use the Services, we automatically collect your IP address, browser and device type, access times, the web page from which you came, the regions from which you navigate the web page, and the web page(s) you access (as applicable) (collectively referred to as "traffic data"). We may use this data to improve the features and usability of our Services, and better understand and market to our customers and website users.

Somera also makes use of non-identifiable information gathered for statistical purposes to keep track of the number of visits to the Services and Website pages with a view to introducing improvements and improve usability of our Services. Your IP address and other relevant non-identifiable information may be used in order to trace any fraudulent or criminal activity or any activity in violation of the Terms.

COOKIES AND RELATED TECHNOLOGIES

Somera uses tracking technology ("cookies") on the Website, in the Applications, and in the Platforms, including mobile application identifiers and a unique Somera user ID to help us recognize you across different Services, to monitor usage and web traffic routing for the Services, and to customize and improve the Services. By visiting the Website or using the Services you agree to the use of cookies in your browser and HTML-based emails. Cookies are small text files placed on your device when you visit a web site, in order to track use of the site and to improve your user experience.

By using cookie technology, Somera may track and collect information about your computer and software when you visit this Site. This information may include your IP address; server; type of computer; type of web browser; access times; and referring websites addresses.

In order for you to access certain portions of our Site, we may require you to provide us with information that personally identifies you, such as your name, mailing address, email address and home and/or business telephone numbers ("Personal Information").

You may choose not to provide us with any Personal Information. In such an event, you can still access and use much of the Site. You, however, will not be able to access or use those portions of the Site that require your Personal Information.

Session Cookies

The Services use "session cookies", which improve your user experience by storing certain information from your current visit on your device, such as log-in information. These enable us to remember your log-in session so you can move easily within the Website or the other Services. Without these session cookies, we wouldn't be able to provide the Services to you. These session cookies have limited functionalities and expirations, and you may be required to re-enter your Somera log-in information after a certain period of time has elapsed to protect you against others accidentally accessing your account contents and related Personal Information.

Performance Cookies

We use the following service to discover usage patterns of users on our web site and services.

Google Analytics

Somera uses a specific cookie in order to facilitate the use of Google Universal Analytics for users logged-in to the Applications or the Platforms ("Logged-In User"). If you are a Logged-In User, Somera may use your Somera user ID in combination with Google Universal Analytics and Google Analytics to track and analyze the pages of the Services you visit. We do this only to better understand how you use the Website and the other Services, with a view to offering improvements for all Somera users; and to tailor our business and marketing activities accordingly, both generally and specifically to you. Google Analytics cookies do not provide Somera with any Personal Information.

Learn more about privacy at Google and to opt-out of this feature by installing the Google Analytics Opt-out Browser Add-on.

Most computer and some mobile web browsers automatically accept cookies, but if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. The Network Advertising Initiative has also developed a tool that may help you understand which third parties have currently enabled cookies for your browser and opt-out of those cookies. Further information can be found at http://www.networkadvertising.org. Please note however that, by blocking or deleting cookies, you may not be able to take full advantage of the Website, Applications and/or Platforms. If you do not want to receive tracking pixels, you will need to disable HTML images in your email client, and that may affect your ability to view images in other emails that you receive.

Somera may also use web beacons and customized links and/or similar technologies to determine whether electronic newsletters sent by us to those who have requested them from us have been opened and which links are clicked. Any data collected will only be used in optimization and will not contain any Personal Information, as that term is defined below.

LINKS

This Site may contain links to third-party websites. These links are provided solely as a convenience to you. They are not an endorsement by Somera of the contents on such third-party websites. Somera is not responsible for the privacy practices or content of linked third-party sites and does not make any warranty or representation regarding the content or accuracy of materials on such sites. Nor does Somera make any warranty or representation regarding, nor does it endorse, any linked third-party websites or the information appearing thereon or any of the products or services described thereon. If you decide to access linked third-party websites, you do so at your own risk.

WHEN WE MAY SHARE PERSONAL INFORMATION

Except as provided in the next paragraphs and elsewhere in this Privacy Policy, Somera does not divulge any Personal Information gathered via the Services to third parties.

Notwithstanding anything in the Privacy Policy to the contrary, we may share any information we have collected about you or that you have submitted:

(01) when you explicitly consent to the disclosure of such information to a third party when connecting to a third-party service that asks you if you consent to such sharing;

(02) where we are legally required to do so, such as in response to court orders or legal process, or to establish, protect, or exercise our legal rights or to defend against legal claims or demands;

(03) if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person;

(04) if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Services infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of the Website infrastructure or the Services generally);

(05) to a parent company, subsidiaries, joint ventures, or other companies under common control with Somera;

(06) if we are acquired by or merged with another entity (in which case we will require such entity to assume our obligations under this Privacy Policy or inform you that you are covered by a new privacy policy);

(07) if we need to protect our rights or property;

(08) when we provide you the products and/or information that you may have requested;

(09) if we need to enforce our rights;

(10) if we believe it is necessary to protect the interest of users of the Site, other than you, or any other person;

(11) if we need to operate or conduct maintenance and repair of our equipment;

(12) if we need to detect, prevent and/or otherwise address fraud, security or technical issues, as authorized by law.

Subject to obligations consistent with this Privacy Policy, we may also disclose information to our affiliates, agents, contractors, and service providers in order to facilitate the functioning of the Services or to perform tasks that are integral to the Services, such as processing transactions, fulfilling requests for information, or providing support services or other tasks, from time to time. Information may also be transferred from Somera to the third parties in control of the Supported Platforms, but only to the extent required in order for the Services to function properly.

We may share Personal Information with third parties that provide services to Somera (including handling and delivering of email communications and newsletter, and website hosting services) as reasonably necessary for them to provide said services. Service providers of Somera who have (or will have) access to Personal Information, however, are (or will be) required to protect this information in a manner that is consistent with this Privacy Policy and not to use it for any purpose other than to carry out the services they are performing for Somera.

We may use Traffic Data to analyze trends, administer the Site, track user'­s movement, and gather broad demographic information for aggregate use.

We may provide Traffic Data and/or other aggregate non-personally identifying information to third parties.

Notwithstanding the foregoing, we may transfer, sell or assign information concerning this Site and your use of this Site, including without limitation, Personal Information, to third parties, as a result of the sale, merger, consolidation, change in control, transfer of substantial assets, reorganization or liquidation of Somera.

CHILDREN

Protecting the safety of children when they use the Internet is very important to us. Our Services should only be accessed by individuals of 18 years of age and older. However, if applicable law requires that you must be older than such ages in order for Somera to lawfully provide the Services to you (including the collection, storage, and use of your information in accordance with this Privacy Policy), then these Services are not designed nor intended for use by you.

SECURITY

The Site has security measures in place intended to protect the loss, misuse and alteration of the information under our control. We will take reasonable steps to safeguard Personal Information, in case the information gathered is from unauthorized access or disclosure and accidental loss or alteration.

We use industry best practices to keep any information collected and/or transmitted to the Supported Platforms or Third-Party Apps secure. This includes the use of HTTPS with TLS (Transport Layer Security), which encrypts all transmitted data, and OAuth 2.0 protocols for authentication and data transfer to Supported Platforms and Apps.

Certain Personal Information, most notably Somera log-in details, is encrypted during transmission using TLS. Once validated within our system, passwords are deleted from our system.

You should bear in mind that submission of information over the Internet is never entirely secure. We cannot guarantee the security of information you submit via the Services whilst it is in transit over the Internet and any such submission is at your own risk, and this risk is specifically disclaimed in our Terms of Service.

If you are a Logged-in User, it is advisable that you log out of your account at the end of every session and not leave a logged-in account unattended for any period of time, particularly if you use a shared computer or device.

INFORMATION STORAGE AND INTERNATIONAL TRANSFERS

Somera aligns itself with the Safe Harbor privacy principles which is in accordance with the Law on the Protection of Personal Data, no. 6698 of Turkish Penal Code regarding the collection, storage, use, transfer and other processing of Personal Data. The information that you submit via the Services is hosted on secure servers and complies with international legal norms regarding the collection, storage, use, transfer and other processing of Personal Data.

DELETION REQUEST

If you choose to cancel your account, you are solely responsible for doing so properly. The current account cancellation procedure is as follows: (a) you must log in to the Service and follow the menu to "Profile" then "Account"; then (b) you must click the "Delete Account" button. You can also disconnect your social accounts from respective applications by revoking Somera Application access. For further assistance, see instructions at http://policy.somera.com.tr/deletionrequest 

Your cancellation will take effect immediately and Somera will delete all of your Content from the Services reasonably promptly after cancellation. Once you cancel your account, your Content cannot be recovered.

Somera does not accept any responsibility for loss of Content due to account cancellation.

EMAIL PREFERENCES

Somera uses email as the primary mode of communications with our users. We want to respect your privacy by only sending emails of interest to you. You may opt out or unsubscribe from any future email communications from within a link provided in each email correspondence that we send you. Also, if you do not wish to receive information or other material from us, you may 'opt-out' of receiving these communications by simply letting us know by emailing us via deletion-request@somera.com.tr 

YOUR RIGHTS

You can contact us to obtain a copy of the Personal Information held about you by us. You can also ask us to correct or erase that information. Please note that certain Personal Information may need to be retained by Somera for a period of time following cancellation of your account where this is necessary for our legitimate business purposes (e.g. billing, invoices, receipts, etc.) or required or authorized by applicable law. Any requests to obtain your personal information, or to correct or erase your information, or questions and complaints about privacy, should be made by a direct contact with Somera via email (info@somera.com.tr).

You should also be aware that Somera acts as a conduit between our users and the various Supported Platforms and Third-Party APIs. In several instances, the content published via Somera will not be in Somera's custody or control, and any content that has been shared by you through any Supported Platform or Third-Party API via the Services may continue to be available to third parties and the public at large, as this content is now under the control of the operators of the Supported Platforms and/or the Third-Party APIs. You should also be aware that you can revoke the Third-Party API permissions given to Somera Services via the Third-Parties appropriate pages

Twitter https://twitter.com/settings/applications

Facebook https://www.facebook.com/settings?tab=applications

Google & YouTube https://security.google.com/settings/security/permissions 

LinkedIn https://www.linkedin.com/mypreferences/d/data-sharing-for-permitted-services 

CONTACT

If you have any questions regarding Privacy Policy or about the Site security, you can send an email at info@somera.com.tr