Clarification Text

This Privacy Notice has been prepared within the scope of the Personal Data Protection Law No. 6698 (“KVKK”) in order to provide customers (“Data Subject”) benefiting from SPA, wellness, longevity, beauty, personal care, analysis, assessment, consultancy and similar services offered by EXIM Yatırım ve Mağazacılık A.Ş. (“Longevity Türkiye/Company”) with information regarding the processes, methods and purposes of the collection, processing, storage, protection and destruction of their personal data, as well as their rights under the Law and the methods of exercising such rights.

Data Controller: EXIM Yatırım ve Mağazacılık A.Ş.
Address: 19 Mayıs Mah. Hamidiye Suyu Sk. No: 1 İç Kapı No: 4 Şişli / İstanbul
MERSIS No: 0769057929000015
Trade Registry No: 866383
Tel: 0(212) 227 68 11
Website: https://thelongevitysuite.com.tr/

1. Which Personal Data Do We Process?

Within the scope of benefiting from the services offered by us, we may process the following categories of your personal data:

• Identity Information: Name, surname, date of birth, Turkish ID number, passport information (where necessary),
• Contact Information: Telephone number, e-mail address, address,
• Customer Transaction Information: Membership information, reservation and appointment records, information regarding purchased services, program preferences, payment and invoice information, request and complaint records,
• Financial Information: Information regarding payment, collection and invoicing processes,
• Health Data (Special Category Personal Data): Health declarations shared by you, medical history, information regarding current illnesses and allergies, information regarding medications used, lifestyle and nutrition information, analysis and assessment results, and other health data required for planning the service and program suitable for you,
• Visual Data: Camera recordings obtained for the purpose of providing services or ensuring security, as well as photographs and images shared by you,
• Transaction Security Information: Log records, IP address, device information and other transaction security data generated during the use of our website and other digital platforms,
• Legal Transaction Information: Information processed within the scope of carrying out requests, complaints, disputes and legal proceedings.

2. How Do We Collect Your Personal Data?

Your personal data processed within the scope of benefiting from the services offered by Longevity is collected directly from you, through our representatives, employees or various channels, in accordance with the provisions of the relevant applicable legislation, by all kinds of written, verbal and electronic means, through video recordings, audio recordings, the completion of forms on the website or other forms belonging to our Company, cookies on our website, the call center, telephone, agreements, surveys, interviews, electronic/digital platforms and websites, online channels including social media platforms, e-mail, sales, marketing or support units, events or other means. Collected Personal Data may be recorded in physical form in closed and/or secure areas such as unit/department cabinets or archives, while electronic data may be recorded in software, cloud systems, central servers or the Company database. Personal Data may also be recorded on peripheral systems such as network devices, flash-based media, magnetic tape, magnetic disks, mobile phones, optical disks, printers and access control/security systems.

We may process your Personal Data wholly or partially by automated means based on the legal grounds set forth under Article 5 of the Law, namely “being expressly provided for by law”, “being necessary to process the personal data of the parties to a contract, provided that it is directly related to the establishment or performance of the contract”, “being mandatory for the data controller to fulfil its legal obligation”, “being mandatory for the establishment, exercise or protection of a right”, “being mandatory for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed”, or “explicit consent”.

3. For Which Purposes Do We Process Your Personal Data?

We may process your personal data for the following purposes in connection with the purposes specified under Articles 5 and 6 of the Law.

• Carrying out membership processes, carrying out reservation, appointment and session planning processes, planning, carrying out and monitoring the services offered, creating and implementing programs suitable for the customer, carrying out analysis, assessment and consultancy processes, carrying out coordination processes with business partners
• Carrying out emergency management processes, carrying out information security processes, carrying out audit / ethics activities, carrying out risk management processes, carrying out training activities, managing access authorizations, carrying out strategic planning activities, creating and monitoring visitor records
• Carrying out activities in compliance with legislation, carrying out finance and accounting operations, ensuring physical premises security, carrying out / auditing business activities, receiving and assessing suggestions for the improvement of business processes, organization and event management, carrying out contract processes, carrying out remuneration policy, carrying out management activities
• Ensuring website security, website usage analysis, responding to requests submitted through the contact form on the website
• Fulfilling legal and contractual obligations, monitoring and carrying out legal affairs, carrying out internal audit / investigation / intelligence activities, monitoring requests / complaints, providing information to authorized persons, institutions and organizations, carrying out communication activities, carrying out activities aimed at customer satisfaction,

. 4. To Whom and For Which Purposes Do We Transfer Your Personal Data?

Your personal data held by our Company may be transferred, in accordance with the provisions of the KVKK regarding the transfer of personal data, to the following recipient groups located in Türkiye or abroad, in line with the processing purposes specified above.

• Legal Advisors, Payroll Company, Certified Public Accounting Company from Which Services Are Received, Suppliers: Personal Data may be transferred to the companies/persons from which services are received as specified in this article, limited to the data and purposes required to be processed within the scope of the products, services and services received and the commercial, legal and contractual relationship established with such persons.
• Natural Persons or Private Law Legal Entities: Personal Data may be transferred to private law persons legally authorized to request information and/or documents from our Company, limited to their requests and what is legally required to be disclosed.
• Business Partners: Personal Data may be transferred to business partners for the establishment of the business partnership and/or fulfilment of the purpose of cooperation, in a manner suitable for and limited to such purpose
• Shareholders and Executives: Personal Data may be shared with shareholders, limited to the purposes of monitoring activities, determining and developing commercial strategies, carrying out audits and providing information to shareholders.
• Company Employees: Personal Data may be transferred to other Company Employees for the purpose of enabling communication among Employees.
• Authorized Public Institutions and Organizations: Personal Data may be transferred to legally authorized public institutions and organizations, limited to their requests and the information legally required to be disclosed.

5. What Are Your Rights as a Data Subject?

By applying to our Company, you have the rights to;

• Learn whether your Personal Data is processed,
• Request information if your Personal Data has been processed,
• Learn the purpose of processing your Personal Data and whether it is used in accordance with such purpose,
• Know the third parties to whom your Personal Data is transferred in Türkiye or abroad,
• Request the correction of your Personal Data if it has been processed incompletely or incorrectly and request that the action taken in this respect be notified to third parties to whom your Personal Data has been transferred,
• Request the deletion or destruction of your Personal Data if the reasons requiring its processing cease to exist, despite having been processed in accordance with the Law and other relevant legislation, and request that the action taken in this respect be notified to third parties to whom your Personal Data has been transferred,
• Object to the emergence of a result against you through the analysis of your processed Personal Data exclusively by automated systems,
• Request compensation for damages if you suffer damage due to the unlawful processing of your Personal Data,

you have such rights.

However, pursuant to Article 28/2 of the Law, except for your right to request compensation for damages, you may not exercise the rights listed above in the following cases:

• Where the processing of personal data is necessary for the prevention of a crime or for a criminal investigation.
• Processing of personal data made public by the data subject himself/herself.
• Where the processing of personal data is necessary for the performance of supervisory or regulatory duties and disciplinary investigation or prosecution by authorized and competent public institutions and organizations and professional organizations with public institution status, based on the authority granted by law.
• Where the processing of personal data is necessary for the protection of the economic and financial interests of the State in relation to budgetary, tax and financial matters.

6. What Are the Methods for Exercising Your Rights?

By applying to Longevity Türkiye, you may at any time submit your requests regarding your personal data processed by us within the scope of Article 11 of the KVKK, in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller, in writing or by using a secure electronic signature, mobile signature or the e-mail address previously notified to us and registered in our system, to the addresses specified below:

Address: 19 Mayıs Mah. Hamidiye Suyu Sk. No: 1 İç Kapı No: 4 Şişli / İstanbul
e-mail: [email protected]