Last Update: 12/06/2024


Privacy Policy and the Clarification Statement on the Processing of Personal Data

(“Privacy Policy”)

This Privacy Policy and Clarification Statement on the Processing of Personal Data (‘Privacy Policy’) has been prepared by Desk360 Yazılım Anonim Şirketi (‘Desk360’) in its capacity as the data controller in order to fulfil our disclosure obligation under the Personal Data Protection Law No. 6698 (‘PDPL’).

We, as Desk360, listen to our users and we are committed to protecting the principles of privacy and fair use that underpin our values to offer a transparent and secure service. We want you to be confident that your personal data is safe and secure with us.

This Privacy Policy explains the following:

  • how we collect your personal data;
  • what personal data we collect;
  • how we use your personal data;
  • who we share your personal data with; and
  • your rights and choices you have when it comes to your personal information.


1. Identity of the Data Controller

Pursuant to LPPD, the data controller Desk360 Yazılım Sanayi ve Ticaret Anonim Şirketi is registered with the Istanbul Trade Registry with the registration number 265115-5, 0293097850500001 Mersis number, company headquarter located at the address of Maslak Mah. Büyükdere Cad. USO Centre NTV Apt. No:245/27 Sarıyer, Istanbul.

When we say “Desk360” “our,” “we,” or “us,” we’re talking about Desk360 Yazılım ve Sanayi A.Ş. in its capacity as the data controller.

This Privacy Policy applies to all of our apps, services, games, features, software, and website (together, “Services”) unless specified otherwise.

This Privacy Policy explains how we will use personal data about you and the steps we take to ensure your personal data is kept secure and confidential. It should be read together with our Terms of Service.


2. How do we collect personal data?

Desk360 acts in accordance with all obligations required by the relevant legislation, especially the LPPD, in all personal data processing activities it carries out, and takes the necessary security measures to ensure that your personal data is securely hosted and to prevent unlawful use of your personal data.

We may obtain personal data from you through the websites, mobile applications or other similar devices, channels or applications operated by or on behalf of Desk360.


3. What personal data do we collect?

We collect personal data about you when you give this to us in the course of registering for and/or using our Services for example we may collect your name, surname, email address, phone number or device ID. Note that it is your responsibility to check and ensure that all information, personal data, content, material or data you provide us is correct, complete, accurate and not misleading.

Data that you may provide voluntarily

Certain parts of our Services may ask you to provide personal data voluntarily. For example, we will ask for certain information in order for you to register for an account with us, to begin using our Services, to subscribe to marketing communications from us, and/or to submit enquiries to us, such as:

  • Contact and correspondence information (such as name, surname and email address);
  • User name and password;
  • Phone number
  • Profile information (such as profile photo and biography); and
  • Other data you choose to give us (such as data to identify a lost account).
  • Your relevant information so that we can provide invoicing (If the invoice is to be issued to the company, the trade name, address, tax office and account number, if any; if it is to be issued to an individual, the T.R. Identity number is obtained)


The personal data that you are asked to provide, and the reasons why you are asked to provide it, we will try to explain to you at the point we ask you to provide your personal data.

Data that may be collected automatically

When you use our Services, we may also collect data automatically from you and/or your device which may be considered personal information under applicable data protection laws, such as:

  • Data and analytics about your use of our Services;
  • Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI);
  • Data about your device, such as device name and operating system, browser type and language;
  • Data we collect with cookies and similar technologies;
  • Information about the country of registration;
  • Broad geographic location based on your IP address;
  • Precise geo-location data (GPS, with your consent);
  • In Desk 360 Dashboard and Public API services, the right to access conversations only on the basis of ‘Need to know’ when relevant and necessary and
  • Data about your use of our Services, such as in application interaction and usage metrics.


Advertising ID means Apple Identifier for Advertisers (“IDFA”) on Apple and Google Advertising Identity (“GAID”). These are unique identifiers for mobile device that advertisers use for interest-based advertising. They are consistent across all apps and thus allow cross-app tracking. On Apple you can opt-out this by choosing “limit ad tracking” option from privacy settings. On Google Android you can opt-out by choosing “Opt-out of interest-based ads”.

Advertising IDs are non-permanent, non-personal identifiers, which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognise your device when you use websites and applications.

Data about your device refers to information about your device type, device model, device maker, device operating system and its language or other technical data like screen size or processor, or combination of this data available from a device for a developer for checking the device compatibility with a particular application.

Some of this information may be collected using cookies and/or similar technologies (such as "SDKs" or software development kits), as explained further below.

Data that we may obtain from third party sources

We may receive personal data about you from third party sources. For example, if you clicked on an advertisement to direct you to one of our Services we may be provided with information from which ad-network and advertising campaign the install originated from.

You may choose to connect to our Services via your social media account. Exactly what information we receive from your social media will depend on your social media privacy settings, but it would typically include your basic public profile information such as:

  • your username;
  • profile picture;
  • age range; and
  • gender


The data that we may collect from our partners could include;

  • Data we receive if you link a third-party tool with our Services (such as Facebook, Apple or Google);
  • Demographic data (such as to determine the location of your IP address);
  • Data to fight fraud (such as click fraud in advertising);
  • Data from platforms that our Services run on (such as to verify payment); and
  • Data for advertising and analytics purposes, so we can optimise the Services we deliver to you.


We do not request or intend to collect any special or sensitive categories of data such as any data on health, race, religion, political opinions, sexual preferences or orientation.

While using our Services, you shall be obliged to inform your users or third parties about the processing and / transfer activities of data (domestic and / or international transfer of data) and, if necessary, to obtain explicit consents, and Desk360 will not have any responsibility or liability in this regard.


4. Purposes of data processing

We may use your personal data:

  • to enable you to access and use the Services. For example;
  • To create user accounts and profiles;
  • To provide you with the correct versions of our applications; and
  • To send you service-related communications including confirmations, technical notices, updates, security alerts, and support or administrative messages
  • to personalise and improve aspects of our Services. For example;
  • To respond to your customer support requests;
  • To receive error messages about any issues you / your device encounters with our Services to enable us to fix bugs and interoperability issues;
  • To detecting and preventing illegal activities;
  • To track application installs, for purposes of measuring the effect of our marketing campaigns;
  • To conduct optional user feedback surveys;
  • To remember you next time you visit one of our Services; and
  • Communicate with you about promotions, rewards, upcoming events, and other news about products and services offered by us.
  • to communicate with you, including some or all of the following:
  • To provide you with in-app offers and rewards based on your interaction with our Services;
  • To serve you with relevant targeted advertisements;
  • To make you offers to purchase in-app items on discount based on your activity with our application and your purchase history; and
  • To send you marketing communications and/or newsletters if you have subscribed for them about rewards and promotions.
  • for research, such as analysing market trends and customer demographics;
  • To comply with legal obligations, including to prevent and/or detect fraud or provide disclosure to the authorities when required by applicable law.


5. On what legal grounds do we process your personal data?

We will only collect and use your personal data (as described in section 4) in accordance with data protection laws. Legal grounds for processing your personal data are as follows:

  • Explict Consent – Where necessary we will only collect and process your personal data if you have given your clear and affirmative consent for us to do so.
  • Legitimate Interests – We may use and process some of your personal information where we have sensible and legitimate business grounds for doing so. Our legitimate interests for processing your personal data are for us to enable you access and use of our Services, to communicate with you about our Services and to improve our Services.
  • Legal obligations - We may need to process your personal data when we need to comply with a legal obligation.
  • Processing of personal data of the parties to the contract is necessary, provided that it is directly related to the conclusion or performance of the contract - when we provide you with Services or communicate with you about them


6. Who do we share your personal data with?

When you use any of our Services, we may disclose your personal data to the following parties:

  • To our group companies, third party services providers and partners who provide data processing services to us. For example, to support the delivery of, provide functionality on, or help to enhance the security of our Services, or who otherwise process personal information for purposes that are described in this Privacy Policy or notified to you when we collect your personal information.
  • to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary.
  • to any other person with your consent to the disclosure.
  • Information on payment and payment methods is transferred to our Business Partners, who are third parties, in order for our Company to fulfil its legal obligation as the data controller.

In addition, your personal data may be transferred to and processed by our Group Companies, third party service providers and partners located outside the borders of the Republic of Turkey based on your consent.


7. What cookies do we use?

A cookie is a very small text file placed on your computer or device. We and our partners use cookies and similar technologies to provide and personalise our Services, analyse use, target advertisements and prevent fraud. You can disable cookies in your browser settings, but some parts of our Services may then not function properly.

For detailed information about our cookie policy, please see our cookie policy.


8. What advertisements do we show on our Services?

The advertisements that you see displayed on our Services are delivered on our behalf by certain third-party advertising companies. No information which identifies you, for example your name, address, email address or telephone number, is used to provide this advertising. In order to display advertising most likely to be relevant to you, these third-party advertisers may place or recognise a unique cookie on your browser. This cookie does not collect personal information about you nor is it linked to any identifiable information about you. By using our Services, you are consenting to the use of these third-party cookies for these purposes.

If you would like more information about online advertisements and your choices about how this information may be used by these companies, please find more information here


9. What steps do we take to keep your personal data safe?

Your personal data’s security is very important to us. This is why, where it’s appropriate, we use HTTPS to help keep data about you secure. However, no data transmission over the internet can be guaranteed to be totally secure.

We do our best to keep the data you disclose to us secure. However, we can't guarantee or warrant the security of any data which you send to us, and you do so at your own risk.

By using our Services, you accept the inherent risks of providing information online and will not hold us responsible for any breach of security.


10. How long do we keep your personal data?

Unless a longer retention period is required or permitted by law, we will only retain your personal data only for as long as reasonably necessary to fulfil the purposes outlined in this Privacy Policy and for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements. We will for example periodically de-identify unused user accounts and regularly review our data sets.

Unless otherwise stated in this Privacy Policy, personal data that you provide to us will only be retained for as long as is necessary for us to fulfil our obligations in relation to the provision of the Services.


11. Do we transfer your personal data outside of the country you are resident?

Our Services are global by nature and your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country. We take steps to ensure adequate safeguards are in place to protect your data as explained in our Privacy Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA.

Your personal data may be transferred to our Group Companies, third party service providers and partners located outside the borders of the Republic of Turkey based on your consent. By accepting our terms of service, you are deemed to have consented to the processing and transfer of your personal data abroad. In case you do not accept the processing and transfer of your personal data abroad, you may choose not to use our Services.


12. Age Limits

We do not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 18 or knowingly allow such persons to use our Services. If you are under 18, please do not send any data about yourself to us, including your name, address, telephone number, or email address.

No one under the age of 18 should provide us any personal data. If we learn that we have collected personal data about a child under age 18, we will delete that data as soon as it is practicably possible.


13. Your personal data rights and how to contact us

You have certain rights under existing data protection legislation including the right to request a copy of the personal information we hold about you, if you request it from us in writing.

  1. Right to learn whether your personal data is being processed;
  2. Right to request information about it if it has been processed;
  3. Right to learn the purpose of processing your personal data and whether they are used in accordance with the purpose;
  4. Right to know the third parties to whom your personal data is transferred; (in Turkey or abroad)
  5. Right to access: the right to request copies of your personal information from us;
  6. Right to erase: the right to request that we delete or remove your personal information from our systems;
  7. Right to correct: the right to have your personal information rectified if it is inaccurate or incomplete;
  8. Right to request notification of the transactions in the items 6 and 7 above to third parties to whom personal data is transferred;
  9. Right to restrict our use of your information: the right to ‘block’ us from using your personal information or limit the way in which we can use it;
  10. Right to data portability: the right to request that we move, copy or transfer your personal information;
  11. Right to object to the emergence of a result against the person himself/herself by analyzing your processed data exclusively through automated systems; and
  12. Right to demand compensation for damages in case of damage due to unlawful processing of your personal data.

In this context, you can submit your requests regarding your rights mentioned above to us by filling out the Data Owner Application Form on our website with the information and documents identifying your identity or by creating your own request in a way that meets the conditions determined by the Personal Data Protection Authority and by the methods specified below.

By hand with a wet signature to our postal address below or through a notary public,

Address: Maslak Mah. Büyükdere Cad. USO Centre NTV Apt. No:245/27 Sarıyer/ İstanbul

By e-mail that you will send to our KEP address or e-mail address below from the e-mail address you have previously notified us and registered in our system (please check your e-mail address registered in our system) or with secure electronic signature or mobile signature,

E-mail address :

KEP address :

Desk360 will finalise your request free of charge as soon as possible and within 30 (thirty) days at the latest, depending on its nature. If a cost arises due to the fulfilment of your requests, we may only charge you the fees in the tariff determined by the Personal Data Protection Board.


Changes to this Privacy Policy

Desk360 reserves the right to amend and change this Policy at any time without prior notice to you. It is your responsibility to review the Policies regularly to be aware of changes. Your continued use of the Services after modifications constitutes your agreement to be bound by the revised Policies. The most current version of our Policies will be available on our website and any changes will be effective upon publishing. The date of the most recent revision will be displayed on this page.


If you do not agree to these changes, please do not continue to use our Services.


For more information, please read our company policies below:


Data Subject Application Form