Privacy Policy ApuriBotti

 Thousand Lakes Software Inc. & Horizon Ecommerce Inc.

Privacy Policy and Personal Data Text


Update Date: 8th May 2023


  1. Objective

 Thousand Lakes Software Inc. (“ Thousand Lakes Software Inc.” or “Company”), aims to process the personal data of users in accordance with general principles of privacy and the provisions of the applicable data protection legislation to the relevant person, particularly Law on Personal Data Protection No. 6698, (“PDP Law”) and other applicable legislation.

Your personal data, which you provided/will provide to our Company and/or obtained by our

Company by any external means, may be processed by our Company as “Data Controller”;


  • In the context of the objective of processing your personal data and in connection with

this purpose, in a limited and measured manner,

  • By maintaining the accuracy and up-to-date version of the personal data as reported

or notified to our Company,

  • May be recorded, stored, preserved, reorganized and be transferred to the institutions

authorized to request such personal data by law and shall be transferred, classified

and shared with third parties within the country or abroad under the conditions

stipulated by legislation and upon your explicit consent if necessary, and they may be

processed by other means listed under the legislation and be subject to other

procedures set forth in the legislation.


This Privacy Policy is adopted for the continuance and improvement of the activities carried

out by  Thousand Lakes Software Inc. in line with the principles set forth in the PDP Law.

This Privacy Policy describes which data we collect, how we intend to use, store, protect and

share the data we collect, how you can withdraw your consent for the processing of these

data and how you can correct and revise the data.

Capitalized terms in this Policy shall have the meanings specified in the Terms and

Conditions unless defined separately in this Policy.

  1. Collection of Personal Data and Method

 Thousand Lakes Software Inc. may process your personal data for the purposes specified in this Privacy Policy.

The personal data of users collected and used by  Thousand Lakes Software Inc. in particular, are as follows: your

order information if you make a purchase through in-app purchase, and identifier for

advertisers designated in your mobile device used in accessing our services (The Identifier

for Advertisers-IDFA), identifier for vendors/developers designated your mobile device (The

Identifier for Vendors-IDVF) and Internet Protocol Address-IP Address.


Data Categories and Data Types

Process Security

  • Internet traffic data (network movements, IP
  • address, visit data, time and date
  • information), device name, In-app purchase
  • history, Token ID (when you allow
  • notifications through your device), identifier
  • for advertisers designated in your mobile
  • device used in accessing our services (if
  • you give a permission, the Identifier for
  • Advertisers-IDFA), identifier for
  • vendors/developers designated your mobile
  • device (The Identifier for Vendors-IDVF)

Customer Transaction

  • Order information

Marketing Data



We may collect your abovementioned data directly from you through electronic or physical

mediums, your mobile device, third party applications or third party sources which you can

access our application through these mediums such as Apple App Store, Google Play App

Store (similar platforms together with “App Stores”), for the purposes of compliance with legal obligations, enhancing  our services, administering  your use of our services, as well as

enabling you to enjoy and easily navigate our services.

We may collect your log data generated while you are using our services/applications

(through our products or third party products). This log data may include information such as

your device’s Internet Protocol (“IP”) address, device name, operating system version, the

configuration of the app when utilizing our service/application, the time/date of your use of

the service/application, and other statistics.


General Principles Regarding Personal Data Processing


In accordance with this Privacy Policy, personal data are processed by  Thousand Lakes Software Inc. as a data controller in line with the basic principles named here: (i) being in accordance with law and good faith, (ii) being accurate and, where necessary, up-to-date, (iii) being processed for specific, explicit and legitimate purposes, (iv) being limited for the purpose for which they are processed and data minimization; and (v) being stored for the period stipulated in the relevant legislation or required for the purpose for which they are processed.


  1. Purposes of Processing Personal Data and Legal Reasons


Your personal data will be processed via automatic or non-automatic means for the purposes

stated below, in accordance with the applicable legislation and articles 5 and 6 of the PDP

Law where it is expressly permitted by the laws, the establishment of a contract or direct

relation to the execution or performance of the contract and for the legitimate interests of

 Thousand Lakes Software Inc. provided that your fundamental rights and freedoms are protected.


  1. Purposes of Processing Personal Data


In accordance with this text, your personal data is processed for the following purposes in

accordance with the above general conditions:


Process Security

  • execution of activities in compliance with legislation
  • execution of company/product/service commitment


  • execution of communication activities
  • execution/auditing of business activities
  • conducting after-sales support services for goods/services
  • execution of goods/services sales processes
  • conducting storage and archive activities
  • execution of agreement processes
  • execution of information security processes
  • conducting audit/ethical activities
  • execution/audit of business activities
  • conducting activities to ensure business continuity
  • providing information to authorized persons, institutions

and organizations


Customer Transaction


  • execution/auditing of business activities
  • conducting after-sales support services for goods/services
  • execution of goods/services sales processes
  • conducting activities for customer satisfaction
  • execution of agreement processes


Marketing Data


  • conducting marketing analysis studies
  • execution of advertising/campaign/promotion processes


Besides, the purposes of processing personal data may be updated in line with our

obligations arising from our company policies and legislation; in particular,


  • Creating user accounts for the service recipients/application users,
  • Customizing our Services, understanding our users and their preferences to enhance

user experience and enjoyment using our Services and improve our users’


  • Informing about new products, services and applications and delivering you

information regarding advertisements and promotions,

  • Carrying out a digital subscription and in-app purchase processes of service


  • Carrying out the auto-renewable subscriptions for giving users access to content,

services, or premium features in our service,

  • Carrying out the processes of information security,
  • Conducting activities in accordance with legislation,
  • Fulfilling the demands of competent authorities,
  • Conducting the processes of finance and accounting transactions,
  • Conducting communication activities,
  • Conducting the processes of contracts,
  • Carrying out strategic planning activities,
  • Following up requests and complaints.
  1. b) Legal Reasons


Customer Transaction

  • It is necessary to process your personal data, provided that

we establish a contractual relationship with you, or that it

is directly related to our performance obligation arising

from this contract

  • We have to process data in order to establish a right for

you, to exercise and protect this right

Process Security

  • The law explicitly stipulates the process by which we

process your personal data

  • Conditions that are necessary in order to fulfill our legal


  • It is necessary to process your personal data, provided that

we establish a contractual relationship with you, or that it

is directly related to our performance obligation arising

from this contract

Marketing Data

  • Your explicit consent (acquired via Apple and/or Google)

Third Party Websites and Applications

APURIBOTTI App (APURIBOTTI); may contain links to other websites that are unknown to  Thousand Lakes Software Inc. and

whose content is not controlled. These linked websites may contain terms and conditions

other than  Thousand Lakes Software Inc. texts.  Thousand Lakes Software Inc. cannot be held responsible for the use or disclosure of

information that these websites may process. Likewise,  Thousand Lakes Software Inc. shall not have any

responsibility for any links from other sites provided to APURIBOTTI owned by  Thousand Lakes Software Inc..

We collect information by fair and lawful means, with your knowledge and consent. We also

let you know why we’re collecting it and how it will be used. You are free to refuse our

request for this information, with the understanding that we may be unable to provide you

with some of your desired services without it.



Cookies are little text files that are stored on the browser or hard drive of your computer or

mobile device when you visit a webpage or application.  Cookies allow a website to run more

efficiently in addition to ensuring the presentation of personalized web pages in order to

make you live a faster visit experience which is more fit for your specific personal needs and

demands. Containing only data on your website visit history via the internet, cookies do not

collect any information, including your personal data/files stored on your computer or mobile

device. We may use cookies when it is necessary for operating our services, to enhance our

service performance and functionality, and to deliver content, including ads relevant to your

interests, on our sites, or third-party sites. You can delete cookies which are already present

on your computer and prevent the recording/location of cookies on your internet explorer.

Internet browsers are predefined to automatically accept the cookies as default. As the

management of cookies varies from browser to browser, you may look at the help menu of

the browser or application to get detailed information.


Push Notifications

 Thousand Lakes Software Inc. may occasionally send you push notifications via its mobile applications regarding

application upgrades or notifications about our services. You can always edit such

communication and notifications through the settings on your device and stop receiving such

communications and notifications.


Your data will be stored for the duration specified in the applicable legislation or for a

reasonable time until the purpose of processing cease to exist, or during legal periods of


 Thousand Lakes Software Inc. may continue to store your personal data, even after the expiry of the purpose of its

use provided that it is required by other laws or a separate granted by you in this regard. 

In cases that you allow  Thousand Lakes Software Inc. to store your personal data for additional time by giving

your consent, such data shall be immediately deleted, destructed or anonymized upon the

expiry of such additional time or once the purpose of processing no longer exists.


Technical and Administrative Measures

 Thousand Lakes Software Inc. stores the personal data it processes in accordance with relevant legislation for

periods stipulated in relevant legislation or required for the purpose of processing.  Thousand Lakes Software Inc.

undertakes to take all necessary technical and administrative measures and to take the due

care to ensure the confidentiality, integrity and security of personal data. In this context, it

takes the necessary measures to prevent unlawful processing of personal data, unauthorized

access to data, unlawful disclosure, modification or destruction of data. Accordingly,

 Thousand Lakes Software Inc. takes the following technical and administrative measures regarding the personal

data it processes:

Anti-virus application. On all computers and servers in  Thousand Lakes Software Inc.  information technology

infrastructure, a periodically updated anti-virus application is installed.

Firewall. The data center and disaster recovery centers hosting  Thousand Lakes Software Inc. servers are

protected by periodically updated software-loaded firewalls; the relevant next generation

firewalls control the internet connections of all staff and provide protection against viruses

and similar threats during this control.

VPN. Suppliers can access  Thousand Lakes Software Inc. servers or systems through SSL-VPN defined on

Firewalls. A separate SSL-VPN identification has been made for each supplier; with the

identification made, the supplier only provides access to the systems that it should use or is

authorized to use.

User identifications.  Thousand Lakes Software Inc.  authorization to  Thousand Lakes Software Inc. systems is limited only

to the extent necessary by job descriptions; in case of any change of authority or duty,

systemic authorizations are also updated.

Information security threat and event management. Events that occur on  Thousand Lakes Software Inc.

servers and firewalls, are transferred to the “Information Security Threat and Event

Management” system. This system alerts the responsible staff when a security threat occurs

and allows them to respond immediately to the threat.

Encryption. Sensitive data is stored with cryptographic methods and if required, transferred

through environments encrypted with cryptographic methods and cryptographic keys are

stored in secure and various environments.

Logging. All transaction records regarding sensitive data are securely logged.

Two-factor authentication. Remote access to sensitive data is allowed through at least

two-factor authentication.

Penetration test. Periodically, penetration tests are performed on servers in the  Thousand Lakes Software Inc.

system. The security gaps created as a result of this test are closed and a verification test is

performed to show that the relevant security gaps have been closed. Besides, Information

Security Threat and Event Management System automatically performs penetration tests.

Test results are recorded.

Information Security Management System (ISMS). At the ISMS meetings made within

 Thousand Lakes Software Inc., the topics contained in the control forum are audited monthly by the director of

information technology and the director of financial operations.

Training. In order to increase the awareness of  Thousand Lakes Software Inc. employees against various

information security violations and to minimize the impact of the human factor in information

violation incidents, trainings are provided to employees at regular intervals.

Physical data security. It ensures that personal data on papers is necessarily stored in

lockers and accessed only by authorized persons. Adequate security measures (for

situations such as electric leakage, fire, deluge, thievery etc.) are taken based on the nature

of the environment where sensitive data is stored.

Backup.  Thousand Lakes Software Inc. periodically backs up the data it stores. As a backup mechanism, it uses

the backup facilities provided by the cloud infrastructure providers, as well as the backup

solutions it develops when deemed necessary, provided that it is in compliance with relevant

legislation and provisions of this Policy.

Non-disclosure agreement. Non-disclosure agreements are concluded with employees

taking part in sensitive personal data processing.

Transfer of sensitive personal data. If transfer of sensitive personal data is required

through email; such transfer is done through (i) encrypted corporate email or (ii) Registered


In the event that the personal data is damaged as a result of attacks on APURIBOTTI or on the

 Thousand Lakes Software Inc. system, despite  Thousand Lakes Software Inc. taking the necessary information security measures, or

the personal data is obtained by unauthorized third parties,  Thousand Lakes Software Inc. notifies this situation to

Users immediately and, if necessary, to relevant data protection authority and takes

necessary measures.


  1. Transferring Personal Data to Third Parties


The procedures and principles to be applied for transferring of personal data are regulated in

articles 8 and 9 of the PDP Law, and the personal and special categories of data of the

supplier may be transferred to third parties within the country or abroad since we may use

servers and cloud systems located abroad.

Your personal data may be transferred abroad for the following reasons:

  • Conducting storage and archive activities
  • Conducting business activities
  • Conducting after-sales support services for goods/services
  • Managing customer relationship management processes

 Thousand Lakes Software Inc. may also transfer your personal data to services providers of our Company, third

parties such as Facebook SDK, Adjust and Firebase Analytics which are embedded into our

service for the following purposes:

  • Sharing identity, communication and transaction security information with authorized

public institutions and organizations for the purpose of execution of activities in

compliance with legislation, monitor and execution of legal affairs, informing

authorized persons, institutions and organizations.

  • Sharing customer transaction information to manage after-sales support services,

conduct business activities and manage customer relationship management



  1. Your Rights as the Data Subject


Pursuant to Article 11 of the PDP Law, you may request the following regarding your

personal data by applying to  Thousand Lakes Software Inc.:

  • Learn whether or not your personal data have been processed;
  • Demand for information as to if your personal data have been processed;
  • Learn the purpose of the processing of personal data and whether data are used in

accordance with their purpose;

  • Know the third parties in the country or abroad to whom your personal data have

been transferred;

  • In case the personal data is processed incompletely or inaccurately; requesting

notification of the transactions made under this scope to third parties to whom

personal data have been transferred;

  • Request deletion, destruction or anonymization of personal data if the reasons for the

processing have disappeared and request notification of the transactions made under

this scope to third parties to whom personal data have been transferred;

  • Object to occurrence of any result that is to your detriment by means of the analysis

of personal data exclusively through automated systems;

  • Request compensation for the damages in case you incur damages due to unlawful

processing of your personal data.

Where General Data Protection Regulation (GDPR) is applicable, data subjects have the

following rights:

  • Right of access - Learning whether personal data is being processed and, if so,

accessing your personal data and the information regarding the processing of your

personal data,

  • Right to correction -To request the correction of information that you believe is

inaccurate or the completion of information that you believe is incomplete by

 Thousand Lakes Software Inc.,

  • Right to delete – To request deletion of personal data under the conditions stipulated

in GDPR,

  • The right to restrict processing - To request the restriction of the processing of

personal data under the conditions stipulated in the GDPR,

  • Right to object to processing - To object to the processing of personal data under the

conditions stipulated in the GDPR,

  • Right to data portability - To request the data collected by Thousand Lakes Software Inc. to be transferred

directly to another organization or under certain conditions,

  • Objection to the occurrence of a result against the person himself/herself, by

analyzing the processed data exclusively through automatic systems, including



In the application that includes your explanations about the right you have as the data subject

and exercise your rights stated above and that you request to exercise; your request must be

explicit and understandable, if the subject of your request is related to you or if you are acting

on behalf of someone else, you must be specially authorized in this regard and your authority

must be documented, the application must contain identity and address information and

documents proving your identity must be attached to the application. Our Company will

enable you to file such requests through the “Data Subject Application Form”

at support@ Thousand Lakes Software In accordance with Article 13 of the PDP Law, our Company will

finalize your requests, free of charge, within 30 (thirty) days at the latest depending on the

nature of the request. In case the request is rejected, the reason or reasons for the rejection

will be notified in writing or electronically along with its justification.

If you believe that we or someone with whom we have transferred your data is violating your

rights, you can file a complaint to the data protection authority in your country and to other

competent supervisory authorities.


This Privacy Policy may be revised by our Company when deemed necessary. If you

continue to access APURIBOTTI and use or access APURIBOTTI without benefiting from the Services offered by  Thousand Lakes Software Inc. after the notification period, you shall be deemed to have allowed the changes in this Privacy Policy.

Company Title: Thousand Lakes Software Inc.