Clarification Text on the Protection of Personal Data (KVKK & GDPR)

1. Identity of the Data Controller

In accordance with the Turkish Law on the Protection of Personal Data No. 6698 ("KVKK") and the General Data Protection Regulation ("GDPR"), Forcell Mobile Applications ("Forcell", "Data Controller") is committed to safeguarding the personal data processed through the Koza: Pregnancy & Baby Tracker mobile application.

2. Legal Bases & Methods of Personal Data Collection

Personal data is collected through electronic media via our mobile application user interfaces when you create an account, log gestational parameters, record personal health logs, participate in community discussions, or submit customer support tickets.

Processing is carried out pursuant to the following statutory legal grounds:

• Explicit Consent (KVKK Art. 5/1 and Art. 6/2, GDPR Art. 6(1)(a) and Art. 9(2)(a)): Required for processing special category health data (gestational calculations, contraction timings, medication schedules, maternal weight evolution) voluntarily inputted by users for tracking purposes.
• Direct Contract Performance (KVKK Art. 5/2(c), GDPR Art. 6(1)(b)): Necessary for establishing and executing user accounts, delivering community forum features, and calculating pregnancy timelines.
• Compliance with Legal Obligations (KVKK Art. 5/2(ç), GDPR Art. 6(1)(c)): Mandatory data retention or disclosure obligations required by applicable laws.
• Legitimate Interests (KVKK Art. 5/2(f), GDPR Art. 6(1)(f)): Essential for app stability, fraud prevention, spam mitigation, and network security.

3. Purposes of Processing Personal Data

Your personal data is processed strictly for the following legitimate purposes:

• Calculating accurate gestational age, fetal development milestones, and estimated delivery dates based on standard obstetric literature,
• Enabling on-device tracking of maternal wellness metrics (water consumption, kick counts, contraction intervals, prenatal medication reminders),
• Facilitating respectful, community-moderated peer discussions in the Koza Forum,
• Providing timely customer support, bug resolution, and processing user feedback,
• Ensuring application resilience, preventing malicious attacks, and safeguarding user privacy through encryption.

4. Transfer of Personal Data & Cross-Border Policy

Forcell does not sell, commercialize, or transfer your personal or health data to third-party advertisers or data brokers.

Personal data may only be transferred to:

• Authorized Cloud Infrastructure Providers: Strictly for hosting backend databases (community forum and support API) under stringent Data Processing Agreements (DPAs) and TLS 1.3 encryption.
• Judicial & Public Authorities: Only when legally mandated by a valid subpoena, court order, or statutory reporting duty under applicable law.

5. Rights of the Data Subject (KVKK Article 11 & GDPR Chapter III)

As a data subject, you have the right to apply to Forcell at any time to:

1. Learn whether your personal data is being processed,
2. Request information if your personal data has been processed,
3. Learn the purpose of the processing and whether data is used in accordance with its purpose,
4. Know the third parties to whom personal data is transferred domestically or abroad,
5. Request the rectification of incomplete or inaccurate personal data,
6. Request the erasure, destruction, or anonymization of your personal data under the statutory conditions,
7. Request notification of rectification and erasure operations to third parties to whom data has been transferred,
8. Object to any adverse outcome arising from analysis conducted exclusively via automated systems,
9. Claim compensation for damage in case of unlawful processing of personal data.

6. Application & Data Subject Request (DSAR) Procedure

You may exercise your rights under Article 11 of the KVKK and Articles 15–22 of the GDPR by submitting a formal written request containing your identification details and explicit request description to:

📧 Email: forcellmobileapps@gmail.com (Subject: "KVKK / GDPR Data Subject Request - Koza")

In accordance with Article 13 of the KVKK, your requests will be concluded free of charge as quickly as possible and within thirty (30) calendar days at the latest, depending on the nature of the request.