KVKK Data Protection Notice

Identity of the Data Controller

In accordance with Article 10 of Law No. 6698 on the Protection of Personal Data ("KVKK") and the Communiqué on the Principles and Procedures to Be Followed in Fulfilling the Disclosure Obligation, we hereby provide the following information as the data controller:

Data controller

iceprofile Bilişim Hizmetleri A.Ş.

Address

TODO(lawyer): resmi tebligat adresi

MERSİS

TODO(lawyer): MERSİS no

KEP

TODO(lawyer): KEP adresi

VERBİS

TODO(lawyer): VERBİS sicil no (zorunluluk doğduğunda)

General contact

legal@iceprofile.com

KVKK requests

kvkk@iceprofile.com

Categories of Personal Data Processed

In our capacity as data controller, we process the following categories of personal data in the scope of our services:

• Identity: first name, surname, year of birth.
• Contact: email address, telephone number.
• Customer transactions: club subscription and payment records, invoice information, membership history.
• Transaction security: IP address, session information, access logs, password hash.
• Professional experience: coach certifications, areas of expertise, years of experience.
• Visual and audio records: profile photos and media uploaded to the club page.
• Marketing: marketing preferences based on explicit consent.

Purposes of Processing

Your personal data are processed for the following specific, explicit and legitimate purposes in line with Article 4 of the KVKK:

1. Account and club membership creation, authentication and access management.
2. Running club operations (groups, training schedule, attendance, payment tracking).
3. Enabling communications and announcements between members, coaches and guardians.
4. Carrying out information security, abuse detection and process monitoring activities.
5. Fulfilling accounting, finance and tax obligations.
6. Responding to information requests from authorized persons, institutions and agencies as legally required.
7. Improving our services, performing statistical analysis and operating on diagnostic data to fix errors.
8. Sending marketing communications and club-specific updates where you have given explicit consent.

Recipients of Transferred Data and Transfer Purposes

Your personal data is shared with authorized administrators and coaches of the club you are a member of, strictly for the operation of that club. We also rely on the following processors to operate the platform infrastructure:

Supabase, Inc.

Amerika Birleşik Devletleri (ABD)

Hosting, database, authentication, file storage and transactional email infrastructure.

Expo / EAS

Amerika Birleşik Devletleri (ABD)

Mobile push notification and over-the-air update delivery.

Vercel, Inc.

Amerika Birleşik Devletleri (ABD)

Web hosting, edge network (CDN) and deployment.

Data may be transferred to public authorities and authorized private law persons only within the legal framework upon their request.

Method and Legal Grounds of Collection

Personal data is collected electronically via the iceprofile website, mobile application and club application form, through information you submit. Processing is carried out on the following legal grounds set out in Article 5/2 of the KVKK:

• Being expressly stipulated by law (Art. 5/2(a)).
• Being directly related to the formation or performance of a contract (Art. 5/2(c)).
• Being required for the data controller to fulfil a legal obligation (Art. 5/2(ç)).
• Being required for the establishment, exercise or protection of a right (Art. 5/2(e)).
• Being required for the legitimate interests of the data controller, provided they do not harm your fundamental rights and freedoms (Art. 5/2(f)).
• Explicit consent of the data subject for processing that requires consent (Art. 5/1).

Your Rights under KVKK Article 11

Pursuant to Article 11 of the KVKK, you may exercise the following rights by applying to us as the data controller:

1. To learn whether their personal data are being processed.
2. To request information about their personal data if processed.
3. To learn the purpose of the processing and whether the data are used in line with that purpose.
4. To be informed of the third parties to whom personal data are transferred domestically or abroad.
5. To request the correction of personal data that are processed incompletely or inaccurately.
6. To request the erasure or destruction of personal data within the conditions set out in Article 7 of the KVKK.
7. To request that operations carried out pursuant to items (5) and (6) be communicated to third parties to whom personal data have been transferred.
8. To object to the occurrence of a result to the person’s detriment by analysing processed data exclusively through automated systems.
9. To demand compensation for damages arising from the unlawful processing of personal data.

Application Method

Within the scope of Article 13 of the KVKK and the Communiqué on the Principles and Procedures for Application to the Data Controller, you may submit requests concerning the rights above through one of the following channels:

• In writing — delivering a signed request along with an identification document in person or through a notary to the address indicated above,
• By email signed with secure electronic signature or mobile signature to kvkk@iceprofile.com,
• Via KEP to the data controller's KEP address above.

Your application must include: your name and surname, your signature if submitted in writing, your Turkish ID number (passport number for foreign nationals), your address for service, your email, phone and fax number if any, and the subject of your request. Pursuant to Article 13 of the KVKK, your application is concluded free of charge within 30 days at the latest, depending on the nature of the request; where the operation itself incurs a cost, the tariff determined by the Personal Data Protection Board may be charged.

Contact

For questions regarding this disclosure, please use the contact details below:

Data controller

iceprofile Bilişim Hizmetleri A.Ş.

Address

TODO(lawyer): resmi tebligat adresi

KVKK email

kvkk@iceprofile.com

KEP

TODO(lawyer): KEP adresi