1. Who we are

İnalbay Tekstil Danışmanlık Ticaret Limited Şirketi ("we", "us") operates mutasyonacademy.com and provides online fitness and nutrition coaching. We are the controller of the personal data described in this notice.

Address: Ferhatpaşa Mah. 41. Sk. Şura Apt. No:50 B, Ataşehir, İstanbul, Türkiye

Trade registry (Mersis) No: 0475104291000001

Email: info@mutasyonacademy.com

2. Scope

This notice applies to users located outside Türkiye, including in the European Economic Area, the United Kingdom and the United States. Users located in Türkiye are covered by our Turkish privacy notice. Where both apply, we give you the protections of both.

3. What data we collect

• Identity data: first name, last name

• Contact data: email address, phone number

• Transaction data: account details, order history, package purchased, payment amount and date

• Technical data: IP address, browser and device information, session logs, cookie identifiers

• Marketing data: browsing behaviour and advertising interaction data

• Health data: height, weight, body measurements and health information you provide for your coaching programme

• Images: before-and-after photographs, where you have given separate written permission

4. Why we process it and our legal basis

• Creating and managing your account — performance of a contract, Art. 6(1)(b)

• Preparing and delivering your coaching programme — performance of a contract, Art. 6(1)(b)

• Processing payments and issuing invoices — contract and legal obligation, Art. 6(1)(b) and (c)

• Meeting tax and accounting obligations — legal obligation, Art. 6(1)(c)

• Site security and fraud prevention — legitimate interests, Art. 6(1)(f)

• Marketing emails and marketing cookies — consent, Art. 6(1)(a)

• Height, weight and body measurements — explicit consent, Art. 9(2)(a)

• Publishing before-and-after photographs — explicit consent, Art. 9(2)(a)

Where we rely on legitimate interests, our interest is keeping the service secure and operating correctly. You can object at any time (section 8).

Your height, weight and body measurements are used solely to prepare your personal nutrition and training programme. They are not used for marketing, not shared with advertising platforms, and not disclosed to any third party other than the hosting infrastructure needed to provide the service.

Providing your identity, contact and payment data is necessary to create your account and deliver the service; without it we cannot provide the coaching programme. All other data, including marketing preferences, is optional.

5. Who we share it with

• iyzico Ödeme Hizmetleri A.Ş. (Türkiye) — payment processing. We never store your card details.

• Our hosting and infrastructure providers — running the website and mobile app.

• Meta Platforms Inc. (United States) — advertising measurement, only where you consented to marketing cookies.

• Accountants and auditors — statutory reporting.

• Public authorities — where legally required.

We do not sell your personal data.

6. International transfers

We are established in Türkiye, which is outside the European Economic Area. Where you provide data to us directly, it is processed on our systems in Türkiye. Marketing data may be shared with Meta Platforms Inc. in the United States, and only where you have consented.

We apply appropriate safeguards to protect your data, and you may request details of these by contacting us at the address above.

7. How long we keep it

• Account and contact data — 3 years after your membership ends

• Order, invoice and payment records — 10 years, as required by Turkish tax law

• Height, weight and body measurements — 2 years after the coaching service ends

• Before-and-after photographs — until you withdraw your consent

• Cookie data — as set out in our Cookie Policy

• Consent records — 3 years after consent is withdrawn

At the end of the retention period we delete, destroy or anonymise the data.

8. Your rights

If you are in the EEA or the UK you have the right to:

• Access — obtain a copy of the personal data we hold about you

• Rectification — have inaccurate or incomplete data corrected

• Erasure — have your data deleted in certain circumstances

• Restriction — limit how we process your data

• Portability — receive your data in a machine-readable format

• Object — to processing based on legitimate interests, and to direct marketing at any time

• Withdraw consent — at any time, without affecting processing carried out before withdrawal

• Complain — to your national supervisory authority

To exercise any of these rights, email info@mutasyonacademy.com. We will respond within one month, free of charge.

9. Cookies

We use strictly necessary cookies to operate the site. Marketing cookies are only set where you have consented. You can set your preferences when you first visit and change them at any time using the "Cookie Settings" link in the footer. Full details are in our Cookie Policy.

10. Automated decision-making

We do not make decisions producing legal or similarly significant effects about you based solely on automated processing. Your coaching programme is prepared by a human coach.

11. Children

Our services are not directed at children under 18 and we do not knowingly collect their data. If you believe a child has provided us with personal data, contact us and we will delete it.

12. Changes

We may update this notice from time to time. The current version is always published on this page.

Effective date: 09.09.2026 | Version: 1.0