PRIVACY POLICY

We respect your privacy and are committed to protecting your personal data. With this Privacy Policy (“Policy”), we explain how HubX Yazılım Hizmetleri Anonim Şirketi (“HubX”) collects and processes your information and personal data, the protection and privacy, and data security measures implemented, including your rights. This Policy is applicable on Lotus Flow app, website and social media platforms owned by Lotus Flow (collectively “Lotus Flow / App / Services / Website”). Your access and use of Lotus Flow is governed by this Privacy Policy and Terms of Use (“Terms”). The Terms apply to the definitions within this Policy and the provisions not included in this Policy. By accessing or using Lotus Flow, you agree to the collection and use of information and personal data in accordance with this Policy, and that you have reviewed and understood the processing of your information and personal data, including your rights. If you do not agree with the Terms or Privacy Policy, please do not use the App, Website, and/or the Services offered by Lotus Flow.

CATEGORIES OF PERSONAL DATA AND PROCESSING

Personal and Contact Information
Data Types: Google or Apple account name (whichever you logged-in with), username, name and surname, email address.
Purpose: To communicate with you, manage your account, provide customer support, and respond to inquiries, create plans and yoga classes personalized for the account.
Legal Basis: Performance of a contract.

Technical and Security Data
Data Types: IP address, device name, browser type and version, operating system, access times, pages viewed, referring URLs, configuration data.
Purpose: To ensure the security and operation of our services, fraud prevention, debugging, diagnostics, and system analytics.
Legal Basis: Legitimate interest, legal obligation (for logs)

Usage and Log Data
Data Types: App usage logs, session information, page interaction, crash reports, download errors.
Purpose: Service improvement, debugging, performance monitoring, internal analytics.
Legal Basis: Legitimate interest, legal obligation (for logs)

Transaction and Order Information
Data Types: Purchase history, subscription and order details, in-app transaction data.
Purpose: To process transactions and subscriptions, manage billing and payment history.
Legal Basis: Performance of a contract, legal obligation (billing)

Health Data
Data Types: Gender, Exercising, Dietary and Sleeping Habits, Height, Age, Current and Target Weight
Purpose: To estimate metabolic rate and BMI index and to create exercises, personal plans and difficulty levels accordingly.
Legal Basis: Performance of a contract, Core function of the app
Please note that this app may use Apple Health app and Apple HealthKit upon your consent for Apple App Store users. You may withdraw your consent anytime by using “Your Choices” section.

Marketing and Analytics Data
Data Types: Cookies, analytics data, user preferences, IDFA, IDFV, interaction with marketing emails or ads.
Purpose: Personalized advertising, performance tracking of campaigns, categorization of yoga and fitness plans.
Legal Basis: Legitimate interest, Consent (for IDFA, IDFV, cookies other than strictly necessary ones)

Cookies

Lotus Yoga uses cookies to understand how you interact with our website and to improve its performance and functionality. Cookies are small data files stored on your device by your web browser. We use different types of cookies, including; strictly necessary cookies, which are essential for the operation of our website (e.g., remembering your login session, exercising plans and sessions) and non-essential cookies, such as those used for enhanced functionality or performance (e.g., remembering preferences, creating daily exercising plans). We only use non-essential cookies after obtaining your explicit consent through our cookie management tool. You can see and manage cookie types from this tool offered and withdraw your consent at any time even after you give consent. Additionally, most browsers also allow you to control or disable cookies via their settings. Please visit your browser’s menu to proceed. Also, please note that disabling cookies may affect the functionality and performance of our website, and some features may no longer be available.

2. Use and Sharing of Information

We use your personal information for the purposes described in this Policy and / or any privacy statement provided for certain Services. Such purposes include, but are not limited to: To provide our Services to users, including viewing customized content, plans, classes and advertisements; Sharing information with our business partners who perform basic services (such as hosting, billing, data storage, security and reporting services) related to the operation of the service; Collecting and processing information about your actual location to provide location sensitive products, services, and other content; Verify your identity; Follow-up of transactions or inquiries initiated on the website, application or via e-mail Audit, research and analysis to maintain, protect and improve our services; To ensure the technical functioning of our network; and Developing New Services.

Service Providers: We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and cloud services. This includes cloud providers (Google, CloudFlare), app stores (Google Play Store, Apple App Store), data analytics providers (Facebook, Google, Appsflyer, Firebase). We may share your personal information with third-party advertising partners. These third-party advertising partners (CookieScript, Clarity) may set technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, yoga session(s) joined).

Law Enforcement and Public Authorities: We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

We may use health data that we obtain through the Apple Health app or Apple HealthKit to provide feedback on your activity or health condition and to improve the Service by creating a more personalized experience for you (ie, by providing content related to your activity) or health, but in no case advertising as stated here. or for marketing purposes). We will not disclose any of your health data we obtain through the Apple Health app or Apple HealthKit to advertising platforms, data brokers or information vendors or for advertising, marketing or usage-based data mining purposes. We will not disclose such data to other third parties without your consent, and then we will not disclose it solely to enable the third party to provide health, movement and / or fitness services. We may provide information, including health data, to affiliates, affiliates and other trusted third parties or individuals to process personal information on our behalf. We ask these parties to agree to process such personal information in accordance with our instructions and in accordance with appropriate confidentiality and security measures.

We may also disclose personal information and health information: (i) if required by law or if we have a good faith belief that such action is necessary (1) to comply with law orders or to comply with notified legal process Lotus Yoga or its parent company, subsidiaries or affiliates, (2) Protects and defends the rights or property of Lotus Yoga or its Website users or (3) acts under necessary conditions to protect the safety of the public or users of the Website; (ii) in connection with any other change of control, including partial or total sale of shares or assets, merger or bankruptcy; or (iii) when we have your consent to do so.

We do not use automated decision making or engage in profiling that produces legal or similarly significant effects. Please note that we may share anonymized technical or personal information without limitation (in such a way that it can no longer be attributed to a specific individual, ensuring your privacy is maintained).

3. Your Choices

When you sign up for the service, we ask you to provide your personal information. If we use this information in a way other than those described in this Policy and / or certain service notices, we will ask for your consent prior to such use. If you no longer wish to receive email notifications from Lotus Yoga, please let us know by contacting us. Please specify the notifications you no longer wish to receive and provide your full name, email address and / or physical address so that we can do our best to stop receiving notifications you no longer wish to receive. Please note that you will continue to receive communications regarding our transactions and our relationship with you.

If we offer and refuse to use personal information for any purpose other than as described in this Policy and / or certain service notices, Lotus Yoga may not be able to provide you with its Service. If you would like to withdraw your consent to our health data collection through the Apple Health app and Apple HealthKit, you can do so using your device settings.

We may partner with third party ad networks and other ad service providers ("Ad Providers") that advertise on our behalf and on platforms not affiliated with others. Some of these advertisements are personalized, meaning that they are intended to be relevant to you based on information that the Ad Providers collect about your use of the Website and other sites or apps over time, including information about relationships between different browsers and devices. This type of advertising is known as interest-based advertising. Lotus Yoga adheres to the Digital Advertising Alliance ("DAA") Self-Regulatory Principles in connection with this interest-based advertising activity. You can visit www.aboutads.info or www.youradchoices.com/AppChoices to learn more about interest-based advertising and how companies participating in the DAA self-regulation program can opt out of these ads. If you delete your cookies, reset your device ad identifier, or use a different browser or mobile device, you will need to renew your opt-out options. You can also limit data collection for advertising purposes using tools available on your device. Note that opting out will not stop ads from appearing in your browser or apps. It can make the ads you see less relevant to your interests.

We may also work with third parties who collect data about your use of the Website and other sites or apps over time for non-advertising purposes. For example, Lotus Yoga uses Google Analytics and other third party services to improve the performance of the Website, to analyze and improve personalized exercising plans and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our website, visit www.google.com/policies/privacy/partners/ and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout/. visit. .

When you use the Service, we endeavor in good faith to provide you with access to your personal information and to either correct this data if it is inaccurate, or delete such data at your request if it is not required by law. for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and in some cases we refuse to process requests in certain circumstances. Whenever we access and correct the information, we perform this service free of charge, except if it requires disproportionate effort. Please contact us on [email protected] if you would like us to remove your data from our servers.

4. User Data Deletion

Users have the right to delete their Personal Data from the Service. If you wish to delete your account and all associated data, you can do so by accessing the "Delete Account" button in the settings section of the app. By clicking on this button, your account and Personal Data will be permanently removed from our servers.

5. Data Security

We take appropriate security measures to protect against unauthorized access to data or unauthorized modification, disclosure or destruction. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to protect against unauthorized access to systems where we store personal information. We limit access to personal information to Lotus Yoga employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are subject to confidentiality obligations and may be subject to disciplinary action, including termination and criminal prosecution, if they fail to comply with these obligations. However, please note that no data transmission over the Internet can be guaranteed to be 100% secure, so Lotus Flow cannot guarantee or guarantee the security of any information you voluntarily provide to Lotus Flow while Lotus Flow tries to protect your information.

6. Users Under 18

Lotus Flow’s content is not intended for users under the age of eighteen (18), and if you provide information about yourself as a Lotus Yoga user, you represent that you are at least eighteen (18) years old. We do not knowingly collect personal information from anyone under the age of eighteen (18), but if we become aware that we have collected personal information from a user under the age of eighteen (18), we will remove such information from our files. As a kind note for parents, if you want to exercise with your kids, please supervise your children and make sure that they are doing the moves correctly and safely. Since all trainings are planned for adults, Lotus Flow bears no responsibility in this regard.

7. Rights Under GDPR

The General Data Protection Regulation No. 2016/679 (GDPR) establishes a comprehensive framework for the protection of personal data within the European Union and the European Economic Area. Under GDPR, users have the following rights regarding their personal data as data subjects:
Right to Access: Obtain confirmation and access to personal data being processed.
Right to Rectification: Request correction of inaccurate or incomplete data.
Right to Erasure: Request deletion of personal data under certain conditions.
Right to Restrict Processing: Request limitation of data processing in specific situations.
Right to Data Portability: Receive personal data in a machine-readable format and transfer it to another controller.
Right to Object: Object to the processing of personal data, especially for direct marketing.
Rights Related to Automated Decision-Making: Not to be subject to decisions based solely on automated processing, unless certain conditions apply.
To exercise these rights, users must send an email or petition clearly stating the right they wish to enforce, along with their name and accurate contact details. A response will be provided within the legal time period.

8. California Residents

The California Consumer Privacy Act (CCPA/CPRA) requires us to disclose categories of personal information we collect and how we use and share it as we have explained above. We are also required to communicate information about rights California residents have under California law. You may exercise the following rights:
Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information we collect, use, or share; (2) purposes for which categories of Personal Information are collected or used by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you.
Right to Equal Service. We will not discriminate against you if you exercise your privacy rights.
Right to Delete. You may submit a verifiable request to close your account and we will delete Personal Information about you that we have collected.
Request that a business that sells a consumer's personal data, not sell the consumer's personal data. If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us. Please note that we do not sell the personal information of our users. For more information about these rights, please contact us.

9. Updates to Privacy Policy

We reserve the right to update this privacy policy at any time to reflect changes in our practices, legal obligations, or operational needs. Users are encouraged to review this policy regularly to stay informed about how we protect their personal data and to understand their rights and responsibilities. The revision date is stated in the introduction of the policy. Any updates will take effect immediately upon posting. If users do not agree with the amendments, they should discontinue using the app. Continued use of the website after such updates constitutes acceptance of the revised policy.

10. Communication

This privacy policy constitutes the entire understanding between you and us regarding the collection, use, and protection of your personal data. If you have any questions or concerns regarding this policy or our data practices, please contact us via physical mail to Gülbahçe Mah. Gülbahçe Cad. No:1/48/16 Urla/İzmir or by sending an e-mail to [email protected]

Last Update: June 2025