AKORT Privacy Policy

This privacy policy explains how the AKORT mobile application (the “App”), developed and operated by FUGİ Bilişim Teknolojileri Anonim Şirketi (“FUGİ”, “we”), collects, uses, shares, stores and protects your personal data. It applies to the Android and iOS versions of the App and includes the information notice required under Turkish Personal Data Protection Law No. 6698 (“KVKK”). The Turkish version of this policy prevails in case of any difference.

1. Who we are and our roles

AKORT is a platform that lets clients follow their nutrition and health together with the clinic and dietitian they receive services from. There are therefore two roles regarding your data:

• Your clinic: is the data controller for data processed as part of the clinical health service (medical history, measurements, nutrition plan, messages with your dietitian and clinical follow-up records). FUGİ processes this data on behalf of the clinic and according to its instructions, as a data processor.
• FUGİ: is the data controller for creating and verifying your account, the security and technical operation of the App, and support requests sent to FUGİ.

If you are not sure whom to contact, write to fugigamestudio@gmail.com; we will resolve your request together with the relevant clinic.

2. What data we process

Not all of the data below is processed for every user. For example, the health app connection, smart device pairing, photos or voice recordings are only used when you use that feature and grant the required permission.

Account and contact information

• Phone number (for sign-in and SMS verification)
• First name, last name, date of birth, gender, email address, profile photo
• The clinic and dietitian you are connected to

Medical history (anamnesis)

Your answers to the nutrition and health assessment form (anamnesis) in the App, for example:

• Height, weight, body measurements and weight history (highest/lowest weight, previous diets)
• Diagnosed conditions, family history of chronic disease, past surgeries and procedures
• Regular medication, food allergies and intolerances, digestive complaints
• Pregnancy and breastfeeding, history of eating disorders, bariatric (obesity) surgery history
• Sleep pattern, smoking and alcohol use, physical activity habits
• Meal pattern, eating habits and the effect of mood on eating
• Blood test values you share (e.g. blood glucose, cholesterol, vitamin levels)

Nutrition records

• Meal, food, portion and water intake records
• Meal photos and the food estimates generated from them
• The nutrition plan assigned to you and progress records

Communication with your clinic

• Messages with your dietitian in the App
• Documents, files, photos and voice recordings you send
• Appointment records

Service, transaction and support records

• Services and contracts you have, payment and collection records
• Your support requests and correspondence

Technical and security data

• IP address, device model, operating system and app version
• Session information and the notification token used to send notifications
• The time of the permissions and consents you give or withdraw, and the version of the text you accepted

Data kept on your phone

The App keeps some records on your phone in order to work, such as session and app state, the last health sync time and paired smart device information. These records are removed from your phone when you uninstall the App.

3. Data from your phone's health app

The health connection is optional. When you turn it on and grant permission, the App reads the following data through Health Connect on Android and Apple Health (HealthKit) on iPhone, to the extent available on your device and connected sources:

• Read only: The App does not write data to Health Connect or Apple Health and does not change or delete records there.
• Historical data: On the first sync, records from up to the last 90 days are read, as permitted. On Android, a separate historical data access permission is requested for this. This is a reading window, not a retention period.
• When data is synced: When you open the App and when the App returns to the foreground. The App does not read Health Connect data in the background.
• Transfer to our server: The data read is sent to the AKORT server together with the data type, value, unit, measurement date and time, source app or device name, source device identifier (if any), device model, recording method and record identifiers. This data is not anonymous; it is linked to your account and to the clinic you are connected to.
• Purpose: To show you your health and nutrition tracking, create personal summaries and assessments, and support your dietitian's follow-up.

Our commitment for health data: Data received from Health Connect and Apple Health, including your health and nutrition data, is not used for advertising, marketing, targeting or profiling, is not sold, is not transferred to data brokers and is not used to train artificial intelligence models. It is used only to provide the App's health and nutrition tracking features to you, and is shared, with your consent, only with the clinic you are connected to. AKORT's use of information received from Health Connect adheres to the Health Connect Permissions policy, including the Limited Use requirements; use of Apple Health data complies with Apple's HealthKit guidelines.

4. Smart ring and band connection

If you pair a compatible smart ring or band directly with the App via Bluetooth, the following data is received from that device independently of Health Connect or Apple Health (depending on device support):

• Steps, sleep duration and sleep stages (deep, light, REM, awake)
• Heart rate, heart rate variability, blood oxygen, skin temperature and, on supporting devices, respiratory rate
• Estimated stress, blood pressure and sleep apnea risk values generated by the device
• Device name, brand and model, Bluetooth identifier, firmware version, battery status, pairing and sync times, and raw technical records from the device

On Android, if a device is paired, data may be synced in the background at intervals set by the operating system (about every 15 minutes). You can stop this by removing the pairing in the App.

Estimated values are based on the device manufacturer's algorithms; they are not medical measurements or diagnoses. We do not guarantee the accuracy of the devices.

Information derived from health data

From your data, the App produces personal results such as daily and weekly health summaries, personal averages and deviations from them, weight and body composition changes, energy balance and rest/recovery assessments. Some of these assessments use resting heart rate, heart rate variability, sleep and skin temperature data. These derived results are also protected as health data.

5. App permissions

Permissions are requested only when you use the related feature; if you do not grant a permission, only that feature will not work.

• Health data (Health Connect / Apple Health): To read the data listed in Section 3.
• Bluetooth: To find and connect a smart ring or band and receive its data. On Android 11 and earlier, Bluetooth scanning requires the location permission by operating system design; the App does not collect or store your location with this permission.
• Camera and photos/files: When you send a meal photo, profile photo or document.
• Microphone: When you send a voice message to your dietitian. The App does not record continuously.
• Notifications: For appointment, message and reminder notifications.

6. Why we use your data

• To create your account and verify your phone number by SMS
• To show you your nutrition plan, records, health data and progress
• To create personal health summaries and assessments
• To enable your clinic and dietitian to follow your progress, communicate with you and manage appointments
• To send notifications
• To run service, contract, payment and support processes
• To keep the App secure, prevent misuse and fix technical errors
• To keep consent records and meet our legal obligations

7. Legal bases

Your data is collected automatically (through the App and connected health apps and devices) and through the information you enter. The legal bases are:

• Health data (anamnesis, measurements, health app and device data, and results derived from them): special category personal data under Article 6 of KVKK; processed based on your explicit consent and the other conditions for health services set out in Article 6.
• Account, contact, service and support data: establishment and performance of the service contract with you (KVKK Art. 5/2-c).
• Security and technical data: our legitimate interests (KVKK Art. 5/2-f) and legal obligations (KVKK Art. 5/2-ç).

You can withdraw your explicit consent at any time. Withdrawal does not affect the lawfulness of processing before it, but the related features may no longer be available.

8. Who we share data with

• Your clinic and dietitian: see your health, nutrition and communication data to provide your follow-up. Authorised clinic staff access only the data needed for their role.
• İlkbyte (Türkiye): server, database and document archive hosting.
• Verimor (Türkiye): sending SMS verification codes; your phone number and the SMS content.
• Google – Firebase Cloud Messaging: sending notifications; notification token, notification content and routing information.
• Google – Gmail: handling support emails; the content of your email and your contact details.
• FUGİ's authorised technical staff: only as needed for operation, security and support.
• Competent public authorities and courts: when legally required.

We do not share your data with any other third parties, and we do not sell it to advertising companies or data brokers.

9. Where data is stored and international transfers

The App's servers, database and document archive are located in İlkbyte data centres in Türkiye. Because notification delivery (Firebase Cloud Messaging) and support email (Gmail) are provided by Google, the limited data these services process (notification token and content, email correspondence) may be processed on servers outside Türkiye. These transfers are made in accordance with Article 9 of KVKK. Your health measurements and anamnesis data are not included in notification content.

10. Retention

• Account, health, nutrition and message data: kept while your account is open and your service relationship with the clinic continues.
• When you delete your account: this data is deleted or anonymised within 30 days at the latest. Copies in backups are deleted within 90 days at the latest as part of the backup cycle.
• Records that must be kept: clinical health service records, invoice and payment records, and security and consent records are kept for the period required by law and deleted afterwards.
• Records on your phone: removed from your phone when you uninstall the App.

11. Managing permissions and data, deleting your account

• Turning off the health connection: On Android, remove AKORT's access in the Health Connect settings; on iPhone, go to Settings > Health > Data Access & Devices. This stops new data from being read; data already sent to the server is not deleted automatically.
• Removing a smart device: When you remove the pairing in the App, data is no longer received from the device.
• Withdrawing your explicit consent or requesting deletion of past data: write to fugigamestudio@gmail.com.
• Deleting your account: In the App, go to Profile > Delete my account (“Hesabımı Sil”), or follow the method on the account deletion page.

12. Security

Your data is transferred between the App and our servers over an encrypted connection (HTTPS/TLS). Access to data is restricted by authorisation; client data can be accessed only by authorised staff of the clinic you are connected to and by technical staff authorised for their role, and access is logged. No system is completely risk-free; in case of a data breach we make the notifications required by KVKK.

13. Age limit

The App is designed for users aged 18 and over. If we learn that we have collected data from anyone under 18, we delete it.

14. Your rights under KVKK

Under Article 11 of KVKK you have the right to:

• Learn whether your personal data is processed and, if so, request information about it
• Learn the purpose of processing and whether data is used for that purpose
• Know the third parties in Türkiye or abroad to whom data is transferred
• Request correction of incomplete or inaccurate data
• Request deletion or destruction of your data under the conditions in Article 7 of KVKK
• Request that corrections and deletions be notified to third parties to whom data was transferred
• Object to a result against you arising solely from automated analysis
• Claim compensation for damage caused by unlawful processing

You can send your requests by email to fugigamestudio@gmail.com, stating the phone number registered in the App, or in writing to our address above. We respond free of charge within 30 days at the latest.

15. Medical disclaimer

AKORT is not a medical device; it does not diagnose and does not replace medical advice. Measurements, estimated values and assessments in the App are for information only. Consult your doctor or dietitian for decisions about your health; in an emergency call 112.

16. Changes and contact

We may update this policy. We announce significant changes in the App and ask for your consent again where required. The current version, with its effective date, is always on this page.

Questions: fugigamestudio@gmail.com