Mobile Application Policy

SOCOTAB YAPRAK TUTUN SANAYI VE TICARET ANONIM SIRKETI Privacy Policy – Mobile Application

Last updated: April 24, 2026

This Privacy Policy describes how SOCOTAB YAPRAK TUTUN SANAYI VE TICARET ANONIM SIRKETI (“Socotab”, “we”, “our”, or “us”) collects, uses, stores, shares, and otherwise processes personal data when you use our mobile application (the “App”).

This App is intended for use by authorized company personnel only.

For the purposes of applicable data protection laws, including, where applicable, the General Data Protection Regulation (“GDPR”), SOCOTAB YAPRAK TUTUN SANAYI VE TICARET ANONIM SIRKETI is the controller of the personal data processed through the App.

Contact details:
SOCOTAB YAPRAK TUTUN SANAYI VE TICARET ANONIM SIRKETI
Email: tr.info@socotab.com

This Privacy Policy explains what categories of personal data are processed through the App, for what purposes, on what legal grounds, with whom the data may be shared, whether the data may be transferred outside the EEA, how long the data are retained, whether provision of the data is required, and what rights users may have in relation to their personal data.

1. Information We Collect

We may collect and process the following categories of personal data through the App:

a) Personal Information

  • Name and surname
  • Phone number
  • Email address

b) Location Data

  • Precise or approximate location data
  • Collected only while the App is actively in use
  • Used for field operations, mapping, and operational tracking

c) Photos and Camera Data

  • The App may access the device camera to capture photos (for example, invoice forms, field documents, and similar operational records)
  • Photos are collected only when the user actively takes them within the App
  • No background camera access is provided

d) Device and Technical Information

  • Device model and operating system
  • Application version
  • Unique device identifiers
  • IP address

e) Usage and Log Data

  • App activity and interactions
  • Error logs and performance data

f) Offline Data Storage

  • The App may store data locally on the device, including collected data and photos, to support offline usage
  • Stored data is securely synchronized with backend systems when internet connectivity is available

The provision of certain personal data may be required in order for the App to function properly and for the relevant business processes to be carried out. If such data are not provided, some features of the App may not function, or the user may be unable to use the App for its intended operational purposes.

2. How We Use the Information

We use the personal data collected through the App for the following purposes:

  • To support field operations and business processes
  • To capture and manage operational documents, including invoices, forms, and similar records
  • To enable offline data collection and later synchronization
  • To maintain, monitor, and improve application performance
  • To ensure system security and prevent unauthorized use
  • To administer and support the use of the App by authorized company personnel
  • To comply with legal and regulatory obligations, where applicable

3. Legal Basis for Processing

Where the GDPR or other applicable data protection laws apply, we process personal data through the App on one or more of the following legal bases:

  • Performance of a contract – where processing is necessary for the performance of a contract to which the user is a party, or to take steps at the request of the user prior to entering a contract
  • Legitimate interests – where processing is necessary for the legitimate interests pursued by Socotab, including supporting field operations, maintaining and improving the App, ensuring system and network security, preventing unauthorized use, and administering business processes, except where such interests are overridden by the interests, rights, or freedoms of the data subject
  • Compliance with a legal obligation – where processing is necessary for compliance with legal or regulatory obligations applicable to Socotab
  • Consent – where required by law, or where a specific processing activity is based on the user’s consent

4. Location Data Usage

  • Location data is collected only when necessary for App functionality and only while the App is in use.
  • We do not track users in the background.
  • Location data is used for field operations, mapping, operational tracking, and other operational purposes connected with the use of the App.
  • Where required by applicable law, location data will be processed on the basis of the user’s consent or another valid legal basis.

5. Camera and Photo Usage

  • The App uses the device camera only when initiated by the user to capture photos required for business processes.
  • Captured images are stored securely and used only for operational purposes connected with the use of the App, including the capture and management of invoices, forms, field documents, and similar records.
  • No background camera access is provided.

6. Data Sharing

We do not sell personal data.

Personal data processed through the App may be shared only with the following recipients or categories of recipients:

  • Socotab backend systems and servers
  • Authorized company personnel on a need-to-know basis
  • Trusted service providers, such as cloud hosting, technical support, analytics, or similar providers, engaged to support the App and bound by confidentiality and data protection obligations
  • Authorities, regulators, courts, or law enforcement bodies, where required by applicable law or valid legal process
  • Other Socotab affiliates, where necessary for internal administrative, operational, compliance, or support purposes and subject to applicable data protection requirements

7. Transfers Outside the EEA

  • Personal data processed through the App may be transferred to, accessed from, or stored in countries outside the European Economic Area (“EEA”), where this is necessary for operational, technical, support, or compliance purposes.
  • Where personal data are transferred outside the EEA, Socotab will implement appropriate safeguards as required by applicable law, including, where relevant, standard contractual clauses or other lawful transfer mechanisms.
  • Further information regarding such safeguards may be requested by contacting us at tr.info@socotab.com.

8. Data Storage and Security

  • We implement appropriate technical and organizational measures to protect personal data processed through the App against unauthorized or unlawful processing and against accidental loss, destruction, damage, or unauthorized access.
  • Data stored locally on the device is protected and synchronized securely with backend systems.
  • Access to personal data is limited to authorized people who require such access for operational, technical, or compliance purposes.

9. Data Retention

  • Personal data processed through the App is retained only for as long as necessary for the purposes described in this Privacy Policy, including operational, administrative, legal, regulatory, and security purposes.
  • Retention periods may vary depending on the type of data and the purpose of processing. Where no specific retention period is prescribed by law, personal data will be retained for the period necessary to fulfil the relevant purpose and thereafter deleted, anonymized, or otherwise securely disposed of.
  • Data temporarily stored locally on the device for offline use will be retained locally only for as long as necessary to enable synchronization and operational use, subject to the App’s functionality and applicable internal retention rules.

10. User Rights

Subject to applicable law, users may have the right to:

  • request access to their personal data
  • request correction of inaccurate or incomplete personal data
  • request deletion of their personal data
  • request restriction of processing
  • object to processing, where applicable
  • request portability of their personal data, where applicable
  • withdraw consent, where processing is based on consent
  • lodge a complaint with a competent supervisory authority

These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data. In some instances, this may mean that we are able to retain data even if you request deletion of your personal data.

Where we require personal data to comply with legal or contractual obligations, provision of such data is mandatory. If such data is not provided, we may not be able to provide the App or support the relevant operational processes. In all other cases, provision of personal data is optional.

Users may exercise their rights by contacting:

Email: tr.info@socotab.com

We may request information necessary to verify the identity of the requester before responding to a request.

11. Third-Party Services

  • The App may use third-party services that process data on our behalf in connection with hosting, storage, synchronization, analytics, technical support, maintenance, security, or similar functions.
  • Such third-party service providers are required to process personal data only on documented instructions, to maintain confidentiality, and to implement appropriate security measures in accordance with applicable data protection obligations.

12. Children’s Privacy

  • This App is not intended for children and is designed exclusively for use by authorized Socotab personnel.
  • Access to the App is restricted through authentication using company-issued credentials, and users cannot register or access the App without such authorization. The App is not directed toward children, does not include child-oriented content or features.

13. Changes to This Policy

  • We may update this Privacy Policy from time to time.
  • Any updates will be published within the App, on our website, or otherwise communicated through appropriate means. The “Last updated” date above indicates when this Privacy Policy was most recently revised.

14. Contact

If you have any questions regarding this Privacy Policy or the processing of personal data through the App, please contact:

SOCOTAB YAPRAK TUTUN SANAYI VE TICARET ANONIM SIRKETI
Email: tr.info@socotab.com