1. Data Controller
Pemt Teknoloji Yazılım Limited Şirketi acts as the Data Controller for personal data processed through the Chucca platform.
2. Personal Data We Process
Depending on how Chucca is used, we may process:
- Phone number
- Membership records
- Loyalty program activity
- Point earning and redemption records
- Campaign participation records
- Transaction records
- Consent records
- Communication preferences
- Customer support requests
- Technical system logs
3. Why We Process Personal Data
Personal data may be processed to:
- Create and manage memberships
- Operate loyalty programs
- Process point transactions
- Manage campaigns and rewards
- Provide customer support
- Improve service quality
- Maintain platform security
- Comply with legal obligations
4. How We Collect Personal Data
Personal data may be collected through:
- QR code interactions
- WhatsApp communications
- Customer support channels
- Digital platforms
- Electronic communication systems
5. Sharing of Personal Data
Personal data may be shared with:
- Technology infrastructure providers
- Cloud service providers
- Messaging and communication service providers
- Customer support providers
- Technical service providers
- Legally authorized public authorities
Merchants and Merchant Group administrators do not have direct access to Members' personal data.
Merchants may only access aggregated, anonymized, or statistical information required to operate loyalty programs.
Where shared point redemption is enabled within a Merchant Group, limited information necessary for processing loyalty transactions may be processed by the system.
6. International Data Transfers
Some technology, communication, and infrastructure service providers used by Chucca may be located outside Türkiye.
Accordingly, personal data may be transferred internationally in compliance with applicable legislation and appropriate security measures.
Additional information regarding international data transfers may be provided through separate disclosure and consent documents.
7. Data Retention
Personal data is retained for the period required by applicable law or for as long as necessary to fulfill the purposes described in this Policy.
Upon expiration of the applicable retention period, personal data is securely deleted, destroyed, or anonymized.
8. Your Rights
Users may have rights under applicable data protection laws, including the right to:
- Request information regarding personal data processing
- Request correction of inaccurate data
- Request deletion where applicable
- Object to certain processing activities
- Request information regarding data transfers
Users located in Türkiye may exercise their rights under Article 11 of KVKK.
9. Security Measures
Chucca implements reasonable technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure.
10. Changes to This Privacy Policy
This Privacy Policy may be updated from time to time.
Updated versions become effective upon publication.
11. Contact
contact@pemttechnology.com