KVKK Privacy Notice (Coach) — version 4

This text explains how the coach's own personal data is processed. There is
a separate privacy notice and explicit consent text for the client's data.

What data is processed

• Identity and contact: name and surname, email.
• Business information: organization name, title.
• Public profile (optional): photo, biography, areas of expertise, city,

social media username. These fields are visible only when the coach opens
their profile to the public, and the coach can close it at any time.

• Usage records: sign-in time, IP address, action records.
• Product usage measurement: which step in the app was completed and when

(e.g. "sign-up completed", "program published"), the step's own numeric
information (e.g. the number of sessions in the program) and the time of the
event. These records are associated with your account.

NO HEALTH DATA and no free text goes into this measurement. Which event
names and which fields are accepted is limited in the software by a fixed
allow list; a field that is not on the list is rejected by the server. Client
notes, measurements, meal and message contents are never put into these
records under any circumstances.

Why it is processed

Establishing and performing the contract, providing the service, security and
fulfilling legal obligations.

Product usage measurement is also processed to improve the service: without
knowing how long each step takes, it is not possible to measure where the
interface gets stuck. The legal basis is KVKK art. 5/2-f (legitimate interest);
the measurement is not used for personalized advertising or profiling and is
not transferred to a third-party advertising network.

To whom it is transferred

To the providers from which hosting, error tracking and email delivery services
are obtained, only to the extent the service requires. The public profile is
opened to the internet by the coach's own choice.

How long it is kept

As long as the account is open; after the account is closed, for the legal
retention periods (10 years for commercial and tax records), after which it is
deleted.

Product usage measurement is kept for at most 24 months, then deleted. When
the account is deleted, these records are deleted together with the account.

Transfer abroad

The artificial intelligence service used to generate program drafts, interpret
posture measurements and estimate items from meal photos is located abroad.
The coach's own identity data is not sent to this service. The data sent
belongs to the client: de-identified measurement and health information,
posture angles calculated on the phone and — only if the client has given a
separate explicit consent — the meal photo. Posture, body and workout photos
are not sent (details: Data Processing Agreement §4). Sub-providers are limited
to the USA and the EU.

Your rights

Under KVKK article 11, you have the right to access your data, have it
corrected, have it deleted, object to its processing and learn where it has
been transferred. You can use the contact channel in the app for your requests.

Objection to product usage measurement is made from within the app: when
the switch under Settings > "Product usage measurement" is turned off, no
record is sent from that device and records waiting to be sent are also
deleted. In addition, from the Settings > My data screen you can download a
machine-readable copy of the data in your account, and from the same screen you
can permanently delete your account and all your data.