Last Revision Date: 05/07/2019
WeWALK Teknoloji AS (“WeWALK”, “we”), adopted the principle of protecting the privacy of users who visit the website at www.wewalk.io address and Android and iOS mobile applications (“Site”) and sign up to the Site (“Users”, “you”). WeWALK’s mission with WeWALK project is to provide smart cane technology service (“Service“) designed for visually impaired individuals. Our promise for being transparent about the data we collect about you, how such data are used, with whom they are shared and how they are protected and protecting the privacy of your data is right in the centre of this mission.
Which Data are Processed?
WeWAK collects certain data about you directly from you or automatically in the background through WeWALK application and device so you can obtain healthy results as expected from the Service you receive within the scope of WeWALK project.
Users sign up to WeWALK application via smart phones and provide express consent for the processing of the following data by WeWALK:
Address and Contact Information: Name, surname, phone number, e-mail address
Identity Verification Data: Subscription information, password and password hints used to authenticate and access to the account, user name
Demographic Data: Year of birth
Medical and Physical Data: The visual impairment percentage of users, walking distance and duration of walk
Frequency of Use and Frequently Used Features: Traffic data records that is kept in order to obtain information on navigation between menu items; activities performed over WeWALK touchpad, activated 3rd party services and the extent of using such services; the number of commands and the source of web traffic directed to the website in order to determine the most frequently used WeWALK features, make UX improvements and build foundation of data.
Location Data: Location data obtained from smart phones of users
Device Information: Serial number and model of WeWALK device and smart phone used, country information, IP information
Data collected through cookies: Statistical information collected to determine preferences of individuals visiting WeWALK website about site, experiences, pages and advertisements within the Site.
Audio Data: Meaning level, sound quality of audio records users create over WeWALK.
Payment Data: Data about payments
Data that are anonymized in an irreversible manner shall not be considered as data within the scope of this Policy.
Where Do We Store and Process Your Data?
Data collected under this Policy will be stored in Microsoft Azure Cloud. The data will be processed using Microsoft Azure Cloud and Google Data Studio Cloud services within the scope of applicable legislation and the prescribed security measures in the country of processing.
What Are the Purposes of Processing Your Data?
WeWALK is entitled to process the data that are directly provided by the users or automatically collected in the background through WeWALK application and device, for the purpose of performing the Service offered under the agreement made with the Users; offering customized services for visually impaired individuals during the development process of features for WeWALK smart cane and mobile application, segmenting visually impaired individuals accordingly; developing features encouraging users to increase their physical activities through tracking of physical activities; releasing recommendations, advertisements and marketing campaigns about WeWALK products and fulfilling any statutory obligation.
Device and location data collected from users are collected for the purpose of recording the locations where Users start and stop receiving navigation services so the distance covered by Users is understood; recommending route alternatives with improved security and reduced number of obstacles while offering navigation service to Users and recording the locations of the obstacles.
WeWALK website uses Google Analytics cookies for the purpose of understanding how site visitors use the site, which pages are visited the most and the efficiency of WeWALK advertisements; recording difficulties experienced in the Site; improving the design and functionality of the Site; and collecting statistical information about the Site use.
WeWALK determines and uses IP address of Users, WeWALK serial number, unique code of the mobile application and error records as deemed necessary, in order to define problems about the system and solve such problems immediately.
Who Is Authorized to Access Your Data?
WeWALK shall not directly share with the third persons any data provided by the User and physical activity data collected in the background through WeWALK application and device.
WeWALK shall anonymize insights based on the data on product and integration use that are generated using personal data of Users and share them with Arikovani Bilisim A.S. For the purpose of organizing in a manner reflecting average behaviours of Users and providing navigation solutions in enclosed spaces, provided that express consent of the user is obtained.
WeWALK shall also be entitled to process personal data and share them with third persons without obtaining consent of Users in case of exemptions under Personal Data Protection Law No. 6698 and/or applicable legislation. The following are examples of such exemptions:
- Clear provisions under the Laws permitting such use;
- Compulsory disclosure for protecting life and physical integrity of a person or any other person in case the relevant person is not able to provide consent due to actual incapability or his/her consent is not valid under the applicable law;
- Requirement to process personal data in case such processing is directly related with execution or performance of the Agreement;
- Compulsory data processing for the fullfilment of a legal obligation by WeWALK;
- Information made public by Users;
- Compulsory data procession necessary for vesting, using or protecting any right;
- Compulsory data processing for legal interests of WeWALK provided that fundamental rights and freedoms of Users are not violated.
About the Right to Access Your Data and Correction Requests Pursuant to Personal Data Protection Law No. 6698 (“Law”)
Pursuant to the Law No. 6698, Users are entitled to submit and application to WeWALK and:
- Get information as to whether personal data are processed or not;
- Get information on the extent of processing if data are processes;
- Get information on the purpose of processing personal data and as to whether they were used in accordance with the purpose;
- Get information on local and foreign third parties who were transferred personal data;
- Request correction if personal data were processed inaccurately or incompletely;
- Request deletion or destruction of personal data in accordance with the conditions stipulated in the applicable legislation;
- Request notification of deletion, correction and destructions made in accordance with the applicable legislation to third persons;
- File objection against unfavourable results obtained through analysis using automatic systems only;
- Claim compensation of losses and damages that may arise from illegal processing of personal data.
Users can submit WeWALK applications about the aforementioned requests in writing or using registered electronic mail (KEP) address, secure electronic signature, mobile signature of electronic mail address that was notified to WeWALK by the User or recorded in the system of WeWALK, or through a software or application developed for submitting inquiries. Users are obliged to submit such applications in Turkish and the following information should be provided thereunder:
- Name, surname and signature if the application is in writing;
- T.R. identification number for citizens of the Republic of Turkey; nationality, passport number or if any, identification number for foreign nationals;
- Residential address or business address basis to notification;
- If any, electronic mail address, telephone and fax numbers basis to the Policy;
- Subject of the request.
WeWALK shall provide positive/ negative response to the aforementioned inquiries by sending written or electronic response to applicant Users and the inquiries shall be resolved immediately but in any case, within thirty days depending on the nature of the inquiry. WeWALK shall process the inquiry of the User in the shortest time possible and provide information to applicant User about the subject matter.
Users guarantee that data constituting subject matter of this Policy are true and up-to-date and they shall be updated in case of any changes in such data. On the contrary, WeWALK shall not be held responsible for any loss or damage that may arise.
Your Rights Arising from the European Union’s General Data Protection Regulation (“GDPR”)
Unless restricted under the applicable laws, the following are the rights granted to data owners under GDPR:
- Right to Access: Right to obtain information about data we process about you and right to request access to such data;
- Right to Correction: Right to request amendment or revision of your data in case of deficient or incorrect data;
- Right to Deletion (Right to Be Forgotten): Right to request deletion of your data;
- Right to Restriction: Right to request temporary or permanent cease of processing all or a part of your data;
- Right to Object:
o Right to object the processing of your personal data based on facts related with your private condition;
o Right to object processing of your data for direct marketing purposes
- Right to Transfer Right: Right to request electronic copy of your data and transfer such data for using in services of another party;
- Right to Be Excluded From the Automatic Processing System: Right to become subject to automatic decision- making mechanism including profiling when the decision has legal effect or similar other effect on you.
Storage and Deletion of Data
WeWALK is entitled to store data collected within the scope of WeWALK project, for the purpose of performing the Service as required; fulfilling the collection purposes; complying with the law; carrying our administrative and judicial proceedings related with a dispute, and for the time limits specified under the applicable legislation.
WeWALK undertakes to take technical and administrative measures and perform the necessary inspections in order to prevent illegal processing of, illegal access to and illegal storage of personal data that are communicated in electronic environment in accordance with the conditions specified in this Policy or as specified under the applicable legislation. Accordingly, data of Users are protected using passwords and encryption methods.
In case a link is provided in the site for access to another application, WeWALK shall not be held responsible in connection with the privacy policies and contents of that application.
WeWALK covenants that such data obtained about Users shall not be disclosed in breach of the provisions under this Policy and the Law, or process them beyond the purpose of processing. However, please note that no system is 100% secure. In case any breach about the system comes its knowledge, WeWALK may attempt to notify you by sending a notification to [email protected] address or sending an electronic mail to you.
If you have any question about data security, you can contact us at www.wewalk.io address.
WeWALK is entitled to revise this Policy time by time. You can check the last revision date in the “last revision date” field. Policy provisions revised by WeWALK take effect on the date of release. In addition, WeWALK shall display a notification or send an e-mail as appropriate, in connection with the material revisions. Therefore, please make sure that you read such notifications carefully.
Privacy of Children
WeWALK service is not aimed at children under 16 years of age. In addition, stricter age restrictions may apply under local regulations of certain countries.
We do not collect information from children under 16 years of age or applicable age limit. If you are under 16 years of age, please do not use WeWALK service or do not provide us any personal data. If you are parent of a child under 16 years of age or you notice that your child provided data to WeWALK, please contact us at www.wewalk.io address.
We will take reasonable steps to delete the data if we find our that data of children under 16 years of age are collected.
Please visit https://tools.google.com/dlpage/gaoptout address in order to control data collected through cookies in WeWALK website.
If you have any questions about this Policy, you can contact Data Protection Officer by writing to the following address: