Last Updated: Effective Date:
This EU/EEA Privacy Notice (“Notice”) explains how Xplore Work Yazılım Ticaret Limited Şirketi (“Xplore Work”, the “Company”, “we”, “us”, or “our”) collects, uses, stores, shares, and protects personal data in connection with the Xplore Work mobile application, desktop applications, website, web application, and related digital services (collectively, the “Services” or the “Platform”).
This Notice has been prepared particularly with regard to individuals located within the European Union (“EU”) and the European Economic Area (“EEA”) who use the Xplore Work Services, taking into account Regulation (EU) 2016/679 of the European Parliament and of the Council, the General Data Protection Regulation (“GDPR”).
The EEA consists of the Member States of the European Union as well as Iceland, Liechtenstein, and Norway.
Xplore Work is a global digital social business and trade platform that enables users and businesses to establish professional connections, share content, discover employment and commercial opportunities, publish product and commercial listings, communicate with other users and businesses, and benefit from digital professional networking services.
This Notice should be read together with Xplore Work’s general Privacy Policy, Cookie Policy, User Agreement, KVKK Information Notice, and other applicable Platform policies.
1. DATA CONTROLLER
For the purposes of the GDPR, the data controller responsible for the processing of personal data covered by this Notice is:
XPLORE WORK YAZILIM TİCARET LİMİTED ŞİRKETİ
Country of Establishment: Türkiye
Registered Office Address: Güvenevler Mah. 1928 Sok. Ekinci Global İş Merkezi Sit. Floor: 14 No: 5/25 Yenişehir, Mersin / Türkiye
Privacy and Data Protection Contact: support@xplorework.com
General Contact: support@xplorework.com
EU/EEA users may submit requests relating to the processing of their personal data and the exercise of their GDPR rights to Xplore Work through the contact channel above.
If Xplore Work becomes legally required to appoint a Data Protection Officer (“DPO”) under Article 37 of the GDPR or other applicable law, or voluntarily appoints a DPO, the relevant contact information will be separately published in this Notice.
2. EU/EEA REPRESENTATIVE
Xplore Work is a company established in Türkiye.
Where Xplore Work is not established within the EU/EEA but falls within the scope of Article 3(2) of the GDPR because it offers goods or services to individuals located in the EU/EEA or monitors their behaviour within the meaning of the GDPR, and no exception under Article 27(2) of the GDPR applies, Xplore Work will designate a representative in the European Union in writing in accordance with Article 27 of the GDPR.
The name, address, and contact details of the designated representative will be made available to users in this Notice and in other relevant areas of the Platform.
EU/EEA Representative: The representative’s details will be published here once the appointment has been completed.
The appointment of a representative does not affect or limit Xplore Work’s own responsibilities or liabilities as a data controller.
Until the representative’s details are published, data protection requests may be submitted to support@xplorework.com. However, this contact channel does not replace Xplore Work’s legal obligation to appoint a representative where such appointment is required under Article 27 of the GDPR.
3. SOURCES FROM WHICH WE COLLECT PERSONAL DATA
We may obtain personal data from the following sources:
- directly from you,
- account registration and profile creation processes,
- your use of the Platform,
- your device and technical systems,
- other Platform users,
- your company or authorised representative,
- documents submitted during company verification processes,
- legally accessible trade registry or company records,
- authorised verification service providers,
- payment and application marketplace service providers, and
- other sources that may lawfully be used.
If you provide personal data relating to another individual through the Platform, you must have the necessary legal authority to provide such data.
4. ACCOUNT AND IDENTITY INFORMATION
Depending on how you use Xplore Work, we may process personal data including:
- first and last name,
- username,
- profile photograph,
- age or date of birth,
- country and region information,
- preferred language,
- account identifiers,
- user and company verification information, and
- authorised representative information.
Additional identity or company verification information may be requested where necessary to provide certain Services, prevent fraud, or complete company verification.
5. CONTACT INFORMATION
We may process contact information including:
- email address,
- telephone number,
- business contact information,
- company address,
- branch or headquarters contact information, and
- other contact information that you voluntarily choose to publish on your profile.
6. PROFESSIONAL AND BUSINESS INFORMATION
If you use Xplore Work’s professional networking and trade features, we may process information including:
- profession,
- position and job title,
- company or organisation,
- industry,
- field of activity,
- work experience,
- educational information,
- professional skills and expertise,
- company profile,
- registered company name,
- company or branch location,
- tax or business activity information,
- product and service information,
- activity categories,
- job listings,
- commercial listings,
- information concerning production or service capacity, and
- other professional or commercial profile information.
Certain parts of this information may be visible to other Xplore Work users depending on the nature of the Platform and your visibility preferences.
7. USER CONTENT
We may process content that you create, upload, or share while using the Services.
This may include:
- posts,
- photographs,
- videos,
- documents,
- listings,
- product or service content,
- comments,
- likes,
- saved content,
- following information,
- favourites,
- company or product reviews, and
- other user interactions.
Content that you choose to make publicly available may be viewed by other users of the Platform.
Users are advised not to disclose unnecessary sensitive, confidential, or commercially protected personal information in publicly accessible areas.
8. MESSAGES AND COMMUNICATION DATA
When you communicate with other users or businesses through Xplore Work, we may process:
- message content,
- sender and recipient information,
- date and time of transmission,
- conversation history,
- message status information,
- file and media attachments, and
- technical records relating to message security.
This information is primarily processed to provide the messaging service.
Subject to applicable law and appropriate access controls, messages may also be subject to limited and authorised access for purposes including:
- preventing fraud,
- detecting spam or abuse,
- maintaining Platform security,
- investigating user complaints,
- complying with legal obligations, or
- investigating serious violations of Platform rules.
Xplore Work aims to implement appropriate technical and organisational measures to protect the confidentiality of user communications.
9. DEVICE, TECHNICAL, AND LOG DATA
When you access the Platform, certain technical information may be collected automatically.
This may include:
- IP address,
- device type,
- operating system,
- application version,
- browser type,
- device and session identifiers,
- session information,
- login and logout records,
- error and performance logs,
- security logs, and
- technical interactions within the Platform.
This information may be processed for security, service performance, error detection, system integrity, and improvement of the Services.
10. LOCATION DATA
Where you grant permission and use a relevant Platform feature, we may process approximate or precise location information.
Location data may be used particularly for:
- displaying nearby businesses or commercial opportunities,
- providing map-based listing features,
- presenting content based on country or region,
- improving search results, and
- security and fraud prevention.
Precise location information is processed only where required by the relevant feature and where the necessary device permission has been granted.
You may change or disable location access at any time through your device’s operating system settings.
11. PAYMENT, SUBSCRIPTION, AND TRANSACTION INFORMATION
Xplore Work may offer paid subscriptions and other paid digital services.
In this context, we may process:
- subscription plan,
- subscription status,
- transaction or purchase identifier,
- transaction date and time,
- transaction amount,
- Service used,
- payment status,
- billing information, and
- necessary financial transaction records.
For purchases and subscriptions made through iOS or Apple platforms, payment processing may be carried out by Apple through its own payment infrastructure and subject to its applicable terms.
Xplore Work may not directly store full payment card numbers, security codes, or similar sensitive payment credentials. Such information may instead be processed by the relevant payment or application marketplace provider under its own privacy and security terms.
Xplore Work may receive limited transaction and subscription information necessary to verify and manage subscriptions.
12. SUPPORT, COMPLAINT, AND MODERATION DATA
If you contact user support or submit a complaint regarding another user, business, listing, post, comment, product, or conversation, we may process:
- the reason for the complaint,
- the content concerned,
- the reporting user,
- the reported user or business,
- relevant message or content records,
- support correspondence,
- moderation decisions,
- appeals or counter-notifications, and
- security records.
This information may be used to maintain Platform safety, enforce the User Agreement and Community Guidelines, investigate disputes, prevent fraud, and comply with legal obligations.
13. ARTIFICIAL INTELLIGENCE, ALGORITHMS, AND PERSONALISATION
Xplore Work may use algorithmic systems and artificial intelligence-assisted technologies to make the Services more relevant, secure, and useful.
For example, recommendations or rankings may be generated using information such as:
- your profession,
- industry information,
- accounts you follow,
- content you view,
- interactions with listings,
- search preferences,
- saved or favourited content,
- your connections, and
- Platform usage patterns.
These systems may be used particularly for:
- displaying relevant content,
- recommending employment or commercial opportunities,
- recommending professional connections,
- ranking search results,
- detecting spam or abuse,
- assessing security risks, and
- personalising the Platform experience.
In the ordinary operation of its current Services, Xplore Work does not intend to make decisions concerning users that produce legal effects or similarly significantly affect them solely through automated processing.
If such processing is introduced in the future, the information, legal safeguards, and user rights required under Article 22 of the GDPR and other applicable provisions will be provided.
14. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA
Personal data may be processed for purposes including:
- creating and managing Xplore Work accounts,
- verifying users and companies,
- providing the Services,
- enabling communication between users and businesses,
- operating professional networking features,
- providing listing, post, and product features,
- providing map and location features,
- providing personalised content and recommendations,
- improving the user experience,
- identifying and resolving technical problems,
- measuring Platform performance,
- preventing fraud, spam, and abuse,
- maintaining account and Platform security,
- conducting company verification procedures,
- conducting complaint and moderation processes,
- managing subscription and payment processes,
- responding to lawful requests,
- complying with legal obligations,
- protecting our legal rights or the rights of our users,
- conducting marketing activities where permitted, and
- developing and improving Xplore Work Services.
15. OUR LEGAL BASES FOR PROCESSING UNDER THE GDPR
We process personal data only where a valid legal basis exists under the GDPR.
15.1. Performance of a Contract — Article 6(1)(b) GDPR
When you create a Xplore Work account or use the Services, personal data necessary to enter into or perform our contractual relationship with you may be processed.
This may include:
- creating your account,
- operating your profile,
- transmitting messages,
- publishing listings and content,
- providing subscription features, and
- providing requested Platform functionality.
15.2. Legitimate Interests — Article 6(1)(f) GDPR
Provided that your rights and fundamental freedoms do not override our interests, we may process personal data for legitimate interests including:
- maintaining Platform security,
- preventing fraud and abuse,
- improving Service performance,
- identifying errors and technical problems,
- measuring service quality,
- recommending relevant professional content and connections,
- protecting the security of our business and Platform, and
- establishing, exercising, or defending legal claims.
Where appropriate, we conduct legitimate interest assessments and balancing tests.
15.3. Consent — Article 6(1)(a) GDPR
Where applicable law requires consent, we process personal data only on the basis of valid consent.
This may include:
- certain marketing activities,
- optional precise-location features,
- non-essential cookies,
- certain tracking or analytics technologies, and
- other optional consent-based features.
You may withdraw your consent at any time.
Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
15.4. Legal Obligation — Article 6(1)(c) GDPR
We may process personal data where necessary to comply with tax, accounting, corporate recordkeeping, competent authority requests, statutory retention requirements, or other legal obligations.
15.5. Vital Interests — Article 6(1)(d) GDPR
In exceptional circumstances, this legal basis may be relied upon where processing is necessary to protect the life or physical integrity of an individual.
16. WHEN PROVIDING PERSONAL DATA IS REQUIRED
Providing certain personal data may be necessary for:
- creating an account,
- completing company verification,
- entering into or performing a contract,
- using particular Platform features, or
- complying with legal obligations.
If required information is not provided, we may be unable to provide all or part of the relevant Service.
Optional fields and consent-based features will, where reasonably possible, be distinguished from mandatory information.
17. SPECIAL CATEGORIES OF PERSONAL DATA
Xplore Work does not generally request that users provide special categories of personal data under Article 9 of the GDPR, including:
- health data,
- genetic data,
- biometric data processed for the purpose of uniquely identifying a person,
- religious or philosophical beliefs,
- political opinions,
- trade union membership,
- data concerning sex life, or
- sexual orientation.
Users are advised not to disclose such information unnecessarily in public profiles, posts, or messages.
Where it is exceptionally necessary for Xplore Work to process such data, an additional valid condition under Article 9 of the GDPR must apply.
18. SHARING OF PERSONAL DATA
Personal data may be shared with the following categories of recipients only to the extent necessary for the relevant purpose.
18.1. Service Providers and Processors
These may include:
- cloud and server service providers,
- data hosting providers,
- authentication infrastructure providers,
- email and notification services,
- analytics and performance services,
- customer support systems,
- security and fraud prevention services,
- payment service providers,
- application marketplaces, and
- technical infrastructure providers.
Xplore Work may use Google Firebase services for certain parts of its technical infrastructure.
Where a service provider acts as a processor on behalf of Xplore Work, the contractual requirements of Article 28 of the GDPR are applied where required.
18.2. Other Users
Information you choose to make public through your profile, company profile, listings, or other public areas of the Platform may be visible to other users.
18.3. Competent Public Authorities
Where legally required, personal data may be disclosed to courts, regulatory bodies, law enforcement authorities, or other competent public authorities.
18.4. Corporate Transactions
In connection with a merger, acquisition, investment, restructuring, sale of a company, or transfer of assets, certain information may be shared with relevant parties and professional advisers, subject to appropriate confidentiality and data protection safeguards.
19. PROCESSING OUTSIDE THE EU/EEA AND INTERNATIONAL DATA TRANSFERS
Xplore Work is headquartered in Türkiye, and certain personal data may be processed in Türkiye or in other countries in which our service providers operate.
Where a transfer of personal data constitutes a transfer to a third country within the meaning of Chapter V of the GDPR, Articles 44 and following of the GDPR apply.
Depending on the nature of the transfer, appropriate mechanisms may include:
- a valid adequacy decision adopted by the European Commission,
- Standard Contractual Clauses (“SCCs”) adopted by the European Commission,
- Binding Corporate Rules, where applicable,
- other appropriate safeguards permitted by the GDPR, or
- only where the relevant legal requirements are satisfied, the derogations provided for under Article 49 of the GDPR.
Where Standard Contractual Clauses are used, the legal and practical circumstances in the destination country may be assessed where necessary, and supplementary technical, organisational, or contractual safeguards may be implemented.
Users may request information about the appropriate safeguards used for transfers of their personal data and, where legally available, a copy of those safeguards.
20. DATA RETENTION PERIODS
We do not retain personal data for longer than necessary for the purposes for which it is processed.
When determining retention periods, we may consider:
- whether the account remains active,
- whether the data remains necessary for the relevant Service,
- whether the contractual relationship remains in effect,
- statutory retention obligations,
- tax and accounting requirements,
- ongoing disputes or legal proceedings,
- applicable limitation periods,
- fraud and security risks, and
- valid user requests.
When your account is closed, personal data will be deleted, anonymised, or access-restricted unless retention is required by law or justified by another valid legal purpose.
Data contained in backup systems may be removed through normal backup rotation and secure deletion cycles.
21. DATA SECURITY
Xplore Work implements technical and organisational measures proportionate to the risks in order to protect personal data against:
- unauthorised access,
- unlawful processing,
- unauthorised alteration,
- loss,
- destruction, and
- unauthorised disclosure.
Where appropriate, these measures may include:
- access authorisation,
- authentication mechanisms,
- role-based access controls,
- system and access logs,
- secure data transmission methods,
- encryption measures,
- security monitoring,
- backups,
- restrictions on employee access,
- security testing, and
- incident response procedures.
Recognising that no electronic system can provide absolute security, security measures are reviewed in light of relevant risks and technological developments.
22. PERSONAL DATA BREACHES
If a personal data breach affecting the confidentiality, integrity, or availability of personal data occurs, Xplore Work will assess the nature and scope of the incident and the risk to the rights and freedoms of affected individuals.
Where notification to the competent supervisory authority is required under Article 33 of the GDPR, notification will be made without undue delay and, where feasible, no later than 72 hours after becoming aware of the breach.
Where the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, affected individuals will also be informed where required under Article 34 of the GDPR.
23. GDPR RIGHTS OF EU/EEA USERS
Where the applicable requirements are satisfied, you may have the following rights under the GDPR.
23.1. Right of Access
You may ask whether we process personal data concerning you and request a copy of your personal data.
23.2. Right to Rectification
You may request correction of inaccurate personal data and completion of incomplete personal data.
23.3. Right to Erasure
Where the conditions set out in Article 17 of the GDPR are satisfied, you may request deletion of your personal data.
This is also commonly known as the “right to be forgotten”.
23.4. Right to Restriction of Processing
Under certain circumstances provided for by the GDPR, you may request that processing of your personal data be restricted.
23.5. Right to Data Portability
For certain personal data processed by automated means on the basis of consent or a contract, you may have the right to receive your data in a structured, commonly used, and machine-readable format.
Where technically feasible, you may request that the data be transmitted directly to another controller.
23.6. Right to Object
You may object, on grounds relating to your particular situation, to processing carried out under Article 6(1)(e) or Article 6(1)(f) of the GDPR.
You have the right to object at any time to the processing of your personal data for direct marketing purposes.
23.7. Right to Withdraw Consent
Where processing is based on your consent, you may withdraw that consent at any time.
23.8. Rights Relating to Automated Decision-Making
Subject to the exceptions provided for under the GDPR, you have the right not to be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you.
Where applicable, you may have the right to:
- request human intervention,
- express your point of view, and
- contest the decision.
24. HOW TO EXERCISE YOUR RIGHTS
You may submit requests relating to your GDPR rights to:
Email: support@xplorework.com
You should clearly identify the right you wish to exercise and the scope of your request.
To protect personal data, we may request reasonable additional information to verify that the person making the request is the relevant data subject or an authorised representative.
Under the GDPR, requests are handled without undue delay and, as a general rule, within one month of receipt.
Taking into account the complexity and number of requests, this period may be extended by up to two additional months where permitted by the GDPR. In such cases, you will be informed of the extension and the reasons for it within the initial one-month period.
Requests are generally handled free of charge. Where requests are manifestly unfounded or excessive, particularly because of their repetitive character, we may charge a reasonable fee or refuse to act on the request to the extent permitted by the GDPR.
25. RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY
Users located within the EU/EEA have the right to lodge a complaint with a competent data protection supervisory authority if they believe that their personal data has been processed in violation of the GDPR.
In particular, you may exercise this right before the competent supervisory authority in the EU/EEA country:
- of your habitual residence,
- of your place of work, or
- where the alleged GDPR infringement occurred.
You are not required to contact Xplore Work before exercising your right to lodge a complaint with a supervisory authority, and doing so does not affect your right to contact Xplore Work directly.
26. MARKETING COMMUNICATIONS
Where required by applicable data protection and electronic communications laws, marketing communications will be sent only after the necessary legal requirements and permissions have been satisfied.
Users may stop marketing communications through:
- account or notification settings,
- the unsubscribe mechanism included in the relevant communication, or
- contacting Xplore Work.
Security, account, contractual, subscription, or transaction notifications necessary for the operation of the Platform are not considered marketing communications.
27. COOKIES AND SIMILAR TECHNOLOGIES
Xplore Work’s web-based Services may use cookies and similar technologies.
These technologies may be used for:
- providing essential functionality,
- session management,
- security,
- remembering user preferences,
- measuring performance, and
- analytics or marketing where permission has been provided.
Where required by applicable law, valid user consent will be obtained before non-essential cookies or similar tracking technologies are used.
Further information is provided in the Xplore Work Cookie Policy.
28. MOBILE DEVICE PERMISSIONS
Certain Xplore Work features may require permissions on your device.
These may include:
- camera,
- photo library,
- microphone,
- location, and
- notifications.
Permissions are requested only where required by the relevant feature.
You may change or withdraw permissions through your device’s operating system settings.
Withdrawing a permission may affect the relevant feature but does not necessarily prevent you from using other Services.
29. CHILDREN’S PRIVACY
Xplore Work is a digital business platform intended for professional and commercial purposes and is not intended for use by persons under the age of 18.
Users must be at least 18 years old to create a Platform account.
If Xplore Work becomes aware that personal data relating to a person under the age of 18 has been unlawfully processed in connection with account registration or use of the Platform, appropriate measures may be taken in accordance with applicable law, including restricting or closing the account and deleting the relevant personal data.
30. THIRD-PARTY LINKS AND SERVICES
The Platform may contain links to third-party websites, applications, or services.
The processing of personal data by independent third parties is governed by their own privacy policies and terms of use.
Xplore Work does not control the data processing activities of independent third parties that do not fall within Xplore Work’s responsibility as a controller.
We recommend reviewing the relevant third party’s privacy notice before using its services.
31. ACCOUNT DELETION
Users may request deletion of their Xplore Work account through the account management features available within the Platform or through Xplore Work support channels.
Following account deletion:
- profile information,
- account information, and
- personal data associated with the account
will be deleted, anonymised, or access-restricted, subject to applicable legal retention obligations, security requirements, and other valid legal grounds.
Information that must be retained for fraud prevention, security, accounting, taxation, legal disputes, or other legal obligations may be retained for the applicable statutory or necessary period.
32. PRIVACY BY DESIGN, PRIVACY BY DEFAULT, AND DATA MINIMISATION
Xplore Work takes into account the fundamental principles set out in Article 5 of the GDPR when processing personal data.
These include, in particular:
- lawfulness, fairness, and transparency,
- purpose limitation,
- data minimisation,
- accuracy,
- storage limitation,
- integrity and confidentiality, and
- accountability.
When developing new products, features, and technical systems, Xplore Work takes into account the principles of Data Protection by Design and by Default under Article 25 of the GDPR to the extent applicable.
33. DATA PROTECTION IMPACT ASSESSMENTS
Where a processing activity, particularly one involving new technologies, is likely to result in a high risk to the rights and freedoms of individuals, Xplore Work will conduct a Data Protection Impact Assessment (“DPIA”) to the extent required under Article 35 of the GDPR.
Such an assessment may be particularly relevant to:
- systematic and extensive profiling,
- high-risk automated assessment systems,
- large-scale processing of sensitive data, or
- large-scale systematic monitoring of publicly accessible areas.
34. PROCESSORS AND SUB-PROCESSORS
Xplore Work may use third-party technical service providers to provide the Services.
Where service providers process personal data on behalf of Xplore Work, the data protection agreements and obligations required under Article 28 of the GDPR are implemented where applicable.
Processors are intended to access personal data only:
- in accordance with our documented instructions,
- for the provision of the relevant service, and
- to the extent necessary for their authorised level of access.
Where processors engage sub-processors, applicable GDPR requirements concerning sub-processors are taken into account.
35. REQUESTS FROM PUBLIC AUTHORITIES
Personal data may be disclosed to competent public authorities only where a valid legal basis exists under applicable law.
Where Xplore Work receives a request for personal data from a public authority, Xplore Work may, to the extent legally permitted, assess:
- the validity of the request,
- its legal basis,
- its scope,
- the legal authority of the requesting body, and
- the necessity and proportionality of the requested data.
Where legally possible and appropriate, Xplore Work may challenge requests that are excessively broad or unlawful.
36. CHANGES TO THIS PRIVACY NOTICE
Xplore Work may update this Notice from time to time due to changes in the Services, technology, data processing activities, or applicable law.
Where changes are material, users may be informed through the Platform, email, in-app notification, or other appropriate methods.
The “Last Updated” date displayed at the beginning of this Notice indicates when the Notice was most recently materially updated.
The updated Notice becomes effective on the stated effective date or when published on the Platform.
Where a change requires new consent, updating this Notice alone will not be considered sufficient; the required consent will be obtained separately.
37. CONTACT
If you have questions about this Privacy Notice, your personal data, or your rights under the GDPR, you may contact us at:
XPLORE WORK YAZILIM TİCARET LİMİTED ŞİRKETİ
Address: Güvenevler Mah. 1928 Sok. Ekinci Global İş Merkezi Sit. Floor: 14 No: 5/25 Yenişehir, Mersin / Türkiye
Privacy and Data Protection Email: support@xplorework.com
General Contact: support@xplorework.com
EU/EEA Representative: Where appointment is required under Article 27 of the GDPR and the appointment has been completed, the representative’s name, address, and contact details will be published here.
38. SPECIAL NOTICE FOR EU/EEA USERS
If you are located within the EU or EEA, the fact that Xplore Work is headquartered in Türkiye does not remove the rights provided to you under the GDPR where the GDPR applies to the processing of your personal data.
Where Xplore Work’s processing activities relating to individuals located in the EU/EEA fall within the territorial scope of the GDPR, Xplore Work aims to comply with the applicable obligations under the GDPR.
For international transfers of personal data falling within Chapter V of the GDPR, appropriate transfer mechanisms and, where necessary, supplementary technical, contractual, or organisational safeguards will be implemented.
Your account or access to the Services will not be unlawfully or discriminatorily adversely affected because you exercise your applicable rights under the GDPR.
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