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In force

KVKK Privacy Notice

Our notice under Article 10 of the Turkish Personal Data Protection Law No. 6698 (KVKK) and the Communiqué on the Duty to Inform, for people who visit our websites, write to us, request a demo or hold an account in Workout OS or Workout Studio. If you are in the EU, UK or elsewhere, also see our Privacy Policy.

Version
2026-11-03
Effective date
(new customers)
(existing customers)
Published
Provider
Laten Lukken Yazılım Sanayi Ticaret Ltd. Şti.

This version applies to customers who sign up from 3 November 2026 as soon as they sign up. For customers who accepted the earlier version 2026-10-29, it takes effect on 3 December 2026; until then the previous version applies to them. You can request the text of the previous version at support@workoutos.app.

Contents

1Data controller

The controller of the personal data described here is Laten Lukken Yazılım Sanayi Ticaret Ltd. Şti. ("Laten Lukken" or "we"), a company established in Türkiye. Our registered address is published in the Turkish Trade Registry Gazette; we send it straight away on request by e-mail. Contact and requests: support@workoutos.app.

2Who this notice covers

  • Visitors to workoutos.app and workoutos.com.tr
  • People who join the early access list, fill in the contact or demo form, or write to us by e-mail
  • Owners, representatives and panel users (managers, trainers, front desk) of businesses that sign up for or subscribe to Workout OS or Workout Studio

If you are a member of a gym or a client of a studio: the business you belong to is the controller of your data. Laten Lukken processes that data only on the business's behalf and instructions, as a processor. Please contact the business first; if you write to us, we will forward your request to them without delay.

Our relationship with businesses is governed by the Data Processing Agreement.

3Personal data we process

FromData categories
Website visitorsTransaction security: IP address, browser and device data, time and address of requests (server logs). The sites use no cookies or analytics tools.
Early access and contact formContact: e-mail. Optional identity and professional data: name, type of business, city or country. Your message. Marketing: the text, version and time of your consent. Transaction security: an irreversible hash of your IP address.
Demo requestersIdentity: name. Contact: phone, e-mail, city. Professional: business name, product of interest, member or client count range. Your message. Transaction security: IP address, browser data.
Account holders and panel usersIdentity and contact: name, e-mail, phone. Account: role, password (only as an irreversible hash), session records, language preference. Transaction security: sign-in times, audit logs of actions in the panel. Legal transaction: records of acceptance of our terms (version, date, method, IP hash, browser data).
Representatives of subscribed businessesFinance: billing name, country, tax ID (if entered at Polar), plan and payment history. Card details are not stored by us; Polar and Stripe process them. Customer transaction: support correspondence and requests.

4Purposes and legal grounds

PurposeLegal ground (KVKK Art. 5)
Answering demo and contact requests, calling you, preparing an offerDirectly related to forming a contract (5/2-c); legitimate interests (5/2-f)
Opening your account, providing the Service, support and essential service noticesPerformance of a contract (5/2-c)
Keeping subscription and payment records, complying with tax and commercial lawExpressly provided by law and legal obligation (5/2-a, ç)
Recording acceptance of our terms, exercising and protecting our rights in disputesEstablishing, exercising or protecting a right (5/2-e)
Operating the sites and panels securely, preventing abuse and unauthorised access, tracking errorsLegitimate interests (5/2-f)
Sending early access, launch and product news e-mailsYour explicit consent (5/1) and consent to commercial electronic messages under Law No. 6563

The box on the demo form confirms that you have read this notice; answering your demo request relies on the grounds above, not on consent. You can withdraw marketing consent at any time with the link in every message or by writing to us.

5How we collect data

  • Directly from you: website forms, e-mail, sign-up and settings screens in the panel
  • Automatically: server, security and audit logs created when you use the sites and panels
  • From the payment provider: payment and subscription status from Polar (never the card number)

Data is collected electronically, by fully or partly automated means.

6Who we transfer data to and why

We do not sell your data. We transfer only what is needed for the purposes above to:

RecipientPurposeLocation
Railway CorporationHosting and databaseEU (Amsterdam, Netherlands); company in the US
Resend (Plus Five Five, Inc.)Transactional e-mail (verification, password reset, notifications)EU (Ireland); company in the US
Functional Software, Inc. (Sentry)Error tracking (with personal data stripped)EU (Germany); company in the US
Hostinger International Ltd.Websites, early access list and business e-mailEU (Frankfurt, Germany)
Polar Software, Inc. and StripeSubscription billing, tax and invoicing (Polar is merchant of record)US
Meta Platforms Ireland Ltd. (WhatsApp)Messages you send to our Turkish WhatsApp support lineEU and US
650 Industries, Inc. (Expo)Push notifications to the member app (where used)US
Competent public authorities and courtsLegal obligations, on request and only as requiredTürkiye

Details: Sub-processors.

Transfers abroad: because some of these services, including hosting, are outside Türkiye, your data is transferred abroad. Transfers rely on appropriate safeguards under Article 9 KVKK, the standard contracts published by the Personal Data Protection Board: a standard contract is signed with each recipient abroad and notified to the Board within 5 business days of signature.

7Retention

DataPeriod
Demo requests12 months after the last contact if you do not become a customer; otherwise together with your account data
Early access list12 months after launch, or until you withdraw consent
Support and contact correspondence2 years after the request is resolved
Account dataWhile the account is open; deleted 90 days after the account is closed
Subscription and payment records10 years (Turkish Commercial Code Art. 82, Tax Procedure Law Art. 253)
Records of acceptance of our terms10 years after the contract ends
Session records (IP address, browser)While the session is active; an unused session expires within 7 days at the latest. Expired session records are deleted, at the latest together with the account data.
Server and error logsServer logs up to 30 days, error logs up to 90 days
BackupsNightly backups 14 days, weekly backups 8 weeks

When a period ends, data is deleted, destroyed or anonymised. A record of deletions (without personal data) is kept for at least 3 years.

8Your rights (KVKK Art. 11)

You may apply to Laten Lukken to:

  • Learn whether your personal data is processed
  • Request information if it is processed
  • Learn the purpose of processing and whether data is used accordingly
  • Know the third parties in Türkiye or abroad to whom data is transferred
  • Request correction of incomplete or inaccurate data
  • Request deletion or destruction under the conditions of Article 7 KVKK
  • Request that corrections, deletions and destructions be notified to the third parties the data was transferred to
  • Object to a result against you arising from analysis solely by automated systems
  • Claim compensation for damage caused by unlawful processing

9How to apply

Send your application in Turkish with your full name, Turkish ID number (or, for foreign nationals, nationality and passport number), address for notifications, e-mail and phone if any, and the subject of your request (Communiqué on the Procedures and Principles of Applications to the Controller):

  • From the e-mail address you previously gave us and that is registered in our systems, to support@workoutos.app
  • Signed with a secure electronic signature or mobile signature, to support@workoutos.app
  • By wet-signed letter to our address registered in the Turkish Trade Registry (published in the Turkish Trade Registry Gazette; write to support@workoutos.app and we send it the same day)

We conclude your application free of charge as soon as possible and within 30 days at the latest. If the process involves an additional cost, a fee may be charged under the Board's tariff. If your application is rejected, our answer is insufficient or we do not answer in time, you may complain to the Personal Data Protection Board within 30 days of learning our answer and in any case within 60 days of your application.