Privacy Notice For Membership & Subsciption
1. General Information
GAIN MEDYA A.Ş. (hereinafter referred to as "GAIN") hereby informs you that, in accordance with legal and contractual obligations, we process, transfer, and dispose of your personal data with utmost sensitivity to ensure compliance with the Law No. 6698 on the Protection of Personal Data ("KVKK"), the General Data Protection Regulation ("GDPR"), and all relevant legislation.
This Privacy Notice has been prepared to inform you about:
• The personal data processed by GAIN,
• The purposes of processing,
• The parties to whom your personal data may be transferred and the purposes of such transfers,
• The method and legal basis for collecting your personal data,
• Your rights under the KVKK and GDPR, and how to exercise them.
By ticking/confirming the box stating "I have read and accept the GAIN Privacy Notice for Membership & Subscription" you hereby declare, accept, and undertake that:
• You have read and understood this Privacy Notice,
• GAIN has fully fulfilled its obligation to inform you as required by law,
• You will not assert any claim or demand regarding GAIN's failure to fulfill its disclosure obligation.
GAIN does not process any additional personal data beyond what is processed during membership and subscription, except for payment information shared for subscription fee collection. Such payment details are processed by third-party payment providers (e.g., Google Play, App Store, or our intermediary payment partner), and GAIN does not have direct access to this information.
GAIN processes your personal data in accordance with the following principles:
✓ Lawfully and in good faith,
✓ Accurately and kept up to date where necessary,
✓ For specified, explicit, and legitimate purposes,
✓ In a manner that is relevant, limited, and proportionate,
✓ Retained for the period required by law or the purpose of processing.
2. Definitions
The terms below are used in this Privacy Notice in line with their legal meanings under the KVKK and GDPR:
• Explicit Consent: Freely given, informed, and specific consent for a particular purpose.
• Anonymization: Rendering personal data unidentifiable.
• Data Subject: The natural person whose personal data is processed.
• Personal Data: Any information relating to an identified or identifiable natural person.
• Processing: Any operation performed on personal data (e.g., collection, storage, transfer).
• Data Controller: The entity determining the purposes and means of processing (GAIN).
• Data Processor: A third party processing data on behalf of the controller.
3. Data Controller & Contact Information
Your personal data is processed by GAIN as the Data Controller. For inquiries, please contact:
• Website: https://www.gain.tv/
• Address: Atatürk Mah. Muhtar Hasan Sok. No:1/73, Ataşehir/Istanbul
• Email: kvkk@gain.com.tr or destek@gain.com.tr
4. Purposes & Legal Basis for Processing
GAIN processes your personal data only for lawful purposes, including:
• Membership and subscription management (KVKK Art. 5/2-c; GDPR Art. 6/1/b),
• Compliance with legal obligations (KVKK Art. 5/2-ç; GDPR Art. 6/1/c),
• Legitimate interests (e.g., fraud prevention; GDPR Art. 6/1/f).
| Purpose of Processing | Processed Personal Data | Legal Basis |
| Execution of Goods/Services Purchase Processes | Name-Surname | Contract Performance, KVKK Art. 5/2-c, GDPR 6/1/b |
| Execution of Goods/Services Purchase Processes | Contract Performance, KVKK Art. 5/2-c, GDPR 6/1/b | |
| Execution of Goods/Services Purchase Processes | Phone Number | Contract Performance, KVKK Art. 5/2-c, GDPR 6/1/b |
| Execution of Goods/Services Purchase Processes | Date of Birth | Contract Performance, KVKK Art. 5/2-c, GDPR 6/1/b |
| Execution of Goods/Services Purchase Processes | Device and Technical Data (Device type, brand/model, browser info, location, download source) | Legitimate Interests, KVKK Art. 5/2-c, GDPR 6/1/b |
5. Special Category Data
GAIN does not process special category data (e.g., health, religion) unless legally required. In such cases, explicit consent or a legal exception under KVKK Art. 6 or GDPR Art. 9 will apply.
6. Data Transfers
• Domestic: Shared only if legally mandated (e.g., judicial requests).
• International: Transferred only if the recipient country ensures adequate protection (KVKK Art. 9; GDPR Chapter V).
7. Your Rights
Under the KVKK and GDPR, you may:
• Request access, correction, or deletion of your data,
• Object to processing or restrict data use,
• Withdraw consent (if applicable),
• Lodge a complaint with the relevant authority. To exercise these rights, contact GAIN via email or post. Requests will be addressed within 30 days.
8. Updates to This Notice
GAIN may update this Privacy Notice to reflect legal changes. You will be notified of significant updates via email or in-app alerts.