# General Mobile GM Watch Privacy Policy
Latest update: December 01, 2021
Effective as of December 01, 2021
Dear Users,
At General Mobile ("Company"), we are aware of how important it is for you to keep your private life and personal data confidential and therefore, we would like to inform you as per the Law No. 6698 on the Protection of Personal Data and other applicable legal legislation with regards to your use of our GM Watch product ("Product"). To this end, we prepared this Privacy Policy to inform you about how we collect, process, use and transfer your information.
For the purposes of this Privacy Policy, "personal data" means any information relating to an identified or identifiable natural person.
Before using our products (or services), we recommend you to read this Privacy Policy carefully and thoroughly to understand our approach to customer privacy.
If you have any questions, complaints or suggestions about this Privacy Policy, please contact us using the contact information set forth below.
This Privacy Policy will help you understand the following:
- 1. How We Collect Your Personal Data
- 2. How We Use Cookies and Similar Technologies
- 3. How We Use Your Personal Data
- 4. How We Share, Transfer and Disclose Your Personal Data
- 5. How We Protect Your Personal Data
- 6. How Your Personal Data is Transferred Globally
- 7. How We Store Your Personal Data
- 8. Your Rights to Your Personal Data
- 9. Privacy of Minors/Children
- 10. How Your Personal Data is Managed under GDPR
- 11. Updates to This Privacy Policy
- 12. Contact Us
## 1. How We Collect Your Personal Data When you use our products and services, we may collect the following categories of your personal data.
**Account information**: If you create an account on our application, you may need to provide your country or region, email address, password, date of birth, gender, height, and weight. You may also choose to provide any additional information, such as your nickname, weight goals, step goals, and profile picture.
**Exercise and health related information**: If you use the health data recording and analysis function provided by us, we will collect your exercise and health related information, such as steps, distance, speed, exercise duration, calories, sleep duration, heart rate, pressure, oxygen saturation, walking time, moderate and high intensity exercise, exercise type, detailed exercise records for each exercise type, for the purposes of the implementation of health data recording and analysis function.
**Location information**: Your GPS location information will be used when you use certain location-based services, such as starting outdoor exercise mode, checking the weather, and selecting your location. We will not collect such information if you prevent the GPS feature of your mobile phone from being activated.
**Device and application information**: When you use our device and application, we will obtain your device and application information, such as user configuration data, MAC address, version number, serial number, firmware version, language, application version, mobile phone system version, device configuration, IP address, network type, and device ID, for the purposes of making statistics and analysis on your use of the products.
**Service information**: When you use the features of any applications on the product, you may need to submit your personal data to use the related services, such as reminder settings. If you use the Female Physiological Cycle Reminder feature, we may collect information, such as the menstrual periods and ovulation periods, you provide. If you use the Call Reminder feature, we may read your call status and contacts, but we will not store your communication content. When you use the Message Notification feature, we may access the notification status of a third-party application. In such case, our device will temporarily store your message for a maximum period of time. If you use the Music Control feature, we may read but will not store your music switch information such as song play and song status.
**Feedback information**: If you have any concerns or suggestions about our products and services, you can give us feedback through the official Company channels. This feature allows us to collect your feedback, and your contact information (if you provide it). Such information will be used to help us better understand your concerns and get in touch with you. During the feedback process, we may access your mobile phone's camera, photo albums, etc., subject to your consent. Thus, you can provide us with specific photos or videos when you give us any feedback to help us better understand and respond to your concerns or suggestions about our products and services.
**Log information**: To keep your device and application up and running, when you use our device or application, we may collect certain data about your use of the device or application, such as creating or logging into your account, matching your account with the device, number of device restarts, network usage information, system errors, system crashes, system restarts, and system upgrades, and thus providing more stable services for you. Your latest 7-day log information will be automatically stored locally on your mobile phone, and the historical log information will be automatically deleted.
**Visitor information**: When you use the Login Free feature (applicable if you have not registered or logged in), you may experience our products in a limited way. Your personal data (such as nickname, gender, height, weight, date of birth, and exercise and health related data) will be stored locally on your mobile phone, and we will not upload such data to our server.
## 2. How We Use Cookies and Similar Technologies
### (1) Cookies
a) What are Cookies? Cookies are small files transmitted by our application or service and stored on your device. The Product may use cookie technology. Cookies may be stored on your device for a shorter or longer period of time, or even for years. Except for browser's self-layout of cookie, we do not set any Cookie in our website, applications or services.
The Cookies We Use We use Cookies to better understand how often you use the Product, the incidents, cumulative usage, and performance data of the Product, and the overall characteristics of the users so that we can analyze the trends, manage the website, and track user behaviors online.
b) Delete/disable Cookies Cookie management and preference must be done within your browser's options or preferences menu. Below are some guidelines on how to do this in common browser software: - Microsoft Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies - Microsoft Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy - Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer - Google Chrome: https://support.google.com/chrome/answer/95647?hl=en - Safari for macOS: https://support.apple.com/kb/PH21411 - Safari for iOS: https://support.apple.com/en-gb/HT201265
c) More details of Cookies Please visit www.allaboutcookies.org for more information about the Cookies and the instructions on setting up your browser to accept, delete, or disable the Cookies.
### (2) Web beacons and pixel tags In addition to Cookies, we will use other similar technologies such as web beacons and pixel tags on the website. For example, the email we send you for application registry purposes may contain a URL that links to the content of our website. If you click on this link, we will track your preferences and behaviors in accordance with those stated here to help us understand your preferences for product or service and thus improve our customer services. A web beacon is usually a transparent image embedded in a website or an email. The pixel tag in the email allows us to figure out whether the email is read or not. If you do not want your activities to be tracked in this manner, you may unsubscribe from our mailing list at any time.
## 3. How We Use Your Personal Data (1) We will use the information collected for the purposes of: a) Providing, processing, maintaining, improving and developing our products and/or services for you, including certain after-sales services, customer support and services on your device; b) Communicating with you. We will use your information as necessary to send you a service notice, and reply when you contact us; c) Storing and maintaining your information in accordance with our services or legal obligations; d) Performing an overall analysis to fix bugs, monitor usage, and optimize our services.
(2) We will obtain your consent in advance when your information is to be used for any purpose other than as specified in this Privacy Policy. We will also obtain your consent in advance when your information collected for a particular purpose is to be used for other purposes.
(3) Prior to or during our collection of your data, we may also provide additional information about our personal information practices through product descriptions, a supplemental privacy statement, or notifications. Some of our websites or features may have separate privacy statements that specifically describe how these websites or features process your personal information. To the extent that a notice provided during the collection of your information or a privacy statement for a particular website or feature conflicts with this Privacy Policy, the specific notice or supplemental privacy statement shall prevail.
## 4. How We Share, Transfer and Disclose Your Personal Data (1) We undertake not to sell your personal data to any third party for processing for any purpose without your consent. We will seek your separate consent if we share, transfer or disclose your personal data to any third party for any purpose other than as stated in this Privacy Policy.
(2) We will not share or disclose your personal data to any non-affiliated third party, but the following exceptions may apply: a) In response to your request. For example, if you authorize us to share your personal data with a third-party device or platform, we will share your information, such as steps, distance, height, weight, heart rate, calories, and other exercise-related data, with such third party upon your request. Please read the privacy policies of these third-party devices or platforms, as your activities on the third-party device or platform will no longer be governed by this Privacy Policy. b) The purpose of implementing our policies or contracts in connection with the product and limited to the use of the product; c) As legally requested through a subpoena or by another legal authority or as mandatorily required by an official authority. d) Solely for the purposes stated in this Privacy Policy, we may share your personal data with our cloud storage service provider stated herein and/or a future cloud storage service provider partner to provide better customer services and user experience. We will share your personal data solely for lawful, legitimate, necessary, specific and clear purposes, and to the extent as necessary to provide services. Our partners are not allowed to use the shared personal data for any other purposes. aa) Service providers. We may share your personal data with our service providers to monitor and analyze our use of services, for example, to contact you for payment processing on third-party websites after you visit our services.
(4) Sharing with third-party service providers To serve you better, we may engage a third party to help us implement the Company services, and you may choose whether to use such third-party services. When you choose to use a third-party service, the third party may collect your information. Therefore, we strongly recommend that you take some time to read the privacy policies of the third-party service, as if you read our Privacy Policy, and share your information accordingly. We are not responsible for how the third parties use the personal data they may collect from you and do not have control over their use. Upon your consent, the service provider will have access to your personal data only to enable the Company services on our behalf and is obliged not to disclose or use it for any other purpose.
a) Map service provider: In Company services, Google and Apple make available the movement tracking feature to users for tracking a single outdoor movement. When you use the services, we will collect your geographic information and provide your location to the map service provider. Please refer to the privacy policies of the corresponding map service providers for details on data collection and processing. You may turn off the GPS on your mobile phones to stop geo-information collection.
b) Weather push service provider: If your product supports push notification on weather, your location information will be sent from the local to a weather service provider (ColorfulClouds) to get weather report of your location and push it to you. Your personal data will be anonymized during this transfer and will not be used to identify or locate you.
c) Cloud storage service provider: In Company services, the service provider for cloud storage service is Amazon Web Services EMEA SARL or Amazon Web Services, Inc. ("Amazon"). When you choose to store your data in the cloud, your personal data will be uploaded to Amazon's servers. Any of your data that will be uploaded to Amazon's servers will not be monitored or accessed by our Company. Such data will only be accessed by you if you deem necessary. Please refer to Amazon's privacy policy for details on data storage.
d) Payment service provider: We may offer paid products and/or services within the GM Watch application. In that scenario, we may use third-party service providers to process payments (e.g. payment processing programs). We will not store or collect your payment details. We will directly provide your payment information to our third-party payment service providers and their use of your personal data will be subject to their privacy policies.
(5) If personal data is transferred when a merger, acquisition, or bankruptcy liquidation takes place, we will request the new company or organization which possesses your personal data to be subject to this Privacy Policy, otherwise we will request such company or organization to obtain your authorization and consent again.
## 5. How We Protect Your Personal Data (1) We are committed to ensuring the security of your personal data, and we will take all practical and necessary measures to protect your personal data, including encryption, authentication tools, and security servers. In order to prevent unauthorized access, disclosure or other similar risks, we will take reasonable administrative, technical, and physical safeguards to protect your personal data as much as reasonably possible.
(2) Upon occurrence of any personal data security violation, we will, in accordance with the requirements of laws and regulations, promptly notify you of the following matters: basic status and possible impacts of such security violation, response measures we have taken or will take, suggestions on how you may prevent or reduce risks on your own, and remedies available to you. We will promptly inform you of the incident related circumstances by email, letter, phone call, push notification or otherwise. If it is difficult to notify such personal data subjects one by one, we will adopt reasonable and effective means to announce a public alert. At the same time, we will take the initiative to report on the handling of personal data security incident in accordance with regulatory requirements.
## 6. How Your Personal Data is Transferred Globally (1) As a globally operating company, we provide products or services through resources and servers around the world. Currently, the Company rents servers from Amazon.
(2) We provide the Company products and services around the world, which means to conduct business globally, subject to your consent and as stated herein, your personal data (including those categories of data listed in the `How We Collect Your Personal Data section) may be transferred to, or accessed from, a jurisdiction other than the country/region where you use the Product.
(3) When your personal data is transferred to, or accessed from, a jurisdiction other than the country/region where you use the Product, we will adopt appropriate safeguards to ensure that your personal data is equally protected as it is in the country/region where you use the products or services. For example, we will take security measures such as encryption, de-identification, and the execution of necessary data transfer/sharing agreements with data recipients prior to the cross-border data transfer. You will have the right to be informed of the appropriate safeguards that GM Watch adopts to transfer your personal data.
## 7. How We Store Your Personal Data If you use our products and services, we may collect and store your personal data, and data storage may continue even after you close your account and ultimately by the end of a maximum period of 30 days which is necessary to delete your personal data. The retention period of personal data collected by us is the period necessary to achieve the purpose of collection as stated in this Privacy Policy, unless a longer retention period is required by law. We will delete or anonymize your personal data after the expiration of the aforementioned retention period. For example, we will keep your personal data when you are registered and use our products or services. If you close your account, we will delete or anonymize your information no later than 30 days as of the date of your request for deletion, unless otherwise provided by laws and regulations.
## 8. Your Rights to Your Personal Data The Company undertakes to respect the confidentiality of your personal data and ensures that you may exercise your rights to your personal data. Subject to this Privacy Policy and the applicable laws, what rights you will have and how we will protect your rights are listed below:
(1) The right to be informed: The Company releases this Privacy Policy to inform you how we will process your personal data. We strive for transparency in the use of your information.
(2) The right of access: You have the right to access your personal data held by us. You can directly access your personal data from Me - Profile in the application. If you are unable to do this on your own, please contact us using the contact information below.
(3) The right to rectification: You have the right to request us to rectify any incomplete or inaccurate information held by us. In addition, you can directly rectify your personal data from Me - Profile in the application. With respect to the personal data for which we have not provided a channel for you to make modification, you may contact us using the contact information disclosed in this Privacy Policy to request rectification or supplementation of your personal data. We will respond and provide feedback in a timely manner in accordance with the laws and regulations.
(4) The right to restriction of processing: You always have the right to request us to restrict our processing of your personal data. You may exercise your right to restrict our processing of your personal data by entering the "General Mobile Application Form" section on https://www.generalmobile.com/tr/Cms/Kvkk.
(5) The right to object. You have the right to object to our processing of your personal data even if such processing is based on our legitimate interest, or for the exercise of public power, direct marketing (including data aggregation), or for statistical reasons. You may exercise your right to object to our processing of your personal data by entering the "General Mobile Application Form" section on https://www.generalmobile.com/tr/Cms/Kvkk.
(6) The right to erasure: You have the right to request the erasure of your personal data. If we have no good reason to continue processing your personal data, you have the right to request us to erase your personal data. In addition, you can delete or permanently anonymize your personal data by canceling your account or erasing the data from the cloud. You may exercise your right to erasure by entering the "General Mobile Application Form" section on https://www.generalmobile.com/tr/Cms/Kvkk.
(7) The right to data portability: You have the right to request the transfer of your personal data. Where technically possible, we will provide you or your chosen third party with your personal data in a structured, commonly used machine-readable format. Please note that this right applies only to the information that you have initially given us your consent to use or that we have collected for the performance of the contract. You may exercise your right to data portability by entering the "General Mobile Application Form" section on https://www.generalmobile.com/tr/Cms/Kvkk.
(8) The right to withdraw consent: You have the right to withdraw your consent to the use of your personal data. If you withdraw your consent, we may not be able to provide you with access to certain features of the service. You may change the scope of your authorization for us to continue collecting your personal data or withdraw your authorization by deleting the device, disconnecting the device from the application, restoring the device to factory settings, clearing personal data from the cloud, turning off data management synchronization, or canceling the account.
(9) The right to object to automated decision-making: You have the right not to be subject to the fully automated decision-making, including user profiling. If these decisions significantly affect your legitimate rights, you may object to automated decision-making by sending an email to szprize@gmail.com. We will respond to your request and take appropriate action as and when necessary to address the issue.
(10) The right to apply to us. You may submit your requests about your personal data to us in writing. In such case, your application will be concluded free of charge as soon as possible and, in any case, no later than 30 days depending on the nature of your request. You will be informed about the result of your application in writing or in electronic medium. Upon its acceptance, your request will be duly complied with.
## 9. Privacy of Minors/Children (1) Our products and services are not applicable to children under the age of 18 (or the age of children with restricted civil capacity in your jurisdiction). General Mobile will not and does not intend to receive any personal data of minors. If we are aware that we have collected any personal data of a child under the age of 18 (or the age of children with restricted civil capacity in your jurisdiction), we have the right to take immediate steps to erase such information and terminate the account of the minor, regardless of whether we have obtained permission from the parent.
## 10. How Your Personal Data is Managed under GDPR If you are an EU user under GDPR, you can contact us using the contact information below to help you manage your personal data.
## 11. Updates to This Privacy Policy We will review this Privacy Policy regularly and may update it to reflect changes to our information practices. We will send you the change notifications through different channels. For the material changes to this Privacy Policy, we will notify you via email before such changes take effect if you have provided us with an email address in your account, otherwise we will post a notice on our website or push a notification to you through our device. You understand and agree that your use of the products or services after the release of the updated Privacy Policy will be deemed as acceptance of the updated Privacy Policy. If you do not agree with any part of this Privacy Policy at any time, you must immediately stop using the products and services.
This Privacy Policy is subject to adjustments, but we will not diminish your rights under this Privacy Policy without your express consent.
## 12. Contact Us If you have any comments or concerns about this Privacy Policy or any question regarding General Mobile's collection, use or disclosure of your personal data, or if you believe that your rights are not fully protected under this Privacy Policy, please contact us using the contact information below:
**PRODUCING COMPANY**
**Title**: Sichuan Koobe Communication Co., Ltd
**IMPORTER COMPANY**
**Title**: Telpa Teknoloji Hizmetleri A.Ş.
**Address**: Hamidiye Mah. Anadolu Cad. No:14 Kağıthane Branch, ISTANBUL/TURKEY
**Email**: info@generalmobile.com
