Introduction
At Toyi Oyun ve Tasarım A.Ş. ("Company" or "TOYİ"), we are aware of the dangers children face regarding their personal data, especially on the internet, and that children are often vulnerable to these dangers. Children's privacy on the internet is among our top priorities and holds great importance among our ethical values. The most important part of this is this Ethical Values Policy Regarding Children's Personal Data ("Policy").
This Policy explains the principles of our ethical values regarding the processing of children's personal data by our Company. For the principles adopted in our personal data processing activities, including children's personal data, and for the basic principles of compliance with the Personal Data Protection Law No. 6698 ("Law"), you can review our Personal Data Protection and Processing Policy.
Scope
This Policy covers all personal data of children, especially data obtained on the internet, processed by automatic means or by non-automatic means as part of a data recording system, and our basic ethical values regarding their privacy.
Ethical Values Regarding the Processing of Children's Personal Data
- Children are seen by some as the world's largest customer group, and there is significant investment in analysis and targeting strategies aimed at them. At TOYİ we do not see children as a marketing target; when developing our products we prefer products that stimulate children's imagination. For this reason, we do not use children's personal data for marketing activities aimed at children, such as personalised product development or personalised advertising.
- The cookies used on our website are necessary for the functioning of our website. We do not monitor children's internet behaviour and do not create any segmentation based on such behaviour.
- We strive not to collect more data than necessary on our website and at our events. For this reason, we design our website and event forms to collect as little information as possible from children.
- We do not use any mechanisms on our website or in our toys that process biometric personal data, such as voice recognition or biometric trace collection.
- When processing children's personal data, we operate the necessary mechanisms to verify age on our website and at our events, especially when personal data is shared and in purchases made through our website.
- Even if children's profiles are public, we do not collect any data from their social media accounts and do not use them to contact them or to give information about our products.
- For posts shared on social media accounts or on the website at your and your children's request, we take all necessary precautions to prevent children from being exposed to cyberbullying, derogatory comments, deceptive and malicious invitations, and we immediately start the necessary legal processes when we become aware of such attempts.
- At events and in social media posts, we approach every child as very valuable, stay away from hurtful attitudes such as unfairness, favouritism and prioritisation, and ensure that children are kept away from such attitudes.
- Aware of children's right to be informed about the processing of their personal data, we include information texts prepared specially for children on our website and at our events.
- We do not include any applications on our website or social media accounts that access the device camera or microphone.
- We do not allow third parties to collect personal data about children during our events, and we take all necessary precautions for this.
- When designing all our company processes and creating our procedures, we make a separate assessment for children's data and always prioritise the security of children's data.
- We stay away from misleading content aimed at children in all our online and offline materials and strive to prevent its use. We set the language we use according to children's general level of understanding and try to avoid misunderstandings.
- To prevent misuse of children's explicit consent, we also ask for your approval for explicit consent texts.
Ethical Values Regarding the Transfer of Children's Personal Data
- We do not share children's personal data with third parties without your and your children's consent unless it is necessary. However, we may share it with the parties stated in our information texts where needed, for example to deliver products bought online, for activities requiring expertise such as finance, law and IT, or to run our business.
- We do not share photos that children share on social media and ask us to post on our social media accounts without [their consent].
- At TOYİ, we do not share children's personal data with third parties for those third parties' own purposes, even where this would be for legitimate purposes and lawful.
Ethical Values Regarding the Protection of Children's Personal Data
- As with all personal data, we store children's personal data encrypted, in secure environments.
- We have our systems audited regularly to prevent possible threats to children's digital data.
- Children's personal data is the highest priority of all our team members. We give regular training to remind team members of the measures to take and work to raise awareness further.
- While the security of all personal data is our first priority, we set our default settings for children's personal data to be more restrictive and protective, and we strictly limit the number of people who can access this data.