As Yönetim Zamanı Eğitim Danışmanlık Ticaret Limited Şirketi (the "Company"), the operator of the Walk & Talk mobile application, we care about the privacy and security of our users' personal data.
Personal data collected through our mobile application and related communication channels is processed in accordance with the Personal Data Protection Law No. 6698 ("KVKK").
1. Collection and Processing of Personal Data and Purposes of Processing
Your membership and contact information, application usage and transaction records, step count data, and discount and campaign usage information may be processed for the following purposes, depending on which features you use:
- Creating and managing your user account and membership profile,
- Displaying your daily step count in the application,
- Providing information about your step count and messages that encourage walking in the motivation window shown when you open the application,
- Determining whether you have met the step targets set out in the campaign terms under "Pay with Steps" ("Adımla Öde"),
- Calculating, verifying and tracking the use of step-based discount and campaign entitlements,
- Responding to customer support requests and performing the contractual relationship,
- Ensuring the security of the application and your account,
- Fulfilling the Company's legal obligations and establishing, exercising or protecting a right,
- Sending you campaign, product and service promotions, subject to your permissions and consents.
2. Access to Health and Step Data, and Collection and Use of This Data
Data accessed and method of access
To display your daily step count, show the motivation window when you open the application and operate the "Pay with Steps" feature, Walk & Talk reads only your step count data, based on the access permission you grant on your device, through:
- Apple HealthKit on iOS devices,
- Google Health Connect on Android devices.
Under these integrations, your heart rate, sleep, weight or other health data is not accessed. Walk & Talk does not write data to HealthKit or Health Connect and does not change your data in these sources.
Purposes of using step data
Your step count data is used for the following purposes:
- Displaying your daily steps in the application,
- Providing information about your step count and messages that encourage walking in the motivation window shown when you open the application,
- Checking whether you meet the step requirement of the "Pay with Steps" campaign,
- Determining, verifying and tracking the use of the related discount or campaign entitlement.
Recording of step data
Your step count data is recorded in a database on the Firebase infrastructure as part of the operation of the motivation window shown when you open the application, and when you use the "Pay with Steps" campaign.
Data recorded for the motivation window is used to provide information about your step count and messages that encourage walking. Data recorded during campaign use is used to verify that the campaign conditions have been met and to track campaign use.
Your step data is not used for advertising targeting or personalized marketing.
Managing access permissions and explicit consent
You can manage or revoke your HealthKit or Health Connect access permissions through the relevant application and permission settings on your device. If you revoke access, the application can no longer read new step data from these sources. As a result, the step information in the motivation window may not be updated, and campaign conditions that depend on step data may not be verifiable.
You can withdraw your explicit consent to the processing of your step data through the contact channel below. Withdrawing explicit consent does not affect the lawfulness of processing carried out before the date of withdrawal.
Revoking device access permission does not automatically delete previously recorded data. You can submit deletion requests and other requests regarding this data through the contact channel below.
3. Transfer of Personal Data
To the extent required by the relevant service, your personal data may be transferred, for the relevant purposes and in accordance with the conditions set out in the KVKK, to:
- The relevant businesses and branches that carry out discount and campaign transactions,
- Data hosting, technical infrastructure and software support service providers, including Firebase,
- SMS and e-mail service providers, if communication services are used,
- Legally authorized public institutions and organizations, and judicial authorities.
Step data is recorded on the Firebase infrastructure as part of the operation of the motivation window shown when you open the application and the campaign usage processes, for the purposes described in Section 2. If services that require the transfer of personal data abroad are used, compliance with the conditions set out in Article 9 of the KVKK is required.
4. Method of Collection and Legal Basis for Processing Personal Data
Your personal data is obtained electronically, by fully or partially automated means, through membership screens, your transactions within the application, the operation of the motivation window shown when you open the application, campaign usage processes and customer support channels. Your step count data is read through the HealthKit or Health Connect connection that you have authorized.
Data required to perform the membership and campaign relationship is processed under Article 5/2-(c) of the KVKK; data required to fulfill legal obligations is processed under Article 5/2-(ç); and records required to establish, exercise or protect a right are processed under Article 5/2-(e).
Records required for application and account security are processed under Article 5/2-(f) of the KVKK, provided that your fundamental rights and freedoms are not harmed.
The reading of your step data, its use and recording for the motivation window, and its processing in step-based campaign processes are based on your explicit consent, which will be obtained separately and covers the relevant purposes. For step data that qualifies as health data, Article 6/3-(a) of the KVKK applies. The technical access permission granted on your device is separate from the explicit consent process under the KVKK.
5. Retention and Security of Personal Data
Your personal data is retained only for the periods required by the relevant processing purpose and prescribed by the legislation. Step data recorded for the motivation window is retained for the period necessary to provide this feature. Step data recorded during campaign use is retained only as long as needed to track the relevant campaign transaction and to meet any legal retention requirements.
When the reasons for processing and retention no longer exist, your data is deleted, destroyed or anonymized in accordance with the legislation.
Our Company takes the necessary technical and administrative measures to prevent unlawful processing of personal data and unlawful access to data, and to ensure that data is stored securely.
6. Rights of the Data Subject
Under Article 11 of the KVKK, you have the right to:
- Learn whether your personal data is being processed,
- Request information about the processing if your personal data has been processed,
- Learn the purpose of processing your personal data and whether it is used in line with that purpose,
- Know the third parties in Turkey or abroad to whom your personal data is transferred,
- Request correction of your personal data if it is incomplete or inaccurately processed,
- Request deletion or destruction of your personal data under the conditions set out in the law,
- Request that the correction, deletion or destruction be notified to third parties to whom your personal data has been transferred,
- Object to a result against you arising from the analysis of your processed data exclusively by automated systems,
- Claim compensation for damages if you suffer damage due to the unlawful processing of your personal data.
7. Application and Contact
You may submit your requests regarding your personal data to our Company using the methods set out in the Communiqué on the Procedures and Principles of Application to the Data Controller.
- Data controller: Yönetim Zamanı Eğitim Danışmanlık Ticaret Limited Şirketi
- E-mail: muhasebe@kasifcocuk.com
- Website: www.walkandtalk.com.tr
You may send your application to the e-mail address above from the e-mail address you previously provided to our Company and that is registered in our system.