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 PUMATRAC APP PERSONAL DATA PRIVACY STATEMENT AND PRIVACY POLICY

Within the context of our obligation to inform arising from the Data Protection Law numbered 6698 (“DPL”), this PumaTrac App personal data privacy statement and privacy policy (“App Privacy Policy”) explains the personal data collected over the PUMATRAC App (“App”) operated by PUMA Spor Giyim Sanayi ve Ticaret Anonim Şirketi (“PUMA”) in order to suggest sports activities best suited for you and to allow you to follow up with your activity history and how the collected personal data is used. This App Privacy Policy also puts forth the choices you have as to how we will collect and use your personal data.

By using this App and benefitting from our services, you are deemed to have consented to the processing of your personal data as stated in this App Privacy Policy, except for instances where your explicit consent is required.

PUMA, as per DPL, shall be responsible for the processing of the personal data obtained or collected from you over this App or other PUMA apps or in relation to using our services through them.

App Privacy Policy Updates
Each time you use the App, you will be subjected to the App Privacy Policy in effect at that time and each time you use the App, you should review this text in order to ensure that you accept the conditions. We can update this App Privacy Policy from time to time. When we update the App Privacy Policy, the new App Privacy Policy will be published on this page and we will change the date visible at the top of this text. Therefore, we urge you to review the App Privacy Policy updates each time you visit the App to check any updates or changes.

If you have any inquiries regarding this App Privacy Policy or any problems not covered hereunder, please contact PUMA through communication mediums provided under this App Privacy Policy.

INFORMATION REGARDING YOUR PERSONAL DATA
As per DPL, PUMA Spor Giyim Sanayi ve Ticaret Anonim Şirketi registered within Istanbul Commercial Registry with the registration number 503363 and with Mersis number 0781032787100015 at the address of Esentepe Mahallesi Harman 1 Sokak No: 7-9 Kat: 1 Nidakule Levent Şişli, Istanbul acts as the data controller of your personal data shared through channels stated under this section.

 

I. Collection of Personal Data and Legal Bases

According to the DPL, if you share your personal data with us in order to benefit from the services provided through the App, in accordance with your explicit consent or with respect to exceptional instances stipulated under the domestic legislation on the protection of personal data, PUMA, as the Data Controller, can obtain your personal data within the scope of the DPL and in accordance with this App Privacy Policy, record your personal data in written/magnetic archives, store, retain, update in order to provide services, alter, reorganize, disclose, transfer to or share with third parties where permitted by and within the boundaries of applicable legislation (domestic or abroad), classify, anonymize and process your personal data through other means stated under the DPL. PUMA processes your personal data by obtaining your explicit consent where necessary or without seeking your explicit consent in accordance with the exceptional regulations of the DPL, within the scope of Articles 5.1, 5.2, 6.2 and 6.3 of the DPL.

When your personal data is processed with your explicit consent, you can withdraw your explicit consent regarding the processing of your personal data at any time within the scope of the DPL. However, in that case you may not be able to benefit from certain functions of the App. When processing your personal data is mandatory, if you choose not to share the necessary personal data with us, we may not be able to provide you with the services requested, therefore, with regards to the App, certain personal data put forth below is determined as mandatory and such is processed exceptionally in order to provide you with the service.

PUMA acts in accordance with the obligations stipulated under the relevant legislation, particularly the DPL, when processing personal data and takes necessary security measures in order to retain your personal data in a secure manner and to ensure that your personal data is not used in an unlawful manner.

 

II. Collected Personal Data, Our Methods and Purposes of Collection

We directly and/or automatically collect certain information and personal data provided to us when registering for the App, using the App, when communicating via e-mail, telephone, letter or other means. Personal data collected in this manner may involve, including but not limited to, the following:

1. Login

To use the App, you have to log in to the App with either the credentials of your PUMATRAC account you registered for (email and password), or with your Facebook or Twitter account credentials.

Once your register for a PUMATRAC account, we process your PUMATRAC credentials (email address and password) when you log in.

For a login via Facebook or Twitter you will be forwarded to Facebook or Twitter, where you can log in with your Facebook or Twitter credentials and grant the App access to your Personal Data from your public profile (e.g. name, picture etc.) and – if you granted consent in your Facebook/Twitter platform settings – your email address, date of birth, and/or friends list.

These processing activities are necessary for the provision of our service, namely to provide you with dedicated access to your PUMATRAC profile.

2. PUMATRAC profile

When you log in to the App for the first time, we collect Personal Data from you in order to create and/or to complete your user profile.

This includes mandatory Personal Data like your name, surname, (nick-) name, your email address (if you registered via email/password), gender, as well as information on your fitness goals, preferred activities, training habits and sports activity history. This processing activity is necessary to provide you with the core functionalities of the App, namely customized workout recommendations and training motivation based on your fitness and training interest, habits, and goals.

In addition, we also process Personal Data, which you voluntarily provide us with, in order to provide you with additional functionalities and/or an even more customized user experience, such as

  • date of birth,
  • information on weight and height, which is necessary to provide you with a customized calculation of calories you burned during your workouts and/or
  • information on your location, which is necessary to provide you with information on trainers and workout courses close to your location

These optional data can be altered or deleted from your profile at any time by using methods provided through the App. This may, however, have the consequence that the described functions are no longer available.

3. Tracking, recording and sharing of workouts

If you want to track and record your workouts we are Processing your workout data (e.g. date, duration, distance, or repetitions, speed, calories etc.). This data may be collected directly via the App or indirectly through access to relevant data (e.g. heart rate) from third party applications (e.g. health app on your device) and/or (fitness) sensors and devices (e.g. GPS and/or gyroscope sensor integrated in your device, external heart rate monitors etc.), provided you granted prior consent that the App can access data from the relevant apps, sensors, and/or devices. This consent can be at any time amended or withdrawn in the account settings.

Once you finished a workout, this workout, including the recorded workout data, is stored in your PUMATRAC profile.

If you have set your profile visibility to “Public – Everyone” in the privacy settings of the App, your completed and saved workouts will appear in the PUMATRAC feed and are, thus, visible to other PUMATRAC users.

These processing activities are necessary to provide you with the opportunity to track, record, and share your workouts to the extent you wish.

4. Location-related design of the App

If you granted consent that the app may access the location data of your end device, we will also use this data to adapt the contents of the App or to send out push notifications (see Section 5 of this data protection information) in a site-specific manner. This way, we can for example automatically inform you about training opportunities and activities in your current environment and, thus, make your app experience even better (legal basis: Article 5 of the DPL).

You can prevent the location-based design of the app at any time by withdrawing your consent for location access through the app in your device settings. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.

5. Push notifications

If you have granted consent to receive push notifications, we process your device token ID to send you push notifications to your App including information on about for example a new version of the App or on current campaigns (legal basis: Article 5 of the Data Protection Law).

You have the right to withdraw your consent at any time by disabling the push notifications for the App in your device settings. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

6. Analytics

We process personal data about your last accesses to the App (e.g. IP address, access time, and – if consent is granted to access location data – location of access).

In addition, we use analytic services from Adobe Systems Software Ireland (Adobe Analytics), Google Ireland Limited (Google Analytics for Firebase), and Facebook Ireland Ltd. (Facebook Analytics) to evaluate and improve the App and its functionalities.

These services use cookies and similar tracking technology to collect pseudonymized data on the usage of the App, so called screen visits and events (e.g. like logins, content viewed, started and/or finished workouts etc.). At collection of this data, your IP address is either not collected or anonymized. Data we collect with the help of these services are merged to aggregated reports on the usage of our app (e.g. numbers of users per day, visits/downloads of specific workouts etc.) and cannot be attributed to you.

For more information on the data processing of these services please refer to the following links:

Adobe Analytics

Google Analytics for Firebase

Facebook Analytics.

This Processing is necessary for the purposes of the legitimate interests pursued by us, namely analyses and statistics.

Right to object analytics:
You can object to this Processing at any time in the privacy settings of the App on your device by deactivating “Analytics”.

7. E-mail marketing

Provided that your consent is provided as per Law on the Regulation of Electronic Commerce numbered 6563, we use the email-address, which you provided for your PUMATRAC profile, to occasionally send you e-mails with information on news and campaigns in connection with the App as well as PUMA products.

Right to object e-mail-marketing:
You can object to this processing and unsubscribe from our marketing-e-mails at any time by sending an e-mail to our customer service pumatrachelp@puma.com stating your wish to unsubscribe or by just clicking on the link “Unsubscribe”, which is included in every one of our marketing e-mails.

 

III. Purposes of Processing Personal Data

Your personal data collected through the aforesaid methods and through channels mentioned in this App Privacy Policy is processed by PUMA for the purposes below.

Your personal data collected with the mentioned methods and through channels mentioned in this App Privacy Policy can be processed with the below purposes without seeking your explicit consent as per DPL Article 5.2 and Article 6.3:

  • For the purpose of fulfilling our statutory obligations (tax legislation, legislation on consumer protection, code of obligations, commercial code and other regulations): processing your data when required so by the legislation and all other processing deemed to be within the scope of the relevant regulations
  • For purposes mandatory for the protection of your life or physical integrity or of any other person or if you are bodily incapable of giving your consent or your consent is not deemed legally valid.
  • For the purposes of conclusion or fulfilment of an agreement: For example, in order to provide the services within the scope of the PUMATRAC App as put forth under “Collected Personal Data, Collection Method and Purposes” section above.
  • For the purpose of fulfilling our legal obligations: all processing deemed to be within the scope of answering and settling your questions, complaints and notification regarding PUMATRAC and Puma products and services, preventing unlawful and unsecure using of your personal data.
  • For purposes mandatory for the establishment, exercise or protection of any right: For example, establishing or protecting a right by means of processing to retain records within the App for evidentiary purposes and all other processing deemed to be within the scope of the relevant regulation.
  • For purposes mandatory for the protection of our legitimate interests, provided that this processing does not violate your fundamental rights and freedoms: processing to evaluate the quality of the service provided to you, to review and to settle your demands put forth in this regard and all other processing deemed to be within the scope of the relevant regulation.

In addition, personal data you have made available to the public can be processed for the abovementioned purposes without seeking your explicit consent. For example, processing by PUMA of your personal data made available to the public through social media, your personal website or other mediums and all other processing deemed to be within the scope of the relevant regulation.

You can give your explicit consent to the processing of your personal data collected with the mentioned methods and through channels mentioned as per DPL Article 5.1 and Article 6.2 by enabling the functions below and you can always withdraw your consent by disabling these functions:

  • Using for the purposes of sending electronic commercial communications including notifications sent over the App for sales and marketing, corporate communication and in order to organize events and gatherings and provide information regarding such and provide product and service opportunities special for you such as campaigns, benefits and product/service advertisements (these notifications can be enabled or disabled)
  • Conducting targeting, re-targeting and cross-selling activities (You can enable or disable this function if you want to allow or prevent advertisements and such activities over the App)
  • Customizing the App by sharing the abovementioned personal data voluntarily (you can prefer not to share such voluntary data and you delete them anytime)
  • If you prefer to use the workout record function, processing your records and sharing them with third parties in accordance with your explicit consent (you can enable-disable this recording function and update the privacy settings of the record at any time)
  • Statistics and analyses (you can stop the relevant statistics and analyses except for the mandatory ones through above stated channels)

 

IV. Sharing of your Personal Data with Third Parties and Transfer of Personal Data Abroad

PUMA can transfer your personal data collected with the mentioned methods and through channels mentioned in this App Privacy Policy to third parties or abroad within the scope of DPL and other legislation and for the purposes mentioned in this App Privacy Policy. Your personal data:

  • In the event of the purposes put forth under Article 5.2 and Article 6.3 of the DPL provided above, can be transferred to service providers (such as storage, archive, IT support, server, hosting, cloud computing, CRM, e-mail providers) and service providers providing log-in support required for the development and maintenance of the services provided through or over the App abroad within Turkey or outside of Turkey in countries with the adequate level of security or countries, while without the adequate level of security, having undertaken the necessary obligations within the scope of the DPL and other relevant legislation, particularly EU countries, OECD countries, India, China and Russia, Puma group companies, particularly PUMA SE, business partners, supplier firms, banks, financial institutions, consultant firms regarding legal, tax, etc. support, governmental institutions and organizations, other related parties and authorized institutions and organizations to which transference is required for purposes determined.
  • Within the scope of abovementioned Article 5.2 and Article 6.3 of the DPL, provided that you enable functions or provide your explicit consent to such from the privacy settings regarding certain purposes determined abroad, particularly EU countries, OECD countries, India, China and Russia:  
  • marketing companies, third party service firms providing marketing support and business partners (firms providing support regarding notifications, establishing campaigns, firms providing behavior analysis, analysis support, firms providing CRM support) can access your personal data limited to the function you have enabled and within the scope of your permission.
  • other users of the PUMATRAC App in following instances:
  • If “Private – Only me” is set in the privacy settings of the PUMATRAC App (default setting), other PUMATRAC users can only see basic and anonymous information from your profile ((nick)name (your surname will be abbreviated to the first letter of your name), country/town, TRAC score and number of your followers, and number of PUMATRAC users you are following),
  • If you have set “Public – Everyone” in the privacy settings of the PUMATRAC App, other PUMATRAC users also have access to your workouts and related training information.

We would like to state that we oblige third parties provided above to use your personal data only with your explicit consent and/or in accordance with the domestic legislation on the protection of personal data. In addition, we require our business partners to always act in accordance with the data protection and privacy legislation in effect and give great importance to the privacy of your data.

 

V. Protection of Your Data

PUMA, aims to maintain physical, technical and managerial security appropriate for workplace and information systems and therefore, prevent the loss, abuse of your personal data, unauthorized access to your personal data, disclosure or altering of your personal data. We protect our website and other systems by obtaining technical and corporate measures against loss, destruction, unauthorized access, altering or disclosure of your personal data by unauthorized persons. While we display the utmost effort to protect your data when you submit your personal data, no data transference over the internet or any general network cannot be guaranteed to be 100% secure.

 

VI. Data Processing Period, Storage and Deletion of your Personal Data

The personal data you have shared with PUMA through the channels mentioned in this Privacy Policy shall be processed in accordance with the periods required under regulation regarding the protection of personal data, particularly DPL, and at any event for as long as the abovementioned legitimate purposes are effective.

All Personal Data that you share with us or that are generated when using the App are securely stored in your App (Frontend) as well as in our cloud database (Backend). Upon request, your Personal Data will be deleted from both the App and the cloud database (see hereafter).

Workout history: Your stored workouts and related Personal Data can be deleted at any time.

PUMATRAC profile and account: In the user settings (“About you”) you can also at any time delete non-mandatory Personal Data from your PUMATRAC profile. You can also delete your entire PUMATRAC profile and account by contacting our support via pumatrachelp@puma.com.

 

VII. Right to Information and to Objection

As per Article 11 of the DPL, you have the right to apply to our Company and;

  • Learn whether your personal data are processed or not,
  • Request information if your personal data is processed,
  • Withdraw any permission you have given to us regarding using your personal data,
  • Learn the purpose of your data processing and whether this data is used for intended purposes,
  • Know the third parties to whom your personal data is transferred at home or abroad,
  • Request the rectification of the incomplete or inaccurate data, if any,
  • Request the erasure or destruction of your personal data to be evaluated in accordance with the purpose, period and justification principles,
  • Request notification of the rectification, erasure or destruction operations carried out to third parties to whom his personal data has been transferred,
  • Object to the processing, exclusively by automatic means, of your personal data, which leads to an unfavourable consequence for you,
  • Request compensation for the damage arising from the unlawful processing of your personal data

In this regard, you may send your demand regarding your abovementioned rights to our e-mail address provided below that can change from time to time with secured electronic signature or by hand or through the notary public to the address provided below that can change from time to time with a signed petition along with documents authenticating your identity. PUMA shall conclude the within the shortest time possible depending on the nature of the demand and within 30 (thirty) days at the latest and free of charge. If conclusion of the demands by PUMA incurs additional costs, the prices set by the Personal Data Protection Board may be collected.

If you want to exercise your right to information and/or right to objection to using of your personal data or if you have any inquiries regarding privacy, you may contact us through the mediums below:

E-mail: pumatrachelp@puma.com

Mail: PUMA Türkiye Esentepe Mahallesi Harman 1 Sokak No:7-9 Kat:1 Nidakule Levent, 34394 Istanbul, Türkiye