PRIVACY POLICY
semaozpekmezci.com
(Disclosure Text Regarding the Protection and Processing of Personal Data)

1. IDENTITY OF THE DATA CONTROLLER

Pursuant to Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”), your personal data is processed, within the scope described in this Privacy Policy, by the party specified below acting as the data controller:

Name/Title: [Sema Özpekmezci / company name]
Address: [full address]
Email: info@semaozpekmezci.com
Website: www.semaozpekmezci.com

2. PERSONAL DATA WE COLLECT

2.1. General Personal Data

• Identity information: First name, last name
• Contact information: Email address, phone number, (if provided) address
• Transaction security information: IP address, browser/device information, cookie data, site usage/browsing logs
• Payment information: Order/invoice information (sensitive payment data such as card numbers is processed by the payment institution/bank, not by the SELLER; see Article 5)
• If you have given marketing consent: Your preference regarding e-newsletter/campaign communications

2.2. Special Categories of Personal Data (Health Data)

Information we may request from you within the scope of consulting/program services, such as eating habits, health history, existing conditions, laboratory results, height/weight, falls within the scope of “special category personal data” pursuant to Article 6 of the KVKK.

• This data is processed only for the purpose of providing you with the appropriate program/consulting service and with your explicit consent.
• This data is retained for the period required for the performance of the service and is not used for any purpose other than intended, nor shared with third parties (except for the exceptions in Article 5).
• You are not obligated to share this data; however, due to the nature of certain services (e.g., a personalized nutrition program), the service may not be able to be provided without this information.

3. METHOD OF COLLECTING PERSONAL DATA AND ITS LEGAL BASIS

Your personal data is collected electronically through the following channels:

• Order/membership/contact forms on our website,
• Correspondence via email, phone, or messaging applications,
• On-site cookies and analytics tools (e.g., services similar to Google Analytics),
• Order information transferred through the payment infrastructure provider.

This data is processed based on the legal grounds set out in Article 5 of the KVKK — “necessity for the establishment/performance of a contract,” “fulfillment of a legal obligation,” and “legitimate interest of the data controller”; and, with respect to special category data, based on your explicit consent pursuant to Article 6 of the KVKK.

4. PURPOSES OF PROCESSING PERSONAL DATA

• Providing and performing the Service you purchased (course, program, consulting),
• Carrying out order, payment, and invoicing processes,
• Preparing content/program recommendations suited to you (for health data, only within the scope of your explicit consent),
• Responding to customer support requests and maintaining communication,
• Sending e-newsletter, campaign, and promotional messages, where you have given explicit consent,
• Fulfilling legal obligations (tax, accounting, consumer regulations, etc.),
• Ensuring website security and preventing misuse.

5. TRANSFER OF PERSONAL DATA

Your personal data may be transferred to the following parties, limited to the purposes above and subject to necessary security measures:

Payment institution/bank: Your credit card information is processed directly by the payment institution/bank, in accordance with security standards such as 3D Secure and PCI-DSS; this information is not seen or stored by the SELLER.
Service providers: Technical infrastructure providers such as website hosting, email delivery/automation tools, and video conferencing platforms (e.g., Zoom) — only to the extent necessary for the performance of the service.
Authorized public institutions and organizations: In the event of a legal request or obligation (tax office, courts, regulatory bodies, etc.).

Your personal data is not shared with or sold to any third party for commercial purposes other than those listed above.

6. DATA RETENTION PERIOD

• Your personal data is retained for the period required for the relevant purpose and, in any event, for the statutory retention periods stipulated under applicable legislation (e.g., the Tax Procedure Law, the Turkish Commercial Code).
• Your health data is deleted, destroyed, or anonymized within a reasonable period after the performance of the service is completed; it is not retained indefinitely unless there is a legal retention obligation.
• Your marketing consent is retained until you withdraw it or until it ceases to be valid due to non-use for a reasonable period.

7. COOKIES

Our website may use cookies to improve user experience, analyze site traffic, and (if applicable) carry out advertising/promotional activities.

Necessary cookies: Required for the site’s core functions (login, cart, etc.) to work; cannot be disabled.
Analytics cookies: Enable the collection of statistics such as visitor count and browsing behavior.
Marketing/targeting cookies: Used only with your explicit consent/approval.

You can manage or completely reject cookies through your browser settings; however, in that case, some functions of the site may not work properly.

8. DATA SECURITY

Appropriate technical and administrative measures are taken to prevent the unlawful processing of your personal data and unauthorized access to it, and to ensure the security of the data. Payment transactions are carried out not by us, but through payment institutions holding the relevant security standards (PCI-DSS, etc.).

9. YOUR RIGHTS UNDER THE KVKK

Pursuant to Article 11 of the KVKK, we would like to note that by applying to the data controller, you have the right to:

• Learn whether your personal data is being processed,
• Request information regarding this, if it is being processed,
• Learn the purpose of processing and whether it is used in accordance with that purpose,
• Know the third parties to whom it is transferred domestically/abroad,
• Request correction if processed incompletely/incorrectly,
• Request deletion/destruction within the conditions set out in Article 7 of the KVKK,
• Request that correction/deletion be notified to third parties to whom the data has been transferred,
• Object to a result arising against you due to the exclusive analysis of processed data through automated systems,
• Request compensation for damages in the event you suffer harm due to unlawful processing.

Application Method

To exercise your rights above, you may submit your requests in writing, together with information verifying your identity, to info@semaozpekmezci.com. Your request will be concluded free of charge within 30 days at the latest, depending on its nature; if the transaction also requires an additional cost, a fee determined in the tariff set by the Personal Data Protection Board may be requested.

10. COMMERCIAL ELECTRONIC MESSAGES

Commercial electronic messages such as e-newsletters, campaign announcements, or program information will only be sent to you if you have given your explicit consent (including consent given through the İYS – Message Management System). You may withdraw this consent at any time by using the “unsubscribe” link in the message sent, or by writing to info@semaozpekmezci.com.

11. CHANGES TO THE POLICY

This Privacy Policy may be updated in line with changes in legal regulations or our business processes. The current text is always published at www.semaozpekmezci.com.

Last Updated: [dd/mm/yyyy]

This text is for general informational purposes only and does not constitute legal advice. It is recommended that you update Article 5 according to the specific tools you use (email marketing software, hosting provider, payment institution, etc.) and have the final text reviewed by legal counsel.