Privacy Policy

1. Purpose and Scope

This Privacy Policy (the “Policy”) sets out the principles governing the collection, use, storage, sharing and protection of the personal data of members, visitors and customers (the “User”) who use the www.vitalyglobal.com website and mobile application (the “Site”) operated by Vitaly Global Vitamin Gıda Takviyeleri ve Kozmetik Ticaret A.Ş. (“Vitaly Global”, the “Company”). Detailed information on the processing of personal data is provided in the separately issued Privacy Notice under the Personal Data Protection Law No. 6698 (KVKK) (the “KVKK Privacy Notice”); this Policy shall be interpreted together with, and as a complement to, the Privacy Notice. Detailed information on cookies is set out in the Cookie Notice.

2. Information Collected

2.1 Membership and Order Information

When you create a membership, place an order or manage your account, we collect your full name, email address, mobile phone number, delivery address and order history.

2.2 Supplement Test Information

We collect the answers you provide in the supplement tests offered on our Site (Focus, Immunity, Energy, Hair-Skin-Nails, Sleep, Digestion, Joint and Bone Health, and Stress Tests). It has been specifically confirmed that special categories of personal data (health data) within the meaning of KVKK Art. 6 are collected in the Immunity Test (frequency of past illnesses), in the Joint and Bone Health Test (chronic conditions, the area of the body where the complaint is felt, impact on daily movement) and in the Digestion test (issues such as bloating, reflux, etc.).

Since special categories of data have been identified in at least one test, the explicit consent mechanism is applied to all tests in line with the principle of prudence; however, in each test only the data relating to the questions actually asked in that test is processed. Where it becomes clear that a test contains health data, the relevant scope and explicit consent text are updated to correspond exactly to the questions actually asked. Data of this nature is processed only on condition that your explicit consent is obtained on the relevant test screen; for detailed information, please refer to Sections 3.2 and 5 of the KVKK Privacy Notice.

2.3 Automatically Collected Information

During your visit to the Site, your IP address, browser type, date/time of visit and browsing activity may be collected automatically through cookies and similar technologies. Cookies other than strictly necessary cookies are only activated with your explicit consent (see Section 4 and the Cookie Notice).

3. Purposes of Use of Information

1. Carrying out membership and order processes,
2. Administering the supplement tests and offering personalized product recommendations based on the test results,
3. Sending test results and product recommendations by email,
4. Sending promotional, campaign and e-newsletter communications, provided that you have given your explicit consent,
5. Operating and improving the Site and ensuring its security,
6. Fulfilling legal obligations and managing legal proceedings.

Important note: The Site offers the supplement tests for general information and product recommendation purposes only, without any intention of medical diagnosis or treatment. Test results do not replace an assessment by a healthcare professional.

4. Cookies

Cookies are used on our Site to improve the user experience, manage session information and analyze site traffic. The types of cookies and their purposes of use are as follows:

• Strictly necessary cookies: Required for the basic functions of the Site (such as logging in and cart management) to work; they do not require consent.
• Functional cookies: Used to remember preferences and personalization.
• Performance/analytics cookies: Used to analyze Site usage and improve service quality.
• Marketing cookies: Used only with your relevant consent, to present content and advertising tailored to your interests.

Cookies other than strictly necessary cookies (functional, performance/analytics and marketing cookies) are used only with your explicit consent and are not activated before you give your approval. You may change your cookie preferences at any time via the Cookie Management Platform on the Site or through your browser settings, or disable cookies entirely; in that case, some features of the Site may not function properly. Detailed information on cookies is provided in the Cookie Notice.

5. Google Sign-In and Processing of Google User Data

Vitaly Global uses the Google Sign-In service to enable users to log in securely with their Google accounts. When a user logs in with a Google account, and in accordance with the user’s explicit approval, the following Google user data may be accessed:

• Google account ID (OpenID Identifier),
• First and last name,
• Email address,
• Profile photo (if any),
• Basic Google profile information.

This information is used solely for the following purposes:

• Verifying the user’s identity,
• Creating a Vitaly Global user account or linking it to an existing account,
• Enabling the user to log in to their account securely,
• Ensuring account security and preventing unauthorized access.

Google user data is not used for advertising, targeted marketing or profiling user behavior for commercial purposes. This data is not sold or rented, and is not shared with third parties except where required by law.

Vitaly Global does not access user content in Google Drive, Gmail, Google Calendar, Google Contacts, Google Photos or any other Google services. Users may revoke the access permissions granted to the Vitaly Global application at any time through their Google account settings.

6. Information Security

Our Company takes all necessary technical and administrative measures to ensure an appropriate level of security in order to prevent the unlawful processing of your personal data and unlawful access to the data, and to ensure the safekeeping of personal data. Sensitive payment information such as credit card details is not stored in our Company’s systems; it is processed directly and in encrypted form between you and the relevant banks and card institutions.

7. Sharing with Third Parties

Your personal data may be shared, on a limited basis and solely for the purpose of providing the relevant service, with cargo/logistics companies for order delivery, banks/payment institutions for payment transactions, cloud/hosting providers for hosting the Site, and email marketing service providers for sending test result/campaign emails. These third parties may process your data only in accordance with our Company’s instructions and to the extent required by the service.

Where the servers of some of these service providers are located abroad, your personal data may be transferred abroad in accordance with the conditions set out in KVKK Art. 9. Your special categories of personal data (health data) are not shared with third parties beyond the scope of your explicit consent.

Third-party websites linked from our Site are subject to their own privacy policies; our Company is not responsible for the content and practices of these sites.

8. Commercial Electronic Messages

The sending of commercial electronic messages to you for e-newsletter, campaign or promotional purposes is subject to your explicit consent pursuant to Law No. 6563 on the Regulation of Electronic Commerce. You may give this consent via a checkbox in the membership form or the test result form that is separate from the membership/transaction approval and is not pre-ticked. You may stop these messages at any time by using the “reject/unsubscribe” link in the messages, by notifying iletisim@vitalyglobal.com, or through the Message Management System (İYS).

9. Rights of the Data Subject

Your rights under KVKK Art. 11 (including the right to learn whether your personal data is processed, to request information, to request correction/deletion, to object and to claim compensation for damages) and the method of applying for these rights are set out in detail in Sections 10 and 11 of the KVKK Privacy Notice.

10. Storage and Destruction of Data

Your personal data is retained for the period required by the purpose of processing and for the retention periods stipulated in the relevant legislation; upon expiry of these periods or when the purpose of processing no longer exists, it is deleted, destroyed or anonymized.

11. Policy Changes

Our Company reserves the right to make changes to this Privacy Policy in line with legislative changes or updates to our business processes. The updated Policy becomes effective as of the date it is published on the Site. Users are advised to check the Site periodically.

12. Contact

You may submit your questions, requests and complaints regarding the Privacy Policy to our Company through the following channels:

Address: İçerenköy Mah. Umut Sk. No:10-12 Quick Tower Kat:16 Ataşehir/İstanbul

Email: iletisim@vitalyglobal.com

Website: www.vitalyglobal.com

Mersis No: 0925-1331-2630-0001