Draft text. This page must not be published until it has been approved by legal counsel. Fields in square brackets must be filled in with company information.
1. Data controller
Under Personal Data Protection Law No. 6698 (“KVKK”), your personal data is processed, in the capacity of data controller, by [data controller trade name] (“Hybrid”, “the Club”) within the scope described below.
Address: [full address] · Email: [KVKK email address] · VERBİS registration: [registration number, if any]
2. Personal data processed
| Data category | Example data |
|---|---|
| Identity | First name, last name, date of birth |
| Contact | Phone number, email address |
| Customer transaction | Membership and package information, session attendance records, payment records |
| Health (special category) | Only with your explicit consent: injury history, physician restrictions, conditions preventing exercise |
| Performance | Level test results, training and measurement records |
| Transaction security | IP address, cookie records, site usage data |
| Visual records | Only with your explicit consent: event and training photos/videos |
3. Purposes of processing
- Establishing and performing the membership agreement, managing session bookings
- Preparing personalized training programs and tracking progress
- Ensuring exercise safety and assessing health risks
- Handling requests and complaints, carrying out communication activities
- Fulfilling financial, accounting, and legal obligations
- Promotional and marketing activities, if you give explicit consent
4. Legal grounds
Under KVKK Art. 5/2, your personal data is processed on the legal grounds that it is directly related to the establishment or performance of a contract, that it is necessary for the data controller to fulfill its legal obligation, and the data controller’s legitimate interest; your special-category health data and visual records are processed under KVKK Art. 6 solely on the basis of your explicit consent .
5. Transfers
Your personal data may be transferred, within the framework of KVKK Art. 8 and Art. 9, to suppliers we work with to deliver the service (payment institution, membership software, hosting provider), to authorized public institutions and organizations, and to the relevant authorities where legally required. If data is transferred abroad, the conditions set out in the KVKK are complied with.
6. Retention period
Your personal data is retained for as long as required by the purpose of processing and for the statute of limitations periods set out in the relevant legislation; when that period expires, it is deleted, destroyed, or anonymized.
7. Your rights
Under KVKK Art. 11, you have the right to learn whether your personal data is processed; to request information if it has been processed; to learn the purpose of processing and whether it is used for that purpose; to know the third parties in Turkey or abroad to whom it is transferred; to request correction if it is incomplete or inaccurate; to request its deletion or destruction; to request that these actions be notified to third parties to whom it was transferred; to object to an outcome against you arising from analysis exclusively by automated systems; and to claim compensation if you suffer damage.
You can send your requests to [KVKK email address] . Applications are concluded within thirty days at the latest.
