1. Who we are
1.1 This Privacy Policy explains how the EceTempo app for iPhone and Apple Watch (the "App") handles personal data. It is provided by VIVARDIQ Sağlık Bilişim Ltd. Şti., Pamukkale Teknokent, Denizli, Türkiye, trade registry no 55428, MERSİS no 0925134148200001 ("VIVARDIQ", "we", "us").
1.2 The short version: EceTempo has no user accounts and no servers that store your workout or health data. Your data stays on your iPhone, your Apple Watch and in Apple Health, under your control. We do not see it, sell it, or use it for advertising.
1.3 For users in Türkiye, this policy is also our information notice (aydınlatma metni) under Article 10 of the Personal Data Protection Law No. 6698 ("KVKK"). For users in the European Economic Area and the United Kingdom, it is our notice under the GDPR.
1.4 Contact for privacy questions: [privacy e-mail].
1.5 This Privacy Policy is available in Turkish and English. For users in Türkiye, the Turkish version prevails; for all other users, the English version prevails.
2. At a glance
| Data | Where it is stored | Can VIVARDIQ see it? |
|---|---|---|
| Heart rate and workout data from Apple Health | Your iPhone, Apple Watch and Apple Health | No |
| Workouts recorded with EceTempo | Your devices and, if you allow it, Apple Health | No |
| Your profile values (age, resting and maximum heart rate, clinical test values, zones) | Inside the App on your devices | No |
| Interval plans and perceived-effort ratings | Inside the App on your devices | No |
| Subscription purchase | Apple; the App only receives your subscription status | No (Apple gives us only aggregated sales reports) |
| Messages you send to support | Our e-mail system | Yes, only what you choose to send |
3. Data the App uses
3.1 Apple Health (HealthKit). Only with your permission, the App may:
read heart rate, resting heart rate and past workouts, to calculate your zones and guide you during a workout;
write the workouts you complete with EceTempo, with their heart rate and active energy, so they appear in Apple Health and Fitness.
You choose which types to allow, and can change this at any time in Settings > Health > Data Access & Devices > EceTempo.
3.2 Data you enter. Age, resting and maximum heart rate, values from clinical exercise tests (for example peak heart rate or heart rate at ventilatory thresholds), your heart-rate zones, perceived-effort ratings and interval plans. These are stored inside the App on your devices.
3.3 Purchases. Apple processes your subscription payment. The App only checks with Apple whether your subscription is active. We do not receive your name, Apple ID, or payment details. Apple's own privacy policy applies to the purchase.
3.4 Support. If you e-mail us, we receive your e-mail address and whatever you include in your message. We use it only to answer you. Please do not send health details that we do not need to help you.
3.5 What we do not collect. We do not collect your location, contacts, photos, advertising identifier or browsing activity, and we do not track you across other apps or websites.
4. Purposes and legal bases
We use data only for the purposes below. Where processing takes place on your device, you control it; where the law treats us as responsible for it, these are our legal bases.
| Purpose | Data | Legal basis (KVKK) | Legal basis (GDPR) |
|---|---|---|---|
| Calculate zones and give real-time guidance | Heart rate, workouts, values you enter | Explicit consent for health data (Art. 6) | Explicit consent (Art. 9(2)(a)) |
| Save your workouts to Apple Health | Workout, heart rate, active energy | Explicit consent for health data (Art. 6) | Explicit consent (Art. 9(2)(a)) |
| Provide the subscription | Subscription status from Apple | Performance of a contract (Art. 5(2)(c)) | Contract (Art. 6(1)(b)) |
| Answer support requests | E-mail address, your message | Legitimate interest (Art. 5(2)(f)) | Legitimate interests (Art. 6(1)(f)) |
| Meet legal obligations, such as tax records | Information Apple provides on sales | Legal obligation (Art. 5(2)(ç)) | Legal obligation (Art. 6(1)(c)) |
You give explicit consent for health data on a separate screen in the App, and you can withdraw it at any time (Section 7). Withdrawing consent does not affect processing that happened before, but the guidance features will stop working.
5. Where data is stored and who receives it
5.1 On your devices. Data in the App is stored on your iPhone and Apple Watch. Data in Apple Health is managed by Apple under your device and iCloud settings. Apple's privacy policy applies to Apple Health and iCloud.
5.2 No transfers by us. Because we do not run servers for the App, we do not transfer your workout or health data to anyone, in Türkiye or abroad. Support e-mails are handled by our e-mail provider, [provider name, server location]; if its servers are outside Türkiye, we transfer that data under KVKK Article 9.
5.3 Our commitments on Apple Health data. We do not:
use Apple Health data for advertising, marketing or data mining;
sell it or share it with third parties;
store it in iCloud ourselves or on any server we control;
use it for any purpose other than providing the App's fitness features.
5.4 Legal requests. We may disclose the limited data we hold, such as support e-mails, if required by law or by a court or competent authority.
6. Retention and deletion
6.1 App data stays on your devices until you delete it. You can delete individual plans and settings in the App. Deleting the App removes all data stored inside it.
6.2 Apple Health data stays in Apple Health until you delete it there. Workouts saved by EceTempo can be deleted in the Health app, under Settings > Health > Data Access & Devices > EceTempo > Delete All Data.
6.3 Support e-mails are kept for up to [2] years after your request is closed, then deleted, unless a longer period is required by law.
6.4 Sales records that Apple provides to us are kept for as long as Turkish tax and commercial law requires.
7. Your rights
7.1 You control most of your data directly. You can view, change and delete App data in the App, and Apple Health data in the Health app. You can withdraw Apple Health access, or your explicit consent, at any time in the App or in Settings > Health.
7.2 Rights under KVKK (Article 11). You have the right to:
learn whether your personal data is processed, and 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;
ask for incomplete or incorrect data to be corrected;
ask for data to be deleted or destroyed under Article 7;
ask for corrections and deletions to be notified to third parties who received the data;
object to a result against you arising only from automated analysis;
claim compensation for damage caused by unlawful processing.
7.3 Rights under the GDPR (users in the EEA and UK): access, rectification, erasure, restriction, data portability, objection, and withdrawal of consent at any time.
7.4 How to apply. Send your request in writing to our address in Section 8.4, by registered e-mail (KEP) to [KEP address], or by e-mail to [info@vivardiq.com] from the address you used to contact us. We will answer within 30 days, free of charge, unless the request involves an additional cost allowed by law.
7.5 Complaints. You may complain to the Personal Data Protection Authority (KVKK Kurumu) in Türkiye, or to the data protection authority in your country of residence.
8. Children, security, changes and contact
8.1 Children. The App is not intended for children under 16, and users aged 16 or 17 need a parent's or guardian's consent (see the Terms of Service). We do not knowingly collect data from children.
8.2 Security. Data stored by the App is protected by your device's security, including its passcode, Face ID or Touch ID, and Apple's encryption of Health data. Keep your devices locked and up to date.
8.3 Changes. If we change how the App uses data, for example by adding accounts or cloud backup, we will update this policy and show the change in the App before it applies. Where the law requires, we will ask for your consent again.
8.4 Contact
VIVARDIQ Sağlık Bilişim Ltd. Şti.
Pamukkale Teknokent, Kınıklı Mahallesi, Hüseyin Yılmaz cad. No:67/4, Pamukkale, Denizli, Türkiye
Email: info@vivardiq.com
Effective date: 30.11.2026