WEARTECHCLUB PRIVACY POLICY

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EXPLICIT CONSENT DOCUMENT ON COLLECTION, PROCESSING AND TRANSFER OF PERSONAL DATA OF OUR VISITORS AND CUSTOMERS

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The data controller is Weartechclub Giyilebilir Spor Ürünleri Hizmet ve Teknolojileri Anonim Şirketi, a Turkish joint stock company having its headquarters at “Reşitpaşa Mah. Katar Cad. İtü Arı Teknokent 3 Binası Blok No: 4 İç Kapı No: B205 Sarıyer / İstanbul” (the “Data Controller”). 

You, as a visitor browsing our website (www.weartechclub.com) and our application (WearTechClub) (collectively the “Apps”) and/or as a customer purchasing products or services, hereby confirm that you have been duly informed by the Data Controller on the matters indicated in the “Privacy Policy & Information Letter on Collection, Processing and Transfer of Personal Data for Our Visitors and Customers” as required by the Turkish Law on the Protection of Personal Data No. 6698 (the “KVKK”) and the EU General Data Protection Regulation (the “GDPR”) and other relevant legislation. In this way, you also accept that the Data Controller has fulfilled its informing obligations.

The various procedures of the departments within the Data Controller and different categories of data and personal data belonging to you to be processed in this regard, can be found in detail in the above information letter. As can be seen in this document, in line with the purposes of improving the quality of the products and services provided to you; improving the performance of the product user with the data obtained via machine learning and artificial intelligence; drawing up agreements within the scope of the sales process and analyzing purchasing preferences and developing services in regard to customer satisfaction, your health information (vaccination card information, blood group, disability information, prosthesis information, health insurance information and muscular and nerve movements, number of steps, blood oxygen ratio, pulse, blood pressure, body temperature, breathing rate, location-dependent movement analysis information provided through the Apps) may be processed and transferred as stated below.

Your personal data may be transferred within the country or abroad to the other units within the Data Controller, Information and Communication Technologies Authority (Bilgi Teknolojileri ve İletişim Kurumu), banks, authorized public institutions and organizations such as the Treasury and law enforcement officers, our business partners within İTÜ and Sabancı Group of Companies and servers of Bulutistan application located in the country through online system and also, abroad-servers of the applications Applifting s.r.o. and Amazon Web Services from which we received service within the framework of the objectives and principles mentioned above, in particular for the purposes of improving the quality of the products and services provided to you and marketing and sales of our products and the internal rules of the Data Controller and at the level required by the Data Controller’s operations and in accordance with methods and conditions indicated in the GDPR and the KVKK. 

In addition to those listed above, your personal data may be shared with the competent authorities by the Data Controller in order to fulfill the legal obligations required by law.

 

You, as our visitor and/or customer, hereby give your explicit consent with your free will on the collection, processing and use, and transfer within the country and abroad of your personal data within the above-mentioned scope.

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PRIVACY POLICY & INFORMATION LETTER ON COLLECTION, PROCESSING AND TRANSFER OF PERSONAL DATA FOR OUR VISITORS AND CUSTOMERS

 

This document is prepared to inform the data subject whose personal data (this document also covers sensitive personal data) will be processed in a various ways including collection, recording and transfer of personal data within the country and abroad and within the framework of the relevant legislation, in particular the Law on the Protection of Personal Data numbered 6698 (the “KVKK”) and EU General Data Protection Regulation (the “GDPR”); thus, to comply with the GDPR, the KVKK and the Communiqué on Principles and Procedures to be Followed in Fulfillment of the Obligation to Inform, to fulfill the obligation to inform.

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1. DATA CONTROLLER AND ITS IDENTITY 

 

Data controller is Weartechclub Giyilebilir Spor Ürünleri Hizmet ve Teknolojileri Anonim Şirketi, a Turkish joint stock company having its headquarters at “Reşitpaşa Mah. Katar Cad. İtü Arı Teknokent 3 Binası Blok No: 4 İç Kapı No: B205 Sarıyer / İstanbul” (the “Data Controller”).

 

 

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2. METHOD AND LEGAL BASIS OF PERSONAL DATA COLLECTION

 

The Data Controller may collect fully or partially by automated means or by non-automated methods provided that it is part of the data recording system based on the reasons for compliance with laws stated in the GDPR and in the Articles 5 and 6 of the KVKK, in accordance with the laws and within the scope of fulfilling its legal obligations and/or the purposes of creating a common repository in relation to the business process that it carries out; in case (i) it is necessary to process personal data of the parties to an agreement provided that it is directly related to setting up of an agreement or its performance, (ii) it is necessary to process personal data to establish, use or protect a right, (iii) it is necessary to process personal data for the legitimate interests of the data controller, provided that not to damage fundamental rights and freedoms of data subject.

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3. PROCESSED PERSONAL DATA AND PROCESSING PURPOSES

 

Within the scope of the processes of browsing our website (www.weartechclub.com) and our application (WearTechClub) (collectively the “Apps”) and/or purchasing products or services, different categories of data and, accordingly, your personal data may be processed in order to carry out these processes:

 

• In line with conducting research and interviews with potential customers within the scope of customer acquisition process and planning visits if necessary and the purpose of Execution of Customer Relationship Management Processes; your name and surname information in the identity information category; your address, e-mail address, telephone number and date of birth information in the contact information category

• In line with the purposes of setting up agreements, its performance, issuing invoices and following up payments and Execution of Contract Processes and Execution of Goods/Service Sale Processes, data of customers with whom agreements have been made within the scope of the sales process; your name and surname, your place and date of birth, your marital status, your Turkish identity number and other information in the identity information category; your address, your e-mail address and your phone number information in the contact information category; information on contracts, invoices and promissory notes in the customer transaction information category; your vaccination card information, your blood group, your disability information, your prosthesis information, your health insurance information and your muscular and nerve movements, your number of steps, your blood oxygen ratio, your pulse, your blood pressure, your body temperature, your breathing rate, your location-dependent movement analysis information provided through the Apps in the health information category

• Within the framework of your transactions archived for certain periods of time within the scope of improving the quality of the products and services offered to our customers and in line with the purposes of Execution of Access Authorizations, Storage and Archive Activities and Information Security Processes; your name and surname, your place and date of birth, your marital status, your Turkish identity number and other information in the identity information category; your address, your e-mail address and your phone number information in the contact information category; your muscular and nerve movements, your number of steps, your blood oxygen ratio, your pulse, your blood pressure, your body temperature, your breathing rate, your location-dependent movement analysis information provided through the Apps in the health information category

• Within the framework of the feedback provided within the scope of improving the performance of the product user with the data received with the support of machine learning and artificial intelligence and in line with the purposes of Execution of Activities for Customer Satisfaction and Execution of Goods/Services After Sales Support Services; your name and surname, your place and date of birth, your marital status, your Turkish identity number and other information in the identity information category; your address, your e-mail address and your phone number information in the contact information category; your muscular and nerve movements, your number of steps, your blood oxygen ratio, your pulse, your blood pressure, your body temperature, your breathing rate, your location-dependent movement analysis information provided through the Apps in the health information category

• Within the framework of the data processing activity carried out for the proper performance of the complaint and request processes regarding the products purchased by our customers and in line with the purposes of Execution of Activities for Customer Satisfaction and Execution of Goods/Services After Sales Support Services; your name and surname, your place and date of birth, your marital status, your Turkish identity number and other information in the identity information category; your address, your e-mail address and your phone number information in the contact information category; information on contracts, invoices and promissory notes in the customer transaction information category; your muscular and nerve movements, your number of steps, your blood oxygen ratio, your pulse, your blood pressure, your body temperature, your breathing rate, your location-dependent movement analysis information provided through the Apps in the health information category

• Within the framework of the data processing activity carried out within the scope of planning and conducting market research activities for the sales and marketing of products and services and in line with the purposes of Receiving and Evaluating Suggestions for the Improvement of Business Processes and Executing Activities for Customer Satisfaction; your name and surname, your place and date of birth, your marital status, your Turkish identity number and other information in the identity information category; your address, e-mail address, telephone number information in the contact information category

• In line with analyzing purchasing preferences and developing services in relation to customer satisfaction and the purposes of Receiving and Evaluating Suggestions for the Improvement of Business Processes and Executing Activities for Customer Satisfaction; your name and surname, your place and date of birth, your marital status, your Turkish identity number and other information in the identity information category; your address, your e-mail address and your phone number information in the contact information category; information on contracts, invoices and promissory notes in the customer transaction information category; your muscular and nerve movements, your number of steps, your blood oxygen ratio, your pulse, your blood pressure, your body temperature, your breathing rate, your location-dependent movement analysis information provided through the Apps in the health information category

• In line with the data processing activities carried out through cookies and other tools for the efficient and secure operation of the Apps and the purposes of Execution of Marketing Analysis Studies, Execution of Advertisement/Campaign/Promotion Processes and Execution of Information Security Processes; your name and surname, your place and date of birth, your marital status, your Turkish identity number and other information in the identity information category; your address, your e-mail address and your phone number information in the contact information category; information on contracts, invoices and promissory notes in the customer transaction information category; your cookie logs and your purchase history in the marketing information category; your location information in the location information category

• Within the framework of sharing your personal data with our legal advisors for the follow-up of receivables, execution of legal processes and protection of the interests of our company and in line with the purpose of Follow-up and Execution of Legal Affairs; your name and surname, your place and date of birth, your marital status, your Turkish identity number and other information in the identity information category; your address, your e-mail address and your phone number information in the contact information category; information on contracts, invoices and promissory notes in the customer transaction information category; other information in the legal proceedings category

 

The Data Controller can store by keeping in the physical environment and/or recording in the database; update; and process your personal data collected as stated above through various activities including but not limited to the disclosure and transmission to third parties and to the extent permitted by the GDPR, the KVKK and any other legislation.

 

Your personal data shall be processed in accordance with the procedures and principles set forth in the GDPR, the KVKK and other legislation, in good faith, in a manner that is accurate and up-to-date, for specific, explicit and legitimate reasons; in a limited and measured manner, relevant to the purpose of processing and only to be retained for a period necessary for the purpose.  

 

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4. TO WHOM AND FOR WHAT PURPOSE PERSONAL DATA CAN BE TRANSFERRED

 

Your personal data may be transferred within the country or abroad to the other units within the Data Controller, Information and Communication Technologies Authority (Bilgi Teknolojileri ve İletişim Kurumu), banks, authorized public institutions and organizations such as the Treasury and law enforcement officers, our business partners within İTÜ and Sabancı Group of Companies and servers of Bulutistan application located in the country through online system and also, abroad-servers of the applications Applifting s.r.o. and Amazon Web Services from which we received service within the framework of the objectives and principles mentioned above, in particular for the purposes of improving the quality of the products and services provided to you and marketing and sales of our products and the internal rules of the Data Controller and at the level required by the Data Controller’s operations and in accordance with methods and conditions indicated in the GDPR and the KVKK. 

 

For the other cases required by law other than those listed above, your personal data may be shared with the competent authorities by the Data Controller in order to fulfill the legal requirements.

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5. MEASURES FOR THE PROTECTION OF YOUR SENSITIVE PERSONAL DATA​

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We determine and implement systematic, clearly defined, manageable and sustainable policies and procedures for the security of your sensitive personal data. Within the scope of your sensitive personal data stored in the Apps and our electronic media or accessible in these environments;

 

1. We protect your data using cryptographic methods,

2. We keep cryptographic keys in secure and different environments,

3. We securely log transaction records of all transactions performed on your data,

4. We continuously monitor the security updates of the environments where your data is located, regularly conducts necessary security tests and records test results,

5. In cases where your data is accessed via software, we fulfill the user authorizations of this software and regularly perform the security tests of these software and record the test results in question,

6. We provide at least a two-step authentication system if remote access to your data is required.

 

We prevent unauthorized entry and exit in order to ensure the physical security of these environments by taking adequate safe precautions and routinely inspecting your personal data processed, stored and / or accessible in our physical environments.

 

When transferring your sensitive personal data, in addition to the above;

 

1. If your data is transmitted via e-mail, it is transferred encrypted with a corporate e-mail address,

2. If the portable memory needs to be transferred via media such as CDs and DVDs, it is encrypted with cryptographic methods and the cryptographic key is kept in a different environment,

3. If transfer is made between servers in different physical environments, data transfer is performed by establishing VPN between servers, and

 

Even if the data is required to be transferred through paper medium, necessary precautions are taken against risks such as theft, loss or being seen by unauthorized persons of confidential information and/or documents containing your personal data, and the document is sent in the category of “classified documents”.

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6. RIGHTS OF THE DATA SUBJECT CONCERNED IN THE RELEVANT ARTICLES

OF THE GDPR AND THE KVKK

 

As the personal data subject, you have the following rights within the scope of Articles 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22 and 23 of the GDPR and Article 11 of the KVKK upon your application to the Data Controller:

 

1. to learn whether your personal data is processed or not;

2. if your personal data has been processed, to demand information with regards to the said processing;

3. to learn the purpose of processing your personal data and whether your personal data is being used for the intended purposes;

4. to know the third parties to whom their personal data is transferred within the country or abroad;

5. to request the rectification of incomplete or inaccurate data, if any;

6. to request the erasure or destruction of our personal data in accordance with the conditions of Article 7 of the KVKK;

7. to request notification on operations conducted as per the above sub-paragraphs v. and vi. to third parties to whom your personal data were transferred;

8. to object to the processing, exclusively by automatic means, of your data which leads to an unfavorable consequence for yourself; and

9. to request compensation for the damage arising from the unlawful processing of your personal data.

 

In order to use your above-listed rights, your requests should be transmitted to the Data Controller in writing to the address “Reşitpaşa Mah. Katar Cad. İtü Arı Teknokent 3 Binası Blok No: 4 İç Kapı No: B205 Sarıyer / İstanbul” or via other means that may be determined by the Personal Data Protection Authority in accordance with the GDPR and the KVKK. These requests shall be concluded within the periods indicated in the GDPR and the KVKK.

 

As per this document, you accept and declare that you have been explicitly informed on the data controller and its identity, method and legal basis of personal data collection, processed personal data and processing purposes, to whom and for what purpose personal data can be transferred and rights of the data subject concerned in the GDPR and the KVKK by the Data Controller for all transactions related to processing of your personal data. In this regard, you also explicitly accept and declare that the Data Controller has fulfilled its obligation to inform.

                                                                                            

This document may be amended or changed in accordance with the GDPR and the KVKK and other related legislation when deemed necessary by the Data Controller.

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