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PRIVACY NOTICE

This Privacy Notice regarding the collection, use and disclosure of your personal data Actifit Spor ve Sağlık Hizmetleri Sanayi ve Ticaret Anonim Şirketi (will be referred to as “Actifit” from hereon) which is established at Levent Mahallesi Fulyalı Sokak No:7 Beşiktaş, İstanbul is aimed towards informing you on the following matters:

What Personal Data Actifit collects and processes about you,
Why Actifit collects and processes your Personal Data,
To whom the Actifit discloses your Personal Data,
Any international transfers of your Personal Data,
How Actifit safeguards your Personal Data,
Your rights regarding your Personal Data.

For purposes of this Privacy Notice,

“Personal Data” means any information concerning identified or identifiable individual; and
“Processing” means any operation with respect to Personal Data, such as collection, retrieval, access, use, disclosure, storage and destruction.

Collection, Use and Disclosure of Personal Data

Collection. In accordance with the service act between the parties, Actifit collects your Personal Data via call center, website and the application (app). Additionally, your data can be collected from third party social media sites you have given us permission to access or are public and third parties such as life health applications or websites.

The Personal Data collected and processed by Actifit and/or contracted suppliers are as following:

Name, Surname	Date of Birth	Body Measurements
E-mail Address	Mental Health Data	Digital Photograph
Phone Number	State of Health	-

Sharing of Personal Data other than the ones listed above with Actifit and/or its suppliers and/or uploading them to Actifit means you have made the mentioned data public with your own will. Actifit and/or its suppliers will have no obligations regarding the data made public by you.

Collection of Personal Data to fulfill a legal obligation or to perform a duty arising from a contract. Personal Data listed below will be processed by Actifit and / or its contracted suppliers as data controller within the scope of compliance with the relevant legislation, especially the Turkish Code of Obligations, and in order to fulfill the obligations under the service contract.

Name, Surname	Date of Birth
E-mail Address	Phone Number
Address	-

The relevant Personal Data is processed in accordance with Personal Data Protection Law Article 5/2, subparagraph (c) and (ç) if it is directly related to the establishment or performance of the contract and it is necessary for compliance with a legal obligation. Processing of this personal data is not subject to your consent. Therefore, you do not have the right to ask for destruction of the Personal Data inside the terms set forth in the relevant legislation.

Collection of Personal Data for improving the products and services offered, offering new products and services for customer satisfaction and needs and other commercial purposes.

Name, Surname	Phone Number
E-mail Address	Date of Birth
Digital Photograph	-

Your personal data collected above is processed within the scope of your explicit consent to improve the products and services offered by Actifit, to offer new products and services in line with customer satisfaction and needs, and for advertising and marketing for commercial purposes

Processing of Personal Data mentioned here for the purposes listed above are based on Personal Data Protection Law Article 5/1.

Within the scope of your explicit consent, Actifit can analyze your personal data mentioned above through automated systems and draw conclusions about these data.

Processing of Personal Data for providing dietician and psychological counseling services. (If it is in your scope of service and if you wish to use it)

Body Measurements

Health Data

Mental Health Data

Your Personal Data mentioned above is processed only for the purpose of providing psychological counseling and / or dietician services provided by Actifit and / or its suppliers and within the scope of your explicit consent.

The processing of personal data here for the above-mentioned purposes is subject to Article 6/2 of the Personal Data Protection Law.

Within the scope of services such as psychological counseling and dietician (services provided by contracted suppliers) that Actifit will provide to you, your special categories of personal data such as your body measurements, health data and mental health data are processed directly within the scope of your explicit consent. In such a case, your sensitive data will only be processed by the dietician and / or psychologist and / or the service provider call center Actifit has contracted with. Only persons authorized by Actifit will be able to access your Special Categories of Personal Data that you share within the scope of the service. Under no circumstances will your Special Categories of Personal Data be shared with third parties other than the aforementioned persons.

However, we would like to state that, due to the nature of the psychological counseling and / or dietician services provided, if you withdraw your explicit consent, Actifit and / or its suppliers will not be able to continue to provide these services.

You have the right to withdraw your explicit consent regarding the processing of your personal data mentioned in headings 1.3 and 1.4 and processed in accordance with your explicit consent by Actifit and/or its suppliers for these purposes at any time without giving any reasons. Actifit and / or its suppliers will immediately cease to process your data for this purpose after you submit your declaration of withdrawing your consent to Actifit.

Your withdrawal of consent will not affect the lawfulness of the processing based on your consent prior to this withdrawal. Actifit will continue to retain the information provided before the withdrawal of your consent as long as permitted or required by applicable law.

Processing period of your Personal Data

Your Personal Data is stored until the end of the 10 (ten) year retention period from the date you terminate your relationship with Actifit and / or contracted suppliers. In addition, if there is a call center within your scope of service, your personal data will be stored by the relevant call center for two (2) years from the date they save the data for security and information verification.

Your Personal Data will be deleted or destroyed in the first destroying period prior to the end of this period.

Transferring or disclosing to third persons

Transferring Abroad. With your explicit consent, in accordance with PDPL Article 9/1, your Personal Data listed below will be transferred to the company abroad titled Microsoft, that is based registered in Ireland and that Actifit receives server service from:

Name, Surname	Date of Birth	Body Size
E-mail Address	Mental Health Data	Digital Photograph
Phone Number	State of Health	-

In addition, the results extracted from your personal data collected and analyzed are shared anonymously with your employers. However, during this transfer, no personal data is transferred in a way that can be associated with you.

Transferring to domestic third persons.

Your personal data;

Is transferred to third parties providing information services and with Actifit's suppliers, including the call center from which Actifit receives service from to realize the purposes stated here, and Actifit employees providing services to you. The transfer is done if it is mandatory for the performance of the contract and to fulfill the legal obligations of Actifit in accordance with the reference of Article 8/2 (a) of PDPL to Article 5/2 (c) and (ç).
In case of a legal dispute, it can be transferred to law firms and lawyers for the use and protection of Actifit's right in accordance with the reference of Article 8/2 (a) of PDPL to Article 5/2(e).
In certain circumstances, in accordance with the responsibilities and legal obligations arising from the law, it can be transferred to law enforcement and security forces, judicial institutions and relevant public institutions and organizations as required by the law in accordance with the reference of Article 8/2 (a) of PDPL to Article 5/2(a).

Information on third parties and / or categories of third parties to whom your data is disclosed are always open to your information and review.

In addition, the results drawn from your personal data collected and analyzed are shared anonymously with your employers. However, during this transfer, no personal data is transferred in a way that can be associated with you.

Collection Method of Personal Data

Your Personal Data can be collected from;

Provided by your Employer to ensure the contract can be performed.
Directly provided to Actifit by you.
Third party applications such as social media sites or life health apps that you have given Actifit permission to access.

Your Rights Regarding your Personal Data

Actifit is obliged to take all kinds of physical, technical and administrative measures to ensure the adequate level of security in order to prevent unlawful processing of your personal data, to prevent unlawful access to your personal data and to ensure the protection of your personal data, and takes these measures to the maximum extent.

With subject to some restrictions and/or qualifications, you will have the right to:

(a) request the information on whether your personal data is processed or how it is processed (right to obtain information), (b) request information on the purpose of the processing and if the data is being used accordingly, (c) request information on national and international third parties that data is transferred to, (d) request the correction of your Personal Data, (e) request the deletion or destruction of your Personal Data in accordance with personal data processing, deletion and destruction policy if any, (f) request that the Actifit inform recipients of your Personal Data about the rectification or deletion of your Personal Data, (g) to object to automated processing using your Personal Data (if Actifit were to engage in these activities), (h) request limitation of processing; and (i) if Actifit were to process your Personal Data unlawfully, to request compensation from Actifit for any such unlawful processing.

You can fulfill these rights by sending and e-mail to info@actifit.com.tr. Actifit will respond to these requests in accordance with the data protection regulation in force.

If you believe that your Personal Data has been processed in violation of applicable data protection law and following the rejection of your application by Actifit, or receiving an insufficient reply or not receiving a reply in due time, you have the right to lodge a complaint with the data protection authority.

Personal Data Protection Authority

Adress: Nasuh Akar Mah. Ziyabey Cad. 1407. Sok. No: 4 06520 Balgat, Çankaya, Ankara

Phone: +90 312 216 5000

Website: http://www.kvkk.gov.tr/

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