VONDEL USER PRIVACY NOTICE
This English version is provided for information purposes only. In case of any discrepancy between the Turkish and English versions, the Turkish version shall prevail.
Identity of the Data Controller:
Yiğit Ünalan, operating under the name "Vondel", located at İdealtepe Mah. Cuma Sk. Elif İdealist No: 1 İç Kapı No: 5 Maltepe/İstanbul, registered with the Küçükyalı Tax Office under tax number 9120309518 ("Vondel" or the "Data Controller")
This User Privacy Notice has been prepared to inform users who use the Vondel mobile application (the "Application") individually, and users invited to the Application within the scope of use by our corporate customers (the "User").
Data Categories:
Identity Information: Name and surname, date of birth/age, gender, nickname
Contact Information: E-mail address
Customer Transaction Information: Membership and subscription information, purchase records, corporate use and seat information, information on the affiliated corporate customer and department
User Activity Information: Activity level, equipment and goal preferences, exercise program and exercise records, difficulty ratings, feedback, chat module records, notification preferences, ranking and competition information (number of active days, ranking, applause and votes), application usage records
Transaction Security Information: Password, user number, login records, IP address, device and application version information, device notification token
Request and Complaint Information: Other requests and complaints regarding products and services, content of requests and complaints
Legal Transaction Information: Records of privacy notices, explicit consents and data subject applications, other information and documents that may be requested by the competent authorities
Special Category Personal Data (Health Information): Height, weight, answers to the pain/discomfort questionnaire, photographs and images taken within the Application for posture analysis and fitness tests together with posture analysis results, fitness test measurements and results, pain and discomfort reported during exercise, digital recognition model findings, exercise competition scores, health information shared in the chat module and in request/complaint processes, and health information as well as psychosocial and physical information reported within the Application through other means such as tests, questionnaires or information forms
In Which Business Processes and for Which Purposes Personal Data Are Used, and Their Legal Grounds
Identity information, contact information, customer transaction information, user activity information, transaction security information, and request and complaint information are processed for the following purposes under Article 5(2)(c) of the KVKK, namely that the processing of personal data belonging to the parties of a contract is necessary, provided that it is directly related to the establishment or performance of that contract:
Creating and managing the membership account, ensuring authentication and session security, providing the Application services within the scope of the terms of use, providing the exercise program to the User and keeping exercise records, sending exercise reminder notifications, carrying out in-app purchase and subscription processes, carrying out request and complaint processes, carrying out User information processes
Identity information, contact information, customer transaction information, user activity information, transaction security information, request and complaint information, and legal transaction information are processed for the following purposes under Article 5(2)(ç) of the KVKK, namely that processing is mandatory for the Data Controller to fulfil its legal obligation:
Carrying out information security processes, keeping records of privacy notices, explicit consents and data subject applications, responding to data subject applications, keeping records of the erasure, destruction and anonymisation of personal data, carrying out finance and accounting activities, providing information to authorised institutions and organisations
Identity information, contact information, customer transaction information, user activity information, transaction security information, request and complaint information, and legal transaction information are processed for the following purposes under Article 5(2)(e) of the KVKK, namely that processing is mandatory for the establishment, exercise or protection of a right:
Conducting legal proceedings, sharing relevant information and documents in the event of a dispute
Contact information, customer transaction information, user activity information, and transaction security information are processed for the following purposes under Article 5(2)(f) of the KVKK, namely that processing is mandatory for the legitimate interests of the Data Controller, provided that it does not harm the fundamental rights and freedoms of the data subject:
Inviting Users to the Application and managing seats within the scope of use by our corporate customers, reporting anonymised aggregate results to corporate customers, developing and improving the Application through statistical analysis of application usage records
Identity information (nickname), customer transaction information (department), and user activity information (ranking and competition information) are processed with your explicit consent for the following purpose under Article 5(1) of the KVKK, which provides that "Personal data shall not be processed without the explicit consent of the data subject.":
Conducting in-company rankings and competitions within the corporate customer
Special category personal data (height, weight, answers to the pain/discomfort questionnaire, photographs and images taken within the Application for posture analysis and fitness tests together with posture analysis results, fitness test measurements and results, pain and discomfort reported during exercise, digital recognition model findings, health information shared in support requests) are processed with your explicit consent for the following purposes under Article 6(3)(a) of the KVKK, namely that the processing of special category personal data is prohibited but may be carried out where the data subject has given explicit consent:
Creating your health profile, performing posture analysis, evaluating fitness tests, preparing and updating the digital recognition model and the personalised exercise program, using the health information you share in your support requests solely to respond to the relevant request
Special category personal data (health information shared in the chat module, health profile and digital recognition model findings) are processed with your explicit consent for the following purposes under Article 6(3)(a) of the KVKK, namely that the processing of special category personal data is prohibited but may be carried out where the data subject has given explicit consent:
Answering User questions via the chat module by using an artificial intelligence language model service, review by the Vondel team of answers flagged as incorrect
Special category personal data (exercise competition scores) are processed with your explicit consent for the following purpose under Article 6(3)(a) of the KVKK, namely that the processing of special category personal data is prohibited but may be carried out where the data subject has given explicit consent:
Conducting in-company rankings and competitions within the corporate customer
Posture analysis, fitness test evaluation, the digital recognition model, the exercise program and the chat module answers are created and updated through automated systems on the basis of the data provided by the User, and do not constitute medical diagnosis or treatment.
To Whom and for Which Purposes Personal Data May Be Transferred
Identity information, contact information, customer transaction information, user activity information, transaction security information, and request and complaint information are transferred to suppliers for the following purposes under Article 5(2)(c) of the KVKK, namely that the processing of personal data belonging to the parties of a contract is necessary, provided that it is directly related to the establishment or performance of that contract:
Carrying out the service procurement process, obtaining IT and software services for the continuity, operation and development of the Application
Special category personal data are transferred to suppliers with your explicit consent for the following purpose under Article 8(1) of the KVKK, which provides that "Personal data shall not be transferred without the explicit consent of the data subject.":
Obtaining IT and software services for the continuity and operation of the Application
Transaction security information (user number), user activity information (exercise program and exercise records, chat module records), and special category personal data (health information shared in the chat module, health profile and digital recognition model findings) are transferred to suppliers located abroad with your explicit consent for the following purpose under Article 9(6)(a) of the KVKK, namely that the data subject gives explicit consent to the transfer, provided that he/she has been informed of the possible risks:
Answering User questions via the chat module by using an artificial intelligence language model service
Contact information and customer transaction information (seat allocation status within the scope of use) are transferred to corporate customers for the following purposes under Article 5(2)(f) of the KVKK, namely that processing is mandatory for the legitimate interests of the Data Controller, provided that it does not harm the fundamental rights and freedoms of the data subject:
Managing seats within the scope of use and carrying out reconciliation processes relating to use
Identity information (nickname), customer transaction information (department), user activity information (ranking and competition information), and special category personal data (exercise competition scores) are transferred with your explicit consent to other Users within the same corporate customer for the following purpose under Article 8(1) of the KVKK, which provides that "Personal data shall not be transferred without the explicit consent of the data subject.":
Conducting in-company rankings and competitions
Identity information, contact information, customer transaction information, user activity information, transaction security information, request and complaint information, and legal transaction information are transferred to legally authorised public institutions and organisations for the following purposes under Article 5(2)(ç) of the KVKK, namely that processing is mandatory for the Data Controller to fulfil its legal obligation:
Fulfilling obligations arising from legislation, responding to requests for information and documents from judicial and administrative authorities
Special category personal data are transferred to legally authorised public institutions and organisations for the following purpose under Article 6(3)(b) of the KVKK, namely that the processing is explicitly provided for by law:
Responding to requests for information and documents from judicial and administrative authorities that are based on law
Identity information, contact information, and customer transaction information are transferred to suppliers for the following purpose under Article 5(2)(ç) of the KVKK, namely that processing is mandatory for the Data Controller to fulfil its legal obligation:
Carrying out finance and accounting activities
Identity information, contact information, customer transaction information, user activity information, transaction security information, request and complaint information, and legal transaction information are transferred to suppliers for the following purposes under Article 5(2)(e) of the KVKK, namely that processing is mandatory for the establishment, exercise or protection of a right:
Conducting legal proceedings and obtaining legal consultancy services
Notifications and in-app purchases are carried out through the infrastructure of the mobile operating system and app store provider you use; the servers of these providers may be located abroad, and the provider processes the device notification token and purchase transaction information in this context on its own behalf within the framework of its contract with you.
Methods of Collecting Your Personal Data
Your personal data listed above are collected through the Application, our website, e-mail and other communication channels, our corporate customers and mobile app stores, in physical or electronic form depending on the method by which you provide them to us, by fully or partially automated or non-automated means, and are processed and transferred for the purposes stated above. Your personal data are retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed; at the end of these periods they are erased, destroyed or anonymised.
The Rights of Data Subjects Regarding Their Personal Data and How They Can Exercise These Rights
Pursuant to Article 11 of the KVKK, you may exercise the following rights by applying to us: to learn whether your personal data are processed; to request information if they have been processed; to learn the purpose of processing and whether they are used in accordance with that purpose; to know the third parties to whom they are transferred; to request correction if they are processed incompletely or inaccurately; to request their erasure or destruction; to request that these operations be notified to the third parties to whom they have been transferred; to object to a result against you arising from the analysis of your data exclusively through automated systems; and to request compensation for damages if you suffer damage due to unlawful processing.
To exercise your rights, you may apply in writing to İdealtepe Mah. Cuma Sk. Elif İdealist No: 1 İç Kapı No: 5 Maltepe/İstanbul or via the e-mail address info@vondelexcellence.com. For additional application methods and more detailed information, please see the Data Subject Application Form.
If your application requires an additional cost, a fee may be charged in accordance with the tariff determined by the Personal Data Protection Board.
Updating Information
It is important that your personal data processed by Vondel are kept accurate and up to date. Therefore, if there is any change in your information qualifying as personal data, you may notify Vondel through the Application, in writing, or through the Data Subject Application Form published on our website.
Date of Update: November 2026