Data Protection Notice (KVKK)
Last updated: 2026-10-25
Draft. This is a template prepared before legal review; it must be approved by counsel before publication. In case of conflict, the Turkish version prevails.
Data controller
MD NutriAcademy Genetik Biyomühendislik Yazılım Sanayi ve Ticaret Limited Şirketi (“MD NutriAcademy”), İstinye Garage, Bilişim Vadisi, Sarıyer / Istanbul. Email: info@mdnutriacademy.com
Personal data we process
- Identity and contact data: name, email, phone, delivery address.
- Transaction data: order and payment information (card details are not stored by MD NutriAcademy; payment is processed by iyzico).
- Health data (special category): dietary questionnaire answers, microbiome sequencing data derived from your stool sample, and the reports and scores derived from them. Processed only with your explicit consent.
- Usage data: TWINbiome dashboard login records, browser and device information, cookies.
Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Taking the order, delivering the kit, invoicing | Performance of a contract (KVKK art. 5/2-c) |
| Performing the microbiome analysis, preparing the report, dietitian consultation | Explicit consent (art. 6/2) |
| Legal obligations (invoicing, accounting) | Required by law (art. 5/2-a) |
| Measuring service quality, improving the dashboard | Legitimate interest (art. 5/2-f) — with anonymised data |
| Scientific research | Explicit consent; anonymised data |
Transfers
Data is shared, strictly for the relevant purpose, with the accredited sequencing laboratory, the courier, the payment institution (iyzico) and the cloud hosting provider. Samples are sent to the laboratory under an anonymous code; your identity is not disclosed to the laboratory. Data is hosted in Turkey; international transfer takes place only with your explicit consent and within KVKK art. 9.
Retention
Order and invoice records are kept for 10 years as required by law; microbiome data and reports are kept while your account remains open and until you request deletion. Upon request they are deleted or anonymised within 30 days.
Your rights (KVKK art. 11)
You have the right to learn whether your personal data is processed, to request information, to learn whether it is used for its purpose, to know the third parties it is transferred to, to request correction or deletion, to object, and to claim compensation for damage. Send requests to info@mdnutriacademy.com or the postal address above; they are answered within 30 days at the latest.
Cookies
The site uses only session and preference cookies and anonymous visitor statistics. No advertising cookies are used.