BaseChat

Privacy Policy

Last updated:

Contents
  1. Introduction
  2. Controller and Contact
  3. Information We Collect
  4. Sharing of Your Information
  5. How We Use Information We Collect
  6. Legal Bases for Processing
  7. Your User Profile
  8. Data Access and Removal
  9. Retention Period
  10. Automated Review
  11. Service Providers
  12. Outbound Links
  13. Opt-Out – Promotional Communications
  14. Security
  15. Data Transfer
  16. Age
  17. Notification of Changes
  18. Your Rights

Introduction

This is the Privacy Policy of TELPASS TELEKOMÜNİKASYON HİZMETLERİ PAZARLAMA SANAYİ İÇ VE DIŞ TİCARET LİMİTED ŞİRKETİ for BaseChat in all its versions and future versions, including the BaseChat web version (hereinafter collectively referred to as “BaseChat”, “us”, “we” or “our”), and is incorporated into and is subject to our Terms of Use. In this Privacy Policy, we refer to our products and services as the “Service”. Please read on to learn more about our data handling practices. Your use of the Service signifies that you agree with the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not use the Service.

Controller and Contact

The controller within the meaning of the General Data Protection Regulation (GDPR) for the processing of your personal data in connection with the Service is TELPASS TELEKOMÜNİKASYON HİZMETLERİ PAZARLAMA SANAYİ İÇ VE DIŞ TİCARET LİMİTED ŞİRKETİ.

For any questions about data protection and to exercise your rights, you can reach us by email at support@base-chat.de with the subject “Privacy”.

Information We Collect

When you install the Service on your device and register with BaseChat, personally identifiable information about you may be collected during the download process for the Service (as requested during the download process) and when you register with us. For registration through BaseChat, you are required to provide your mobile phone number or your email address, city location, gender and name, depending on the device(s) you are using on the Service. You may also provide further personally identifiable information, but that is optional. When you log in using your Facebook account, we may collect additional information you make available to us (see “Your User Profile” below).

In addition, when you install the Service on your device and register with BaseChat, you will be asked to allow us access to your address book. If you consent, we will have access to contact information in your address book on the device you use for the Service (names, numbers, emails and Facebook IDs, but not notes or other personal information in your address book), and we will store them on our servers and use them to help you use the Service, for example by synchronizing your BaseChat contacts between different devices you may want to use with the Service. If you do not want BaseChat to store this information, you may opt out through your account settings in the BaseChat application at any time. However, we may not be able to offer some of the features that require this information.

BaseChat may also collect and gather non-personally identifiable information, such as certain profile information including country of residence and preferences. In addition, BaseChat may collect and store information about your and others’ usage of and interaction with the Service and our websites, including matches, numbers of matches made by members, match durations, text messages, usage by geographies, device and connection information, IP address, device capability, bandwidth, statistics on page views, network type and traffic to and from our websites.

BaseChat allows you to share text messages, photos, screenshots, videos and other communications in the BaseChat application with other users, and if you choose to do so, your text messages, photos, screenshots, videos and other communications will be stored on our servers. In addition, if you choose to share these items with other BaseChat users, we may not be able to remove them from our servers or make them unavailable to anyone you have shared them with. Sending and sharing text messages, photos, screenshots, videos or other communications in the BaseChat application is your decision. By choosing to share that information, you should understand that you may no longer be able to control how that information is used and that it may become publicly available (depending in part on your actions or the actions of others with whom you have shared the information). BaseChat is not responsible for any use or misuse of information you share. In addition, if your conversation partner reports your abusive behavior or language to us, conversation information such as voices, screenshots or contents of the conversation which has been stored only on your partner’s device may be transferred to our servers. Such transferred information will be processed by us to ascertain the genuineness of the report and to determine your penalty level, if needed.

BaseChat may also collect and gather user content (e.g. photos, screenshots, comments and other materials) that you create on the Service. Your photo can be taken by other users on BaseChat, and if they use the capturing function provided by BaseChat, those photos can be stored and used for BaseChat and third-party services (e.g. Facebook). You can change the third-party sharing option in the BaseChat settings. If you do not agree with all the terms of this Privacy Policy, please do not use the Service.

To complete a commerce transaction in the BaseChat item shop, you will be requested to provide your payment information, including your credit card number, card expiration date, CVV code and billing address. In that event, we will transmit your information securely and directly to a third-party vendor or merchant who will collect such information in order to process and fulfill your purchase. BaseChat does not process or store your payment information. However, we may store other information about your purchases made on the Service, which may include the merchant’s name, the date, time and amount of the transaction and other behavioral information.

We also collect error-reporting information if the Service crashes or hangs, so that we can investigate the error and improve the stability of the Service for future releases. In general, these reports do not contain personally identifiable information, or only incidentally. As part of these error reports, we receive information about the type and version of your device, the device identifier, the time the error occurred, the feature being used and the state of the application when the error occurred. We do not use this information for any purpose other than investigating and fixing the error.

Sharing of Your Information

We will not rent or sell your information to third parties (or the group of companies of which BaseChat is a part) without your consent, except as noted in this Privacy Policy.

Parties with whom we may share your information

  • We may share User Content and your information (including but not limited to information from cookies, log files, device identifiers, location data and usage data) with businesses that are legally part of the same group of companies that BaseChat is part of, or that become part of that group (“Affiliates”). Affiliates may use this information to help provide, understand and improve the Service (including by providing analytics) and Affiliates’ own services (including by providing you with better and more relevant experiences). However, these Affiliates will honor the choices you make about who can see your content.
  • We may also share your information, as well as information from tools like cookies, log files, device identifiers and location data, with third-party organizations that help us provide the Service to you (“Service Providers”). Our Service Providers will be given access to your information as is reasonably necessary to provide the Service, under reasonable confidentiality terms.
  • We may also share aggregate or anonymous information with third parties, including advertisers and investors. For example, we may tell our advertisers the number of users our app receives. This information does not contain any personal or personally identifiable information and is used to develop content and services that we hope you will find of interest.
  • We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.

Parties with whom you may choose to share your User Content

  • Any information or content that you voluntarily disclose for posting to the Service, such as User Content, becomes available to the public. With this feature, BaseChat can be protected from exhibitionism. Once you have shared User Content or made it public, that User Content may be re-shared by others.
  • If you remove information and content (e.g. screenshots) that you created on the Service, copies may remain viewable in cached and archived pages of the Service, or if other users or third parties have copied or saved that information (e.g. Facebook).

How We Use Information We Collect

We use or may disclose your personal information only as follows:

  • to verify your identity;
  • to connect you with others as enabled by the Service;
  • to share your Profile with others on the Service;
  • to allow your use of certain features of the Service that may be offered from time to time (such as Premium Services; see our Terms of Use);
  • to show you the names of persons you communicate with and to show your name to persons you communicate with on the Service;
  • to deliver to you any administrative notices, alerts and communications relevant to your use of the Service;
  • to provide you with relevant content that you requested, using information that you allow us to collect from you or that you provide to a social media provider with which your BaseChat account is connected, such as information regarding your and your BaseChat contacts’ respective locations;
  • to contact you via email, SMS or otherwise for the purpose of informing you about new products, services or promotions offered by BaseChat (you can opt out of such emails or SMS by sending an email to support@base-chat.de);
  • for internal operations, including troubleshooting problems, data analysis, testing, research, improvements to the Service, and detecting and protecting against error, fraud or other illegal activity;
  • when we have a good-faith belief that the law, any legal process, law enforcement, national security or an issue of public importance requires disclosure;
  • to protect and defend our rights or property (including to enforce our Terms of Use and other agreements); or
  • in connection with a corporate transaction involving BaseChat, such as the purchase or sale of a business unit, an acquisition, merger, sale of assets or other similar event.

Legal Bases for Processing

We process your personal data on the following legal bases:

  • Performance of a contract (Article 6(1)(b) of the GDPR): for registration, providing the Service and its features, displaying your Profile and processing purchases;
  • Consent (Article 6(1)(a) of the GDPR): where we ask for your consent, for example for access to your address book, for connecting your Facebook account, or for promotional communications where consent is legally required;
  • Legitimate interests (Article 6(1)(f) of the GDPR): for the security and stability of the Service, error analysis, preventing fraud and abuse, moderating content and handling reports, improving the Service, and the establishment, exercise or defense of legal claims. Our legitimate interest in each case is the secure, functional and lawful operation of the Service;
  • Legal obligation (Article 6(1)(c) of the GDPR): where we are legally required to process data, for example to comply with retention obligations or to respond to requests from authorities.

Providing the data required for registration is necessary to use the Service; without these data we cannot provide the Service to you. All other information is voluntary.

Your User Profile

The information you enter into your user profile (your “Profile”) may be shared with your BaseChat contacts. You control your Profile, and you can access and modify your Profile from the BaseChat application at any time. In addition, if you register with BaseChat using your Facebook account (e.g. Facebook Connect), we may store your Facebook ID and corresponding token on our servers and, if you give us your express consent, we will have access to and may collect certain information that you make available on Facebook (for example, your first and last names, email address, profile picture, your friend lists and birthdays). Your Profile is available to other users of the Service who are connected to you on BaseChat. In addition, unless you opt out (which you may do at any time in the BaseChat application), your Profile is discoverable by other BaseChat users, including, by way of example, in listings of contacts that will include your proximity to other users. You may also “block out” any BaseChat user in your contact list from discovering your Profile at any time. In addition, BaseChat may pre-populate your Profile with certain information such as your name and Facebook profile picture if you or your friends have logged onto the Service using Facebook.

Data Access and Removal

You can always control what information you choose to share with us on the Service. To do so, you can change your settings in the Service or on your mobile device. Alternatively, you can remove the Service from your mobile device entirely.

You can remove your data any time you want. If you ask us to delete your account, we will use commercially reasonable efforts to remove your data from our servers.

Any personally identifiable information that you (i) share in text messages, photos, videos or otherwise in or through the BaseChat application with other users, or (ii) submit on a blog, bulletin board or chat room on our website or elsewhere, can be viewed and used by others, including to send you unsolicited messages or to commit identity theft. BaseChat is not responsible for any use or misuse of your information that might result from your disclosure of information.

Retention Period

We store personal data only for as long as is necessary for the purposes for which they were collected. If you delete your account, we delete or anonymize your personal data unless we are legally required to retain them (for example under commercial or tax law) or need them for the establishment, exercise or defense of legal claims or to investigate violations of our Terms of Use. In those cases, we restrict processing to these purposes and delete the data once the respective reason no longer applies.

Automated Review

Profile photos are reviewed automatically before they are published; flagged content is then reviewed by our moderation team (see our Terms of Use). No decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you (Article 22 of the GDPR) takes place.

Service Providers

In certain instances, BaseChat may have contracts with third parties to provide products and/or services in connection with the Service. In those cases, BaseChat may share your personal information with BaseChat’s third-party service providers, but only in connection with providing the services to you. For example, BaseChat shares your phone number or email with third-party SMS and email providers to deliver the authentication SMS or email to you when you register with BaseChat. We contractually require that these third parties use your information solely to deliver SMS or email to you and use appropriate security measures to protect your information. In addition, certain BaseChat servers are owned and hosted by third-party service providers. This Privacy Policy does not apply to the practices of third-party service providers.

Opt-Out – Promotional Communications

BaseChat allows you to choose not to receive promotional email messages from BaseChat and its service providers. You may opt out by following the instructions in the message sent by BaseChat or its service providers on how to unsubscribe from that particular mailing. You may also opt out by contacting us at support@base-chat.de.

Security

Protecting user privacy and personal information is a top priority for BaseChat. We make substantial efforts to ensure the privacy of all personally identifiable information you provide to us. Access to all personally identifiable information is restricted to those BaseChat employees, contractors, agents and third-party service providers who need to know that information in order to provide, operate, develop, maintain, support or improve the Service. BaseChat uses password protection, access logs and system monitoring to safeguard the confidentiality and security of all member information. We take appropriate technical and organizational measures pursuant to Article 32 of the GDPR to ensure a level of security appropriate to the risk.

In addition, due to the inherent nature of the Internet and related technology, we do not guarantee the protection of information under our control against loss, misuse or alteration.

Data Transfer

Your information may be stored and processed in countries in which we or our service providers maintain facilities. These may include countries outside the European Union (EU) and the European Economic Area (EEA), including the country in which the controller is established (Türkiye).

Where we transfer personal data to a country outside the EU/EEA for which there is no adequacy decision of the European Commission, we ensure an adequate level of data protection through appropriate safeguards pursuant to Article 46 of the GDPR, in particular the Standard Contractual Clauses adopted by the European Commission, or we base the transfer on a derogation under Article 49 of the GDPR. You can request a copy of the relevant safeguards using the contact details in the Controller and Contact section.

Age

The Service is intended exclusively for persons aged eighteen (18) and over (see our Terms of Use). We do not knowingly collect personally identifiable information from persons under the age of eighteen as part of the Service. If we become aware that we have inadvertently received personally identifiable information from a person under the age of eighteen, we will delete such information and the account concerned without delay, unless we are legally required to retain it – for example, to report offences against children to the competent authorities.

Notification of Changes

We reserve the right at our discretion to make changes to this Privacy Policy. You may review updates to our Privacy Policy at any time via links on our website. You agree to accept electronic communications and/or postings of a revised Privacy Policy on the BaseChat website, and you agree that such electronic communications or postings constitute notice to you of the Privacy Policy. We reserve the right to modify this policy from time to time, so please review it frequently.

If we make material changes to this policy, we will notify you by publishing a revised Privacy Policy or by means of a notice on our website, or as required by law. You agree to review the Privacy Policy periodically so that you are aware of any modifications. You agree that your continued use of the Service after we publish a revised Privacy Policy or provide a notice on our website constitutes your acceptance of the revised Privacy Policy. If you do not agree with the terms of the Privacy Policy, you should not use the Service.

Your Rights

If you wish to use any of the rights described below, you may contact us at any time by emailing us at support@base-chat.de. We process and answer your requests without undue delay and in any event within one month of our receipt of the request, unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total, as permitted by Article 12 of the GDPR.

1) Right to request access

You have the right to request access to the data that we are processing on you (see Article 15 of the GDPR), including information about:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipient to whom the personal data have been or will be disclosed;
  • the envisaged period for which the personal data will be stored.

Furthermore, you have the right to obtain a copy of the personal data undergoing processing. Please note that access may be restricted due to intellectual property or trade secrets.

2) Right to object

You have the right to object to our processing of your personal data on grounds relating to your particular situation when the data are processed based on the balancing-of-interests rule in Article 6(1)(f) of the GDPR (see Article 21 of the GDPR). In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms, or if the processing is necessary for the establishment, exercise or defense of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes at any time. We will cease the processing of your personal data for this purpose after the objection. Objecting to direct marketing does not affect your use of the Service. If you object to processing that is necessary to provide the Service, we may no longer be able to provide the Service to you, or only to a limited extent.

3) Right to rectification and erasure

You have the right to have inaccurate personal data rectified (see Article 16 of the GDPR). Furthermore, you have the right to have your personal data erased where one of the following grounds applies (see Article 17 of the GDPR):

  • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • you have withdrawn your consent and there are no other legal grounds for the processing;
  • you have objected to the processing and there are no overriding legitimate grounds for the processing;
  • the personal data have to be erased for compliance with a legal obligation in Union or Member State law;
  • the personal data have been unlawfully processed; or
  • the personal data have been collected in relation to the offer of information society services.

Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims (see Article 17(3) of the GDPR).

4) Right to restriction of processing

You have the right to request the restriction of processing of your personal data (see Article 18 of the GDPR), in particular if you contest the accuracy of the data, if the processing is unlawful and you request restriction instead of erasure, if we no longer need the data but you require them for the establishment, exercise or defense of legal claims, or if you have objected to the processing and it has not yet been determined whether our legitimate grounds override yours.

5) Right to data portability

You have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and to transmit those data to another controller, where the processing is based on your consent or on a contract and is carried out by automated means (see Article 20 of the GDPR).

6) Right to withdraw consent

Where processing is based on your consent, you may withdraw it at any time with effect for the future (see Article 7(3) of the GDPR), for example via the settings of the app or your device, or by email to us. The withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

7) Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a data protection supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement (see Article 77 of the GDPR). In Germany, this is generally the data protection authority of your federal state. We would appreciate the chance to address your concern first, so please feel free to contact us beforehand.