Privacy Policy

Last Revision Date: 23/07/2018

 

Hayal Ortakları Derneği ve Hayal Ortakları Derneği İktisadi İşletmesi (“YGA”, “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”). YGA'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.

 

This Privacy Policy (“Policy”) also provided information on how you can control personal and private personal information (“data”) collected from Users and how you can apply to YGA when you require deletion of such data.

 

Which Data are Processed?

YGA 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 YGA:

 

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?

YGA 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 YGA 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. 

 

YGA 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?

YGA 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. 

 

YGA 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. 

 

YGA 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:

 

 

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 YGA and: 

 

 

Users can submit YGA 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 YGA by the User or recorded in the system of YGA, 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:

 

YGA 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.  YGA 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, YGA 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:

 

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

 

Storage and Deletion of Data

YGA 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. 

 

Data Security

YGA 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, YGA shall not be held responsible in connection with the privacy policies and contents of that application.

 

YGA 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, YGA 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.

 

Policy Revisions

YGA 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 YGA take effect on the date of release.  In addition, YGA 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 YGA, 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.

Communication

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:

[email protected]