As Kulaçsu Sports Services Ltd. (“Kulaçsu Yüzme Akademisi”), we process your personal data as data controller under the Turkish Personal Data Protection Law No. 6698 (KVKK), for the purposes and on the legal grounds explained below and in line with the principle of proportionality.
Categories of personal data
- Identity and contact details (student and parent)
- Level, attendance, training and race-time records
- Health declaration and medical certificate for the licence (with explicit consent)
- Payment and invoice details
- Security camera footage of common areas (not the pool hall)
- Technique analysis videos (shared only with the parent)
Purposes of processing
Managing enrolment and contracts, planning levels and lessons, ensuring pool safety, handling licences, collecting fees and invoicing, communicating with parents and meeting legal obligations.
Legal grounds
Under Article 5/2 of the KVKK your data is processed for the conclusion and performance of a contract, compliance with legal obligations, the establishment and protection of a right and our legitimate interests. Special-category data such as health declarations and medical certificates is processed only with your explicit consent under Article 6 and is accessible to authorised staff only; sharing photos or videos and sending commercial electronic messages also require your explicit consent. Data of minors is processed with the consent of a parent or guardian.
Transfers
Data may be transferred to the Turkish Swimming Federation and its provincial office for licences, to our accountant for invoicing, to our payment provider for payments and to authorised public bodies as required by law. No transfers are made abroad.
Retention
Data is kept for the periods required by law (10 years for commercial books and records) and is then deleted, destroyed or anonymised. Health declarations are destroyed no later than two years after membership ends.
Your rights
Under Article 11 of the KVKK you have the right to learn whether your data is processed, request information, rectification or erasure, know the third parties to whom it is transferred, object and claim compensation. You can send your request in writing to kvkk@kulacsu.com.tr or to Ataköy 7-8-9-10. Kısım Mah. Yalı Sok. No: 6, Bakırköy / İstanbul, in line with the Communiqué on the Procedures and Principles of Application to the Data Controller; requests are answered free of charge within 30 days. Questions: +90 212 561 48 20.