Meditopia Privacy Policy

The purpose of this Privacy Policy is to set out the terms and conditions regarding the usage of the information and data shared by natural and/or legal person (“User” or “you”) visiting www.meditopia.com (the “Website”) or downloading Meditopia application (the“Application”) to Yedi70 Yazılım ve Bilgi Teknolojileri A.Ş. (the “Company” or “Yedi70” or “we” or “us”) registered at the address Acıbadem Mahallesi Cecen Sokak Akasya Acıbadem Kent Etabı A Blok Kat: 20 No: 85 Uskudar, Istanbul, Turkey with MERSİS number 0946024351100016. This Privacy Policy is an annex and an inseparable part of the User Contract executed with the User, and it applies when you visit or use the Website, download or use the Application, or related services (the “Services”).

Who processes your personal information?

We, as a legal entity incorporated under the laws of Republic of Turkey and with the following contact information, process your personal information:

YEDİ70 YAZILIM VE BİLGİ TEKNOLOJİLERİ ANONİM ŞİRKETİ

Acıbadem Mahallesi Cecen Sokak Akasya Acıbadem Kent Etabı A Blok Kat: 20 No: 85 Uskudar, Istanbul, TURKEY

Email: [email protected]

If you are in Europe, you may also contact our representative appointed according to GDPR Art. 27:

Meditopia GmbH : The Meditation Company GmbH

Address : Brandenburgische Strasse 86/87, 10713 Berlin Deutschland

Email : [email protected]

What Information Do We Need to Process?

We collect certain information directly from you, which includes but is not limited to the information you provide as a response to the questions we ask. We also collect your personal data from third parties, such as the information in your profile in the social media platforms you connect with the Website and/or the Application. There is also certain data we collect automatically, like information about your device and what sections of our Services you interact with or spend time using.

The Information We Collect Directly from You:

We may collect personal information from you, such as your name, email address, password and date of birth (“Profile Data”), when you are setting up your profile. We may also provide you with the option of putting in additional personal information, such as a photograph and the information you may put into the “My Notes” section of the Application.

We use a third-party payment processor to process payments made to us. In connection with the processing of such payments, we do not retain any financial information such as credit card numbers. Rather, all such information is provided directly to our third-party processor. In such circumstances, the third-party service provider, and not Yedi70, stores your payment information on our behalf.

You may be invited to complete a form or a survey, share your testimony, or participate in a promotion (like a contest or challenge) or a user generated content (like podcasts), either through the Services or a third-party platform, such as Typeform. If you participate, we will collect and store the data you provide as part of participating, such as your name, email address, date of birth and/or phone number. The mentioned data is and will be subject to the rules of this Privacy Policy, unless the rules of a campaign or another and more specific privacy policy, which will also be submitted to your attention, contains a contrary or different rule. Provided that you have given your explicit consent, we may collect, store and publish your photograph, for the purpose of sharing your testimony with others through the Application, the Website, email bulletin, or any other means. Where we use a third-party platform to administer a survey or promotion, the third party’s privacy policy will apply.

If you contact us for support or to report a problem or concern (regardless of whether you have created a profile), we collect and store your data such as your contact information, messages, and other data, including but not limited to your name, email address, language, location, operating system, IP address, and any other data you provide or that we collect automatically. We use this data to respond to you and research your question or concern, in line with the rules of this Privacy Policy.

The Information We Collect from Third Parties

We may obtain certain information through your social media profiles or other online accounts you have permitted to be connected to the Application. If you login to the Application via Facebook or another third-party platform or service, we ask for your permission to access certain information which is already given under that account, such as your name, profile picture, account ID number, email address, location, physical location of your access devices, and birthday.

Those platforms and services make information available to us through their APIs, and therefore, the information given to us is limited with the scope of your privacy settings in the platform or service.

If you access or use our Services through a third-party platform or service, the collection, usage, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.

We may also obtain information through Third Parties, which we have a business or legal relationship with, such as business partners, technical, payment and delivery service subcontractors, advertising networks, analytics providers or search information providers.

The Information We Collect Through Automated Means:

When you access the Services, we collect certain data by automated means, including but not limited to technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types (“System Data”); usage statistics about your interactions with the Services, including meditations accessed, time spent on the Service, pages visited, features used, your search queries, click data, date and time, and other data regarding your use of the Services (“Usage Data”); an approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.

We also collect certain information through Apple Health and/or Google Fit, provided that you have given your explicit consent.

Apple HealthKit. We use Apple’s HealthKit framework, which provides a central repository for health and fitness data on iPhone and Apple Watch and – with your explicit consent – lets apps communicate with the HealthKit store to access and share this data. If you download and use Apple Watch version of the Application, we may collect and process your heart rate data, obtained through the HealthKit framework and the Apple CoreMotion framework, with your explicit consent. New data attributes may be added to the HealthKit framework, which will be portrayed in the Application and which you have to consent to.

Yedi70 may analyze engagement data for research purposes designed to provide a personalized experience and motivate engagement in healthy habits. We do not use information gained through the HealthKit framework for advertising or similar services. You can always stop us from accessing your data by changing the settings of your mobile device.

If you grant the Application access to HealthKit, it can add information to certain sections of HealthKit, ie. adding the minutes of meditation that the User is listening to in the Application to the Awareness Time section in HealthKit.

Google Fit. We use Google’s Fit SDK which is an open platform that lets users control their fitness data. We do not collect or process any data from Google Fit. However, we may add information to certain sections of Google Fit, ie. adding the minutes of meditation that the User is listening to in the Application to the Awareness Time section in Google Fit. New data attributes may be added to the Google Fit framework, which will be portrayed in the Application and which you have to consent to.

We also use cookies to access information when you sign in, store your preferences, to keep you logged in, and to store a limited amount of behavioral data.

What We Use Your Information For?

Your personal data collected hereunder may be processed

● to develop, improve, personalize, provide, and administer the Services, including to display customized content.

● to process your requests and orders for products, specific services, information, or features;

● for correspondence with you about the Services by:

○ responding to your questions, requests and concerns;

○ sending you administrative messages and information, including messages from our team, notifications about changes to our Service, and updates to our agreements;

○ sending you information and e-mail about your progress in meditations, rewards programs, new services, new features, promotions, advertising, newsletters, and other available products and services which you can opt out of at any time;

○ sending push notifications to your wireless device to announce campaigns and promotions, to recommend content, and to provide updates, daily quotes, and other relevant messages.

○ offering you the possibility of taking part in user generated contents.

● to manage your profile preferences;

● to maintain and develop the technical functioning of the Services, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse;

● to solicit feedback from users;

● to market and administer surveys and promotions administered or sponsored by us;

● to learn more about you by linking your data with additional data through third-party data providers or analyzing the data with the help of analytics service providers;

● to identify unique users across devices;

● to tailor advertisements across devices;

● to improve our Services and develop new products, services, and features;

● to analyze trends and traffic, track purchases, and track usage data;

● to advertise the Services on third-party websites and applications;

● as required or permitted by law; or

● as we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services.

Profile Data, System Data and Usage Data, will be stored in our secured database for a period of 1 (one) year following the User's deletion of the Application or termination of membership to expedite the process and for user satisfaction if the User who was a member of the Application subsequently wishes to re-join.

Who Do We Need to Share Your Information With?

By using our Services, you give explicit consent to sharing of your information with third parties by the Company, for the purposes set forth in this Privacy Policy. In addition, you accept and undertake that your information may be shared:

With Service Providers, Contractors, and Agents: We share your data with third parties who perform services on our behalf, like payment processing, data analysis, marketing and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service. We may transfer your information to the servers located anywhere in the world and outside the country of your domicile.

With Analytics and Data Enrichment Services: As part of our use of third-party analytics tools, like Amplitude, and data enrichment services, we share certain contact information, Profile Data, System Data and Usage Data, or de-identified data as needed. De-identified data means data where we’ve removed things like your name and email address and replaced it with a token ID. This allows these providers to provide analytics services or match your data with publicly available database information (including contact and social information from other sources). We do this to communicate with you in a more effective and customized manner.

To Power Social Media Features: The social media features in the Services (like the Facebook Like button) may allow the third-party social media provider to collect things like your IP address and which page of the Services you’re visiting, and to set a cookie to enable the feature. Your interactions with these features are governed by the third-party company’s privacy policy.

To Administer Promotions and Surveys: We may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, in accordance with this Privacy Policy, or the rules of the promotion or survey.

For Advertising: If we decide to offer advertising in the future, we may use and share certain System Data and Usage Data with third-party advertisers and networks to show general demographic and preference information among our users. We may also allow advertisers to collect System Data through automated data collection tools like cookies, tags, scripts, customized links, device or browser fingerprints, and web beacons (together, “Data Collection Tools”), and to use this data to offer you targeted ad delivery to personalize your user experience (through behavioral advertising) and undertake web analytics. Advertisers may also share with us the data they collect about you. Note that if you opt out, you will continue to be served generic ads.

For Security and Legal Compliance: We may disclose your data to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:

○ Permitted or required by law;

○ Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;

○ Reasonably necessary as part of a valid subpoena, warrant, or other legally valid request;

○ Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;

○ Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues; or

○ Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of Yedi70, our users, employees, members of the public, or our Services.

○ We may also disclose data about you to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy.

During a Change in Control: If Yedi70 undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence).

After Aggregation/De-identification: we can disclose or use aggregate or de-identified data for any purpose.

With Your Permission: with your consent, we may share data to third parties outside the scope of this Privacy Policy.

What We Do to Secure Your Information

We are actively seeking and taking the most effective, appropriate and commercially reasonable physical, managerial, and technical safeguards designed to secure your information from accidental loss and from unauthorized access, use, alteration and disclosure.

Our employees and service providers are under obligations of non-disclosure and confidentiality. Also, our service providers are under the obligation to comply with the provisions of the data processing agreement, which they are subject to, if applicable.

We Might Be Required to Retain Some of Your Information

We do not keep your information we collect and process for the purposes identified in this Privacy Policy for longer than is necessary for the specific purpose specified in this Privacy Policy, unless we are required to retain those information for a longer period of time to comply with our legal obligations, enforce our legal agreements and policies, and resolve disputes.

Last but Not Least

The Website may contain links to other sites and applications and the Company does not bear any responsibility for the privacy practices and contents of those sites and applications.

The Company may change the provisions of this Privacy Policy by publishing it on the Website and/or the Application at any time. The Company's amended Privacy Policy provisions become effective on the date when they are posted on the Website and/or the Application

Please send your questions, opinions, and recommendations regarding privacy and any other issue to [email protected]. It is an honor and privilege to help you with being a happier, more peaceful and mindful person and every other issue.