INFORMATION TEXT ON THE PROCESSING AND PROTECTION OF PERSONAL DATA
A. Information as Data Controller
As Castrum Capital (“Castrum”), we attach utmost importance to the security of your personal data. Your personal data is processed and stored in accordance with the Law on the Protection of Personal Data No. 6698 (hereinafter referred to as “KVKK”). The KVKK was published in the Official Gazette dated April 7, 2016, and numbered 29677. This law is designed to protect the fundamental rights and freedoms of real persons whose personal data is processed, including the privacy of private life protected by our Constitution and Turkish Penal Code, and to determine the obligations of real and legal persons who process personal data.
The purpose of our personal data protection and processing policy (“KVK Policy”) is to establish management instructions and procedural requirements to ensure that personal data is processed and protected in compliance with the KVKK at Co Print.
In accordance with the KVKK, your personal data will be collected and processed by us within the scope explained below. As Castrum, your personal data will be recorded, stored, updated, disclosed/transferred to third parties where permitted by legislation, classified, and processed in the ways listed in the KVKK, as described on this page.
Castrum operates the following sites:
i. Castrum Capital – castrum.capital
A venture capital firm focused on blockchain and cryptocurrency projects, providing investment and strategic support to innovative startups in the Web3 space.
ii. Castrum Legions – castrumlegions.com
A game guild that organizes and supports gaming communities, fostering collaboration and growth within the blockchain gaming ecosystem.
iii. Castrum Work – castrum.work
A crypto growth agency dedicated to scaling blockchain projects through targeted marketing strategies and community engagement.
iv. Castrum Social – castrum.social
An influencer agency that connects brands with influencers in the crypto and blockchain space to amplify their reach and engagement.
v. Crypto Data Space – cryptodataspace.com
A news and data platform providing insights and updates on the latest trends in the cryptocurrency market.
vi. Castrum Academy – castrum.academy
An educational platform offering courses and training programs on blockchain technology and cryptocurrency, aimed at fostering knowledge and skill development in the industry.
The aforementioned sites, applications, and any other products shall hereinafter be collectively referred to as the “Websites.”
Definitions
| Term | Definition |
|---|
| Explicit Consent | Consent on a specific subject, based on information and expressed with free will. |
| Obligation of Clarification | The obligation to inform the relevant persons by the data controller or the person authorized by him/her, at the time of obtaining personal data, regarding the identity of the data controller and his/her representative, if any, the purpose for which personal data will be processed, to whom and for what purpose the processed personal data may be transferred, the method and legal reason for collecting personal data, and the rights of the relevant person as specified in KVKK Article 11. |
| Relevant Person | The real person whose personal data is processed. |
| Law/KVKK | Law No. 6698 on the Protection of Personal Data. |
| Personal Data | Any information relating to an identified or identifiable real person. |
| Processing of Personal Data | Any operation performed on data, such as collection, recording, storage, preservation, alteration, rearrangement, disclosure, transfer, takeover, making available, classification, or preventing the use of personal data. |
| Board | Personal Data Protection Board. |
| Authority | Personal Data Protection Authority. |
| Data Processor | The natural or legal person who processes personal data on behalf of the data controller based on the authority granted by him/her. |
| Data Controller | The natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system. |
B. What Personal Data is Processed and on What Grounds?
In accordance with Articles 4 and 10 of the KVKK, the categories of personal data processed, the types of data, and their legal grounds are listed in the table below. Your personal data shared with Castrum can be partially or completely, automatically or non-automatically, processed by us by being collected, recorded, stored, altered, rearranged, and by being subject to any processing specified under the KVKK. Your personal data can be collected in written/physical or electronic environments through cookies when you participate in events, use Castrum services, engage in advertising or marketing campaigns. Castrum processes Personal Data when users submit forms, documents, or other information related to their interactions and commercial relationships with Castrum.
DATA CATEGORIES
| Data Categories | Types of Personal Data Collected and Their Legal Grounds |
|---|
| Identity Information | When you receive services from Castrum, have meetings with well-known persons, register as a member or sign up, you share information such as your “Name”, “Surname”, “Date of Birth”, “Identity” with Castrum voluntarily. Identity information is processed to fulfill our obligations under the legislation, to conduct necessary operational activities, and to facilitate interaction. |
| Contact Information | When you receive services from Castrum, have meetings with well-known persons, register as a member or sign up, submit a document or form, you share information such as your “Email Address”, “Address”, “City and District of Residence”, “Web-Site”, “Project Name”, “Preference on Advertising” and “Mobile Phone” with Castrum voluntarily. Sharing contact information is important to facilitate communication between Castrum service users or event participants. |
| Visual and Multimedia Data | When you receive services from Castrum, have meetings with well-known persons, register as a member or sign up, you share photos, multimedia recordings, and visuals related to your work with Castrum voluntarily. Sharing visual and multimedia data is important for Castrum’s communication with the user. |
| Cookies Information | Cookies are small text files stored on your device or network server by Websites you visit through your computer or mobile device. Depending on their type, cookies collect data related to your browsing and usage preferences on the device you use to visit the site. These data include information such as the pages you access, the products and services you review, your language preference, and other preferences. We use various types of cookies to provide a better experience for our users and visitors. In this context: |
| • Mandatory and essential cookies, such as session, load balancing, user ID, and security cookies, to ensure the proper functioning of web pages, |
| • Preference-related cookies, such as password, language, location, history, flash, and mobile cookies, to enhance usage efficiency based on users’ and visitors’ preferences, |
| • Functional and analytical cookies that collect analytical data to obtain information about visits to the Website/pages, |
| • Targeting and marketing cookies, which are frequently used for advertisements today, including cookies for advertisement, market analysis, targeting, fraud detection, and campaign promotions, |
| • Third-party cookies, which are generally found in advertising sites on web pages and include cookies related to another web page’s advertisements or plugins, are used on our Website. It is accepted that the user has given explicit consent to the use of cookies unless these settings are changed. |
Castrum may provide links to third-party Websites or mobile applications through its Website. However, we have no responsibility for the application of privacy policies on these sites or the policies to which third parties are subject. Privacy policies within the scope of third-party Websites or mobile applications may differ from this Personal Data Protection Policy.
C. Methods and Legal Reasons for Collecting Personal Data
In accordance with the KVKK, the personal data you share with Castrum can be processed by us, partially or completely, automatically or non-automatically, by being collected, recorded, stored, altered, rearranged, and subjected to any processing specified under the KVKK. All operations performed on data within the scope of the KVKK are considered as “processing of personal data.” Castrum can generally collect and process data of its users through its web pages and call centers for the following purposes:
- To collect personal information to facilitate interaction through our Website,
- To provide personalized services to our users and improve user experience to increase satisfaction,
- To communicate with our users to the extent they permit, inform them about services and opportunities,
- To perform the services we provide in accordance with our contracts,
- To send newsletters via email or make promotions or notifications,
- To make promotions or notifications via SMS,
- To respond to your calls and meet your support needs,
- To develop and market the product during the management process of our current and RD applications,
- To resolve complaints related to our services upon your request or in case of complaints on social media,
- To collect and process your data anonymously for statistical evaluations, database creation, and market research.
When we plan to collect user data in the future, this data will be used for the following purposes:
- Potential marketing activities,
- Adding to mailing lists,
- Personalized advertisements and promotions,
- Measuring user experience and personalizing UI/UX.
The personal data collection activity carried out by Castrum is based on the following reasons in accordance with Article 5, paragraph 2 of the KVKK;
- It is mandatory for the fulfillment of our legal obligations,
- It is mandatory for the protection of Castrum’s legitimate interests, provided that it does not violate your fundamental rights and freedoms,
- It is explicitly stipulated in the laws,
- It is necessary for the establishment or performance of a contract, provided that it is directly related to the processing of personal data belonging to the parties of the contract.
D. To Whom Your Personal Data is Transferred
By accepting the Personal Data Protection Policy, you have given your explicit consent to the collection, storage, processing, use, and transfer of your personal data to Castrum’s domestic and international business partners, employees, and third parties with whom we have cooperation, within the scope of Castrum applications and services, to provide you with various advantages. In addition, this information will only be shared with third parties with whom we have a contractual relationship, who have the same legal and technical responsibilities regarding data protection and security as us, and who comply with the relevant legislation, only when necessary and to the extent required, to ensure the flawless delivery of the services provided to you, and to ensure that our notifications are delivered on time via phone, SMS, and/or email.
User data collected may be shared with third parties such as Google and Meta for standard marketing activities.
Castrum may share your visit data and browsing information on its Website and membership information, such as traffic information, with public institutions and organizations authorized to request this information legally (such as for crime prevention and threats to state and public security but not limited to these) when required by law or administrative obligation.
E. What Are Your Rights Regarding Your Personal Data?
Regarding your personal data; Article 11 of the KVKK came into force on October 7, 2016, and according to this article, the rights of the Relevant Person are as follows: The Relevant Person can apply to Castrum and;
- Find out whether personal data is being processed,
- Request information if personal data has been processed,
- Find out the purpose of processing personal data and whether they are used appropriately for their purpose,
- Know the third parties to whom personal data is transferred domestically or abroad,
- Request correction of personal data if it is incomplete or incorrectly processed,
- Request the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the KVKK,
- Request notification of the transactions made pursuant to paragraphs (d) and (e) to third parties to whom personal data has been transferred,
- Object to the occurrence of a result against the person himself/herself by analyzing the processed data exclusively through automated systems,
- Request compensation for the damage if personal data is damaged due to illegal processing.
Users will have the right to access, correct, or delete their personal data. They will be able to exercise these rights through their user profiles. Users will have the right to withdraw their consent for the processing of their data. This process will be provided through an unsubscribe method and the option to continue anonymously (as a guest).
F. Application and Application Methods for Your Personal Data
Castrum Capital, which operates in compliance with the KVKK as a data controller, respects the rights of you, the Relevant Person/data subjects, and strives to fulfill your requests in your application. According to Article 11 of the KVKK, email at cc@castrum.istanbul. You can access detailed information regarding the application in the Information Policy for the Relevant Person.
G. Changes to the Privacy Policy
Changes to the privacy policy will be communicated to users through application notifications and email notifications.
H. International Data Transfer and Local Compliance
Currently, user data will be collected globally. To ensure compliance with local data protection laws (KVKK, GDPR) for users in different countries, we will ensure compliance with these policies by using software applications belonging to global companies.
