Yuppo Privacy Policy
Introduction:
This Privacy Notice ("Notice") has been prepared by Upgrade Teknoloji Anonim Şirketi ("Company"), a corporation established under the laws of the Republic of Turkey, registered with the Istanbul Trade Registry under number 469779-5, and having its registered office at Sultan Selim Mah. Libadiye Sk. No: 3, İç Kapı No: 1, Kağıthane / İstanbul.
The purpose of this Notice is to ensure that your personal data processed within the scope of the Yuppo mobile application, as well as all elements arising from the User Agreement and related contractual relationships ("Yuppo"), are processed in compliance with the Constitution of the Republic of Turkey, the international human rights conventions to which Turkey is a party, Law No. 6698 on the Protection of Personal Data (KVKK), the EU General Data Protection Regulation (GDPR), other applicable legislation, and the decisions of the Personal Data Protection Authority, and to enable you to exercise your rights effectively.
Definitions
In this Notice, the terms "personal data," "special categories of personal data," and "data processing" are used in accordance with the definitions set forth in the Personal Data Protection Rules.
- "Personal data" means any information relating to an identified or identifiable natural person.
- "Special categories of personal data" include information on an individual's race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, association, foundation or trade union membership, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data.
- "Processing of personal data" refers to any operation performed on personal data, whether or not by automated means, such as collection, recording, storage, retention, alteration, rearrangement, disclosure, transfer, retrieval, classification, or preventing the use of such data.
Data Categories Collected
Yuppo collects all types of data (excluding special categories of personal data) that Users share with Upgrade under the User Agreement. The main categories of data collected include:
| Data Category | Examples of Data | | --- | --- | | Identity Information | Name, email address, profile photo; information on children registered per user. | | Child Information (0-6 years) | Name, gender, relation to user, date of birth, premature birth status (including gestational week). | | Unborn Child Information | Name, gender, relation to user, pregnancy week, twin status. | | Communication Preferences | Permission status for app notifications. | | Interactions & Interests | Stated interests (optional), engagement with app content (viewing, reading, updating, etc.). | | Tracking Tools | Sleep tracking (manual or automatic), vaccination data (Ministry of Health schedule and user-added entries), weight and height logs (with timestamps and charts), photo albums, feeding details (breast milk, formula, solid food), diaper changes (date, content, color, texture). | | Development Tracking | Physical, cognitive, language, and socio-emotional milestones (as marked with user consent). | | Usage Information | Time spent in app, login/logout times, device details (type, OS, city/country-based location). | | AI-Related Data | Chatbot history and natural language processing data, in-app search history. | | IP & Subscription Information | IP address, subscription type, and payment history. |
Purposes of Processing Personal Data
Your personal data - including but not limited to your name, surname, email, phone number, and address - transmitted via Yuppo, may be processed for the following purposes:
Service Provision and User Experience Improvement
- Creating and verifying membership accounts.
- Providing products, services, and content tailored to the age and needs of the children registered by the user.
- Personalizing the application experience.
App Development and Analytics
- Analyzing user behavior to improve app performance and develop new features.
- Visualizing user interactions and engagement metrics for analytical purposes.
Natural Language Processing
- Analyzing conversations with the AI-powered chatbot and providing personalized suggestions based on keywords.
Legal and Administrative Compliance
- Fulfilling legal obligations and protecting the Company's rights.
- Managing and resolving potential disputes.
User Experience and Communication
- Managing subscription services and user requests.
- Providing data portability upon request.
- Enhancing and developing Yuppo.
Additionally, your personal data may be processed for compliance with consumer protection, e-commerce, and electronic communication regulations, to issue invoices following purchases, to respond to inquiries and complaints, and to retain data for the statutory limitation period.
Transfer of Personal Data
Your personal data may be transferred-within the scope and purposes outlined in this Notice-to:
- Private and public legal entities within Turkey and abroad,
- Authorized public institutions and judicial authorities where legally required,
- Business partners and group companies contributing to Yuppo's services,
- Domestic and international service providers for hosting, storage, or analytics purposes,
- User family members (if explicitly shared),
in compliance with the provisions of Articles 8 and 9 of the Personal Data Protection Rules and relevant data transfer principles under applicable law.
Data Collection Methods and Legal Basis
Your personal data may be collected in written, verbal, or visual form through the contracts you sign and via the Yuppo platform.
The legal bases for processing are:
- Your explicit consent pursuant to Article 5(1) and Article 6(2) of the Personal Data Protection Rules.
- Cases falling under the exceptions to consent as specified in Article 5(2)(c), (ç), (e), and (f) of the Personal Data Protection Rules.
Your data are collected, processed, and transferred by the Company in accordance with the applicable legislation and the purposes set forth in this Notice.
Your Rights as a Data Subject
As a data subject, you may contact the Company to:
- Learn whether your personal data are processed,
- Request information about such processing,
- Learn the purpose of processing and whether your data are used in accordance with that purpose,
- Learn the third parties to whom your data have been transferred domestically or abroad,
- Request correction of incomplete or inaccurate data,
- Request deletion or destruction of your data under Article 7 of the Personal Data Protection Rules,
- Request notification of corrections or deletions to third parties to whom data have been transferred,
- Object to processing that results in an outcome against you through automated systems,
- Request compensation if you suffer damages due to unlawful processing of your data.
You can exercise these rights by contacting us at [email protected].
Explicit Consent Statement
This Explicit Consent Statement has been prepared in accordance with Law No. 6698 on the Protection of Personal Data to document whether you consent to the processing of your personal data and special categories of personal data, as detailed in the Privacy Notice above.