SPOTLIGHTER CLARIFICATION TEXT
Last updated: 24.06.2022
1. Data Controller ID


Neo Bilişim Teknolojileri ve Medya Yapım A.S.
info@spotlighter.app

2. Purposes of Data Processing, Data Collection Methods and Legal Reasons
2.1 App Registration: The user can log in by linking their Google or Apple store account, in which case Spotlighter can only see an ID assigned to Apple or Google by Spotlighter if you say Hide your account during linking.

Instead, the user can register in the field on the web base or mobile application by processing the e-mail address, name and surname, username, password and submitting the contract confirmation notice. If they register in this way, the phone number will be requested and a verification code will be sent to the number for the purpose of session verification immediately after registration. User matching with phone number is performed for security verification purposes. This means that each phone number can only be used for one user account. Unless this verification process is done, the User may not use the content creation functions (including commenting) in Spotlighter in any way.

When processing personal data during the registration process for the application, we rely on the legal reason in Article 5(2)-c of KVKK No. 6698 “It is necessary to process the personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract”.

2.2 Presentation of Currents Close to the User: In the area on the application, the user may choose to customize the content to be encountered by entering the birth year, profession, city, gender data. Here, we rely on the legal reason for the explicit consent of the user in the provision 5(1) of the KVKK.

2.3 Newsletter Sending: Users receive a monthly plan for in-app activities. Here, we rely on the legal reason for the explicit consent of the user in the provision 5(1) of the KVKK. Please note that there is a “unsubscribe” button in these newsletters and that you can unsubscribe from the newsletter mailing list at any time.

2.4 Messaging Between Users: If you use the messaging tools in the application, we inform you that your messages (chat history) will be stored on your own devices, that Spotlighter will not be able to access this data in any way, and that Spotlighter does not have the title of “data controller” on this data. Spotlighter has also designed the messaging process to prevent visual and link sharing by considering user safety. If anyone bothers you, you can block them.

2.5 Video content uploaded by users has the status of “works” in accordance with intellectual property legislation. In the contracts related to these contents, the rights and obligations related to the content are regulated. KVKK will not be operated on the personal data received in these contents. Other rights of the relevant persons whose data are included in the content are reserved. In addition, an application form is presented to the user who shares the content before sharing, asking questions such as age and profession about the user and the answers given to these questions are filtered and used in line with the future needs of the major stakeholders in the ecosystem. For example, talents are determined by filtering methods suitable for a youth series. Users can vote for content shared within the app and make public comments about it. Here, we rely on the legal reasons in Article 5(2)-c of the KVKK “It is necessary to process the personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract” and “Data processing is mandatory for the establishment, use or protection of a right” in Article 5(2)-e.

2.6 Receiving Contest Submissions: Only Spotlighter users can participate in the Contest. The content to be uploaded is technically matched with the user. In addition, the aims of the competition are to increase the number of users and thus contribute to the development processes of the directors. The application to the competition is made with the application form. In the meantime, data such as the content of the film subject to the competition, actor information, if any, and director information are requested. Competitors upload their videos to the application and share them. These videos are legally “works” and can be viewed online by anyone. The contestant must transfer the copyrights of these videos to Spotlighter as a condition of participation in the competition. After the competition, these contents will continue to be watchable. Here, we rely on the legal reasons in Article 5(2)-c of the KVKK “It is necessary to process the personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract” and “Data processing is mandatory for the establishment, use or protection of a right” in Article 5(2)-e.

2.7 Competition Voting and Winner Determination Process: The voting and evaluation of the competitors and the determination of the winner are included in the Application Specifications. Voting will be done by viewers using the “vote” button. Here, we rely on the legal reasons in Article 5(2)-c of the KVKK “It is necessary to process the personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract” and “Data processing is mandatory for the establishment, use or protection of a right” in Article 5(2)-e.

3. Data Transfer Purposes and Data Recipients
Public data consists of the movie title, production date, duration, director name and content. Users’ data is shared with stakeholders (which can be the production company, organizers, agencies and other persons) if there is an agreement in the ecosystem.
Spotlighter servers are provisioned from Microsoft Azure. All data that you have saved in the application and that has been generated during the time you use the application will have been “transferred abroad”. In KVKK, transfer abroad is subject to strict conditions. Your “explicit consent” will be sought for transfer abroad until the “safe country list” is declared by the Personal Data Protection Authority and/or until any regulation is published.
4. Other Rights of the Data Subject
The relevant persons may exercise their rights under Article 11 of the Law No. 6698 at any time by applying to the correspondence address notified above. In addition, users can edit their username, name, surname and password created during registration from the field defined for them. For e-mail address, phone number editing/changing and account deletions, it is necessary to contact the help/support area.