GENERAL DISCLOSURE NOTICE PURSUANT TO THE LAW ON THE PROTECTION OF PERSONAL DATA NO. 6698 (KVKK)
As Esform Sports Athletic Facilities and Healthy Living Services ("Esform Sports" or the "Company"), acting in the capacity of Data Controller under the Law on the Protection of Personal Data No. 6698 ("KVKK") and related secondary legislation, we process and protect the personal data of our club members, athletes, visitors, digital platform users, and partners lawfully, ethically, and in strict adherence to good faith under constitutional safeguards.
This Disclosure Notice has been prepared pursuant to Article 10 of the KVKK and the Communiqué on the Principles and Procedures to be Followed in Fulfilling the Obligation to Inform to notify you regarding the collection methodologies, processing purposes, legal grounds, potential transfers, and statutory rights concerning your personal data.
1. Identity of the Data Controller
Your personal data is processed by Esform Sports acting as Data Controller with the following registered identity and contact credentials:
- Data Controller: Esform Sports Athletic Facilities and Healthy Living Services
- Headquarters: Ihlamurkent Mah. Nilufer Cd. No:20/B Odunpazari / ESKISEHIR / TURKEY
- Operational Facilities: Bursa Yildirim Branch, Eskisehir Odunpazari Branch, Karabuk 100th Year Branch, Kastamonu Kuzeykent Branch
- Phone: +90 (501) 367 67 04
- Official Email: kvkk@esformsports.com
2. Categories of Processed Personal Data
Personal data processed in connection with facility memberships, online inquiries, or web browsing encompasses:
- Identity Data: Full name, national identity number (for formal membership contracts), birth date, biological gender.
- Contact Data: Mobile telephone number, email address, residential address, emergency contact name and phone number.
- Customer Transaction & Membership Data: Designated club branch, membership tier, contract commencement and expiry dates, enrolled fitness disciplines, turnstile check-in/out logs.
- Financial Data: Selected payment method, invoicing records, wire transfers, installment schedules (credit card credentials are never stored by our systems; transactions are handled securely by PCI-DSS compliant licensed payment gateways).
- Physical Venue Security Data: Continuous closed-circuit television (CCTV) video footage recorded at facility entrances, reception desks, common hallways, and exercise floors.
- Special Categories of Personal Data (Health & Biometric Measurements): Medical fitness declaration, chronic condition disclosures, height, weight, body fat/muscle ratio metrics, and 3D spinal posture evaluations (processed exclusively upon explicit consent under coach supervision).
- Digital Security Data: IP addresses, web access logs, browser cookies, and conversation histories from our ESFORM AI chatbot.
3. Purposes of Processing Personal Data
In adherence to the core principles set forth under Article 4 of the KVKK (lawfulness, proportionality, data accuracy, purpose limitation), your data is processed for:
- Formulating and executing membership contracts and provisioning digital access passes,
- Designing personalized, scientifically grounded exercise and nutritional regimens,
- Preventing sports-induced injuries through anatomical assessment and enabling rapid emergency medical interventions,
- Maintaining physical security, facility hygiene, and order across all club branches,
- Complying with mandatory fiscal, financial, and tax reporting requirements,
- Responding to online pre-registrations, feedback, and customer support inquiries,
- Subject to your explicit consent, broadcasting updates on new branch openings and group workout schedules.
4. Processing of Special Categories of Personal Data (Health Data)
Pursuant to Article 6 of the KVKK, physical health metrics constitute sensitive personal data. Health assessments, medical fitness declarations, and posture analyses collected to safeguard your physical well-being are processed:
- Exclusively with the explicit consent of the data subject,
- Under strict technical safeguards prescribed by the Personal Data Protection Board,
- Restricted solely to certified fitness instructors and health consultants on a strict need-to-know basis.
5. Video Surveillance Notice (CCTV)
To uphold facility security and deter criminal activities, 24/7 CCTV surveillance operates in common zones across all branches.
STRICT PRIVACY GUARANTEE: Changing rooms, shower cabins, saunas, and restroom facilities are STRICTLY EXCLUDED from video surveillance. Personal privacy is absolute. Surveillance recordings are automatically overwritten following regulatory retention terms.
6. Transfer of Personal Data
In compliance with Articles 8 and 9 of the KVKK, data may be transferred to:
- Judicial and Public Authorities: Strictly pursuant to statutory duties and court orders,
- Emergency Healthcare Services (112): In the event of medical emergencies occurring on premises,
- Financial Institutions: Licensed banks and payment clearing houses for transaction settlement,
- Domestic IT Providers: Encrypted hosting and cloud computing vendors.
7. Data Subject Rights Under Article 11 of the KVKK
Under Article 11 of the KVKK, you possess the right to:
- Learn whether your personal data is processed,
- Request information regarding processed data,
- Ascertain processing purposes and compliance with those objectives,
- Know domestic or international third-party recipients,
- Demand rectification of incomplete or inaccurate data,
- Request erasure or destruction of data under statutory conditions,
- Request notification of rectification or erasure to third-party transferees,
- Object to detrimental outcomes arising exclusively from automated processing,
- Claim compensation for damages sustained due to unlawful processing.
8. Application Methods
To exercise your statutory rights, you may submit formal requests via:
- In Person / Physical Mail: Hand-delivering an ink-signed petition with photo identification to our Bursa, Eskisehir, Karabuk, or Kastamonu branches, or through a notary public.
- Electronic Mail: Emailing kvkk@esformsports.com from your registered email address on file.
Requests will be concluded free of charge within thirty (30) days at the latest.
