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PRIVACY POLICY

We, as SELF GRUP TEKNOLOJİ LTD. ("SELF"), care about your personal data and it is our principle to protect the personal data of the visitors of our website www.beself.com.tr and our app "Self App". This privacy policy (the "Privacy Policy") describes the type of user data collected by SELF through using our website and our app as well as the ways these are processed and protected.

SELF reserves the right to make amendments to this Privacy Policy and these will be published on this page. The updated policy will take effect on the date it is published on our website and our app.

We reserve the right to and may change this Privacy Policy from time to time. If we make any material changes, we will notify you by email (sent to the email address provided when you register), through the Self App, or by presenting you with a new version of this Privacy Policy. If permitted by applicable law, your continued use of the services after the effective date of an updated version of the Privacy Policy will indicate your acceptance of the Privacy Policy as modified. In some cases, you will be given a choice about whether to explicitly accept changes to the Privacy Policy. If you do not accept the terms of the Privacy Policy, please do not use the website or the Self App.

Data Controller

SELF GRUP TEKNOLOJİ LTD.
Address: Konutkent Mah. Sisa Kule 381 / AK Çankaya

Collecting, Processing and Transfer of Personal Data

We collect Personal Data about you in a variety of ways. Sometimes we collect Personal Data automatically when you interact with the web site or the Self App, and sometimes we collect the Personal Data directly from you. At times, we may receive Personal Data about you from other sources and third parties.

Personal Data you provide to us directly:

General Information

When you sign up to use the Services, we may collect Personal Data about you such as:

  • Name;
  • Email address;
  • Year of birth;
  • Password or passcode;
  • Place of residence and associated location information including time zone and language;

In many cases, we may be able to infer your gender by your use of the Services.

Health and Well-being

When you sign up to use the web site or the Self App, you may choose to provide Personal Data about your health and well-being such as:

  • Weight;
  • Body temperature;
  • Menstrual cycle dates;
  • Fitness data;
  • Various symptoms related to your menstrual cycle, pregnancy and health;
  • Dietary choices;
  • Other information about your health physical and mental well-being, and related activities, including personal life.

You may also allow us to connect to third-party services, such as Apple HealthKit and Google Fit, to enable us to import Personal Data about your health and activities into the Self App. This imported data may include sports activities, weight, calories burned, heart rate, number of steps/distance traveled, and other data about your health. We will process this data in order to provide you with the App functionality described below. When you choose to have this data imported you are subject to the Google Fit and Apple HealthKit privacy policies and practices.

Personal Data We Collect Automatically:

When you access or use the web site or the Self App, we may automatically collect the following information:

Device Information:

  • Device model;
  • Information about the operating system and its version;
  • Unique device identifiers (e.g. IDFA);
  • Enabled device accessibility features (e.g. display features, hearing features, physical and motor features);
  • Mobile operator and network information;
  • Device storage information;
  • Version of your device system.

Location Information:

  • IP address;
  • Time zone;
  • Information about your mobile service provider.

Data about your use of the Services:

  • Frequency of use;
  • Areas and features of the Services that you access, visit or use;
  • Engagement with particular features.

To collect this and other information, we may use cookies and other tracking technologies. See more in our Cookie Policy.

Data from external sources

We may receive Personal Data about you from third parties. For example, we may obtain information from third parties, to enhance or supplement existing user information, including to customize and personalize your experience and for statistical purposes and analytics, as described below.

How we use your Personal Data

We will not collect and use your Personal Data without letting you know. Depending on which features of the web site or the Self App you use, we will process your Personal Data based on one or more of the following legal bases:

  • Your consent. For example, on the registration screen when you give us permission to process your Personal Data;
  • To fulfill our contractual obligations to you in order to provide the Services to you;
  • Legitimate interest. We may process your Personal Data in relation to our interests in providing the web site or the Self App to you, our commercial interests, including our interest in protecting the security and integrity of the web site or the Self App, and wider societal benefits;
  • Legal obligation. We may be obligated to process some of your Personal Data to comply with applicable laws and regulations.

Principles of Processing

Data minimization and purpose limitation. We will not process Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you or collect any Personal Data that is not needed for the mentioned purposes. For any new purpose of processing, we will ask your separate consent.

No sale of Personal Data. We will not sell or rent your Personal Data. We will not disclose your Personal Data except as otherwise described in this Privacy Policy. We may share your Personal Data with our service providers solely as described in this Privacy Policy.

Legal Basis for Processing (Art. 6 & 9 GDPR)

  • Explicit Consent: Since "self" tracks nutrition, sleep, and exercise (Special Categories of Personal Data), we process this information only after obtaining your explicit consent.
  • Contractual Necessity: To provide the core "Habit Formation and Wellness Tracking" services.
  • Compliance: To fulfill legal obligations related to data security.

Detailed Data Processing Activities

AI and Automated Decision-Making: We use machine learning algorithms to calculate your "Wellness Score." This process involves analyzing your biological data to offer behavioral suggestions. You have the right to challenge any automated decision that significantly affects you.

Wearable Integration: With your permission, "self" retrieves data from third-party health apps (Apple Health, Google Fit). We only store the data necessary for your wellness systems.

Data Minimization: We follow the "privacy by design" principle. We only collect data that is strictly necessary for your chosen systems (Nutrition, Sleep, Exercise).

Data Subject Rights (Chapter 3 GDPR)

  • Right of Access (Art. 15): Request a copy of all data "self" holds about you.
  • Right to Erasure (Art. 17): Also known as the 'Right to be Forgotten'. You can delete your account and all associated health records instantly via app settings.
  • Right to Restriction of Processing (Art. 18): Ask us to stop processing your data while keeping it stored.
  • Right to Data Portability (Art. 20): Receive your health logs in a machine-readable format to move them to another service.

Security Measures

We implement industry-standard AES-256 encryption for data at rest and TLS 1.3 for data in transit. Access to sensitive health data is strictly limited to authorized personnel and systems.

Your Rights as Personal Data Subject

Under the personal data protection laws and any other legislation in force you are entitled to:

  • Request information whether or not your personal data are processed;
  • Request information if your personal data have been processed;
  • Request information about the purpose of processing and if your personal data have been used for the purposes described,
  • Receive information about the third parties whom your personal data are transferred in Turkey and abroad;
  • Request correction of your personal data if they are inaccurate or incomplete;
  • Request deletion or destruction of your personal data in accordance with the personal data protection legislation;
  • Request notification is made to the third parties about correction, deletion and destruction of your personal data in accordance with the relevant legislation;
  • Object to any result against you arising from analysis of the processed data by automated systems only,
  • Request compensation for the damages arising from unlawful processing of your personal data.

You may send us your requests relating to your abovementioned rights by email or post at support@beself.com.tr, respectively.

Your request must be clear in your application that you will make in order to exercise your abovementioned rights as the data subject and your application must include an explanation of the right requested to be exercised.

If your request is personal, your application must include your identity information and address details and the documents confirming your identity must also be attached.

However, in case you are acting on behalf of another person, you must have the exclusive authority to do so and your authority must be documented. Again, in this case, the application should include the identity information and address details of the relevant person and the documents confirming the identity of both yourself and the person you are acting on behalf must also be attached.

Based on the nature of your request, your application will be resolved as soon as possible within thirty days at the latest and free of charge. If, however, the relevant action requires additional costs, you may be charged a fee based on the tariff to be determined by the Personal Data Protection Board.

Third Parties Processing Your Personal Data

We will not share your Personal Data with third parties except as specified below.

Processing to make the App run

In some situations, we engage other companies to process your Personal Data on our behalf. We refer to these companies as "processors."

Processors are companies that help us run the Services, support our communication with you or perform other App-related activities. They may process certain Personal Data on our behalf to accomplish the goals related to the App functions and associated activities. We remain responsible for any acts or omissions of our processors and undertake to execute formal data processing agreements with them to the extent required by applicable law.

Here is the list of our main processors upon which we rely:

  • AWS (Amazon Web Services, Inc.); process all Personal Data for storage of all Personal Data when you use the App

Contact

If you have any questions or concerns about your privacy you may contact us at:

SELF GRUP TEKNOLOJİ LTD.
Konutkent Mah. Sisa Kule 381 / AK Çankaya
Email: support@beself.com.tr