Law No. 6698 on the Protection of Personal Data (hereinafter referred to as the “KVKK”) has entered into force upon its publication. Within the scope of the said Law, our company Sword Space Elektronik Aksesuar Tic. Ltd. Şti. (hereinafter referred to as “Sword Space”) has the title of Data Controller, and this Information Notice/Privacy Policy has been prepared in order to fulfill Sword Space’s obligation to inform its users in accordance with the Law. This Information Notice/Privacy Policy may be updated by Sword Space when necessary, and the updated version shall be published accordingly. This text and policy have been prepared for the use of the “Sword watch pro” Mobile Platform (hereinafter referred to as the “Platform”) provided by Sword Space. The software is offered within the scope of cooperation and confidentiality protocols established between Sword Space and a third party. As the third party independently determines the conditions for the processing of personal data and acts as the primary processor of such data, it qualifies as the Data Controller. Sword Space does not process or store any personal data of users in relation to this Platform. All personal data are processed and stored by the third party. Within the territory of Türkiye, Sword Space is the primary point of contact for users in its capacity as data controller.
Users whose personal data are processed within the scope of the Sword watch pro mobile application, and due to the data processing activities described below, are deemed to be “Data Subjects.”
Within the scope of the Law, personal data refers to any information relating to an identified or identifiable natural person. Special Categories of Personal Data refer to data relating to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and attire, membership of associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, biometric data and genetic data. Processing of personal data refers to any operation performed on personal data, whether wholly or partly by automatic means or otherwise than by automatic means provided that the data form part of a data recording system, such as collection, recording, storage, preservation, alteration, reorganization, disclosure, transfer, acquisition, making available, classification or prevention of use. “Sword watch pro” is a wearable smart watch application. It offers functions such as message reminders, alarm clock, inactivity and water intake reminders, exercise and step counting, and provides 24-hour activity tracking and daily service features through a mobile application.
(For products with version 3.18.0 or later) You may continue to use many Sword Space services, such as searching for and browsing product features, even after logging out or without creating an account. Before using our products, we strongly recommend that you carefully read this Policy and review how we collect, process, store, share and transfer your Personal Data, as well as our purposes and practices regarding the processing of Personal Data. This Policy also explains the methods by which you may exercise your rights to access, update, delete or protect your Personal Data.
In order to provide our products and services, we may request certain information that is necessary for their proper operation. If such information is not provided, some functions or services may not be available. The categories of information we collect (whether personal data or not) include, but are not limited to, the following:
We may collect and process information such as QQ, WeChat, Facebook or Twitter account details, mobile phone number, email address, profile image, personal signature, nickname, gender, time zone, language preferences and sports-related preferences.
When activating the App, you may be requested to provide basic physical information including height, weight, gender and age.
When smartwatch data is synchronized with the App, health and activity-related data generated by the device may be recorded. This may include activity records, sleep data, heart rate, blood oxygen saturation, weight, swimming metrics (such as stroke count, stroke speed, stroke length and swimming duration), resistance values, pace, exercise duration, body temperature, blood pressure, body fat data, ECG, respiration rate, mood indicators and stress-related data.
When features such as call alerts, SMS notifications or contact synchronization are enabled, the App may access incoming call data, message notifications and contact information for display purposes. With your consent, this information may be displayed on the smartwatch; however, the App does not store call logs, message content or contact data.
Information such as your mobile device’s operating system version and brand/model may be collected to ensure compatibility with the App.
When music control features are used, limited music metadata (including song title, album name, artist, playback status and playlist information) may be synchronized from your mobile device to the smartwatch. This data is displayed only on the smartwatch and is not stored.
When using location-based services (such as workout tracking), location data and related device information may be collected to improve positioning accuracy. This may include longitude and latitude, IP address, GNSS data, network type, Wi-Fi status and parameters, base station information, signal strength data, sensor data (such as acceleration and pressure), device identifiers (IDFA, OAID), application information, and system parameters (device brand, model, operating system, carrier and screen resolution).
If you submit feedback through the App, relevant feedback records, contact details and supporting information may be collected according to your submission preferences.
When connecting the App to a smartwatch, technical data such as device identifiers, firmware versions, approximate location data (non-personal) and functional usage statistics (non-personal) may be transmitted to the server. This may also apply following system updates, software upgrades or factory resets.
If you configure exercise goals, weight goals or heart rate reminders, the corresponding values may be collected to provide notifications when targets are reached. When using female health features, information such as menstrual cycle length, interval data, recent cycle dates and related physical or mood conditions may be collected. If you choose to customize watch faces, images uploaded by you may be collected solely for this purpose.
You may choose to add other users as relatives or friends. Once authorization is granted, selected health and activity data (such as activity, sleep, heart rate, blood pressure, body temperature, blood oxygen, ECG and similar metrics) may be displayed to you.
When using login functions or App push services, the list of installed applications on your device may be accessed to enable related features. This information is not stored.
Personal information is collected for the purpose of delivering products and services and ensuring compliance with applicable laws and regulations. By using the App, you consent to the processing and disclosure of your personal information to affiliated companies (including those operating in communications, social media, technology and cloud services) and to third-party service providers, in accordance with this Privacy Policy.
Your personal information may be used for the following purposes:
* Creating and managing a sports account within the AppYou may delete your personal information by deleting your account directly within the Sword Space app. To do so, access “Me” via the App → tap your avatar → select “Delete” in the upper-right corner → confirm deletion in the pop-up window.
Once the account deletion process is completed, all personal data associated with your account will be permanently deleted and cannot be recovered. Please ensure that you back up any necessary information prior to deletion. After account deletion, access to the account and all related services will be terminated.
Within the scope of the defined services, personal data are collected through digital and technical channels by automatic or non-automatic means in accordance with the law, and processed within the framework of the personal data processing conditions and purposes set forth in Article 5 of the KVKK.
The conditions for processing personal data as specified in Article 5 of the KVKK are listed below:
(1) Personal data may not be processed without the explicit consent of the data subject.In cases where explicit consent is required pursuant to the relevant provisions, your explicit consent is obtained. However, provided that the conditions set out in paragraph (2) of Article 5 are met, personal data may be processed without obtaining consent.
In order to provide our products and services to users, it is necessary for you to share certain personal data. If you do not share your personal data, we may not be able to provide some of our services due to the nature of the system.
When you create an account with us, we may collect your contact information such as your name, email address, phone number, username and login credentials. During your interaction with our products, we may also collect your nickname, profile picture, country code, language preference and time zone information within your account.
If you allow login via a third-party account, we may obtain account information (such as profile image, nickname, region, gender, etc.) from such third party that may be linked to your Sword Space account for fast login purposes. While processing your Personal Data, we comply with applicable data protection laws and regulations, as well as the policies, agreements or documents agreed upon regarding the sharing of personal information with such third parties.
When you use the feedback and suggestion features in our products, we collect your email address, mobile phone number and the content of your feedback in order to resolve your issues and address device malfunctions in a timely manner.
When you interact with our products, we automatically collect device information such as your device’s MAC address, IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files and mobile network information.
During your interaction with our websites and services, we automatically collect usage data related to visits, clicks, downloads, sent/received messages and other usage activities associated with our websites and services.
System and exception logs may be uploaded when you use our application. Device Information or Log Information alone cannot be used to identify a specific individual. However, if such non-personal information is combined with other data, it may be used to identify a specific person. In such cases, such non-personal information shall be deemed Personal Data. Unless otherwise required by laws and regulations or unless your explicit consent is obtained, such data will be kept in anonymized form.
When you enable location-based functions through the permission settings on your mobile device, we collect and process your location information in order to enable certain functions such as pairing with smart devices. In addition, when you use certain smart devices and related services such as weather services, we may collect information regarding your real-time precise or approximate geographic location.
Subject to your explicit consent, when you enable the geo-fence feature on the products, your location data will be generated and shared with Google Maps services. In this case, Google applies relevant data protection measures. You may refuse such use of your location information by managing the permission settings on your products, through which you may stop the collection and use of your location data at any time.
• Basic Smart Device Information: When you connect your Smart Devices to our Products, we may collect basic information about your Smart Devices, such as device name, device ID, online status, activation time, firmware version, and upgrade information.
• Information Reported by Smart Devices: Depending on the different Smart Devices you choose to connect to our Products, we may collect different information reported by your Smart Devices. For example, smart scales or fitness trackers may report your height, weight, body fat percentage (BFM), BMI (Body Mass Index), and skeletal muscle mass (SMM). Specifically, when you proactively allow our Products to connect with Apple Health, we will share your health data (including only your BMI, height, weight, and body fat percentage) with Apple Health solely for the purpose of measuring and analyzing your health-related indicators. We will not disclose such health data to any other third party. You can disconnect the Products from Apple Health at any time by managing your HealthKit settings on your smartphone.
The purposes for which we may process your information are listed below:• To Provide You with Services: We process your account and profile data, device information, usage data, location information, and Smart Device-related information to provide you with the Products and Services you have requested. The legal basis for this processing is to enforce our contract with you in accordance with our Terms of Use.
• To Improve Our Services: We process your device information, usage data, location information, and Smart Device-related information to ensure the functionality and security of our Products, to improve and enhance our Products and Services, to analyze the efficiency of our operations, and to prevent and monitor fraudulent or improper use. The legal basis for this processing is to enforce our contract with you in accordance with our Terms of Use.
• Non-Marketing Communications: We process your Personal Data to send you important information about the Services, changes to our terms, conditions, and policies, and/or other administrative information. Because this information may be important, we do not recommend that you refuse to receive such notifications. The legal basis for this processing is to enforce our contract with you in accordance with our Terms of Use.
• Marketing communications: We may process your Personal Data to provide you with marketing and promotional materials about our Products and Services. When we do this, each notification we send you will include instructions allowing you to opt out of receiving such notifications in the future. The legal basis for this processing is your explicit consent. Furthermore, if you agree to participate in our lotteries, contests, or other promotions, we may use your Personal Data to manage such activities.
• Personalization: We may process your account and profile data, usage data, and device information to personalize product design and offer you personalized services, such as suggesting and displaying information and advertisements about products that are suitable for you and inviting you to participate in surveys about your use of our Products. The legal basis for this processing is your explicit consent.
• Legal compliance:
(a) We may process your Personal Data to comply with applicable laws and regulations;As “Sword Space,” we only share Personal Data in the ways we have described to you. We may share your Personal Data with the recipients listed below:
• We may share it with our third-party service providers who perform certain business-related activities for our company, such as website hosting, data analytics, payment and credit card processing, infrastructure provision, Information Technology (IT) services, customer support services, email delivery services, and other similar services to enable them to provide services to us.Since the service is provided from abroad, and your personal data will be processed abroad, we request your explicit consent in accordance with Article 9 of the KVKK (Personal Data Protection Law).
• To ensure a smooth browsing experience, you may receive content or network links from a third-party provider (hereinafter referred to as a third party). We do not have control over such third parties. You may choose whether or not to access links, content, and services provided by third parties. We cannot control the privacy and data protection policies of third parties, and third parties are not bound by this policy. Before sending personal information to third parties, please review the relevant third party's privacy policy.• We may share it with subsidiaries or affiliates within our corporate family to conduct regular business operations.
• Where explicit consent is required by law (except where explicit consent is not required by law) and within the framework of conditions determined by law, your personal data may be transferred. To facilitate our operations, we may transfer, store and process your Personal Data in jurisdictions outside of where you reside. The laws in these countries may differ from the laws applicable in your country of residence. When we do so, we will ensure that an adequate level of protection is provided for the information by using one or more of the following approaches:
Agreement based on approved EU standard contractual clauses in accordance with Article 46 of the General Data Protection Regulation (GDPR). For more information, see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
If you would like more detailed information about the measures we have taken, you can contact us directly as described in this Privacy Policy.This Privacy Policy applies solely to the products and services provided by us and does not extend to services offered by third parties. Depending on the features you choose to use, certain third-party products or services may be involved, including but not limited to analytics, statistical tools, map services and third-party login services. These services may be accessed through external links, SDKs, APIs or similar technical integrations.
When you use such third-party services, they may independently collect and process your information in accordance with their own privacy policies. We strongly recommend that you carefully review the privacy policies of any third party whose services you use. We do not control and are not responsible for how third parties handle personal information collected from you. This Privacy Policy does not apply to external websites or services accessed through links provided within our services.
By using Google Fit , you agree to Google Fit 's Terms of Service and Privacy Policy :
http://www.google.com/policies/privacy
By using Apple Health, you agree to Apple’s Terms of Service and Privacy Policy:
https://www.apple.com/legal/privacy/szh/
In addition , we have also integrated the following SDKs . When you use these specific products , your information collected by the SDK , the purpose of use , and the applicable third-party privacy policies are listed below :
To ensure proper operation of certain features, the App may request the following permissions. You may manage or revoke these permissions at any time through your device’s system settings. Disabling permissions may limit related functions but will not affect unrelated services.
Storage Permission:Used for content sharing, setting profile images, customizing watch dials, firmware upgrades and similar functions.
Camera Permission:Required for scanning QR codes, adding relatives or friends, taking photos and setting avatars or dial backgrounds.
Album Permission:Used for selecting and editing images or videos when customizing static or dynamic watch dials.
Location Permission:Used for map positioning, workout route recording, Bluetooth pairing, weather services and other location-based functions. On Android 10 or later, background location access may be requested to ensure accurate exercise tracking.
Phone Permission:Used to obtain phone status information when managing call notifications or call rejection through the smartwatch.
Call Permission:Required to enable call handling and call notification features on the smartwatch.
Call Log Permission:Used to display caller identification information on the smartwatch.
Address Book Permission:Used to display contact information for incoming calls and messages on the smartwatch.
SMS & MMS Permission:Used to display message content on the smartwatch.
Media Audio Permission:Used to synchronize selected local audio files from your mobile device to the smartwatch.
All permissions can be reviewed, modified or disabled at any time through your device’s system settings.
We take commercially viable physical, administrative, and technical measures to protect the integrity and security of your personal data. “Sword Space” offers various security strategies to effectively ensure the data security of users and devices. Regarding device access, “Sword Space” uses proprietary algorithms to provide data isolation, access authentication, and authorization requests. Regarding data transmission, commercial-level information encryption transmission based on communication and dynamic keys is supported using security algorithms and transmission encryption protocols. Regarding data processing, strict data filtering and verification and complete data auditing are implemented. Regarding data storage, all confidential user information is securely encrypted for storage.
Unless there is a specific legal requirement for us to retain your personal data for a longer period, our third-party platform software partner, “Sword Space,” does not process personal data for the purposes stated in this Privacy Policy. However, we undertake to retain your personal data for a limited and proportionate period relevant to the purpose. We determine the appropriate retention period according to the amount, nature, and sensitivity of your personal data, and we destroy your Personal Data after the retention period expires. If we are unable to destroy it due to technical reasons, we ensure that appropriate measures are taken to prevent further use of your Personal Data in this way. Your personal data will be stored for a period proportionate to the purpose. After this period, your personal data will be irreversibly deleted, destroyed, and/or anonymized in accordance with the Personal Data Retention and Destruction Policy at the first periodic destruction period. You can withdraw your consent for the processing of personal data, except for data that must be processed by law, at any time.
For example; Email address: When you use the platform service, we will need to store your email address to ensure that you can use the service normally; when you delete your account, we will delete the relevant information; If we discontinue our products or services, we will delete or anonymize your personal information in the first destruction process 3 years after the discontinuation date.
Protecting the privacy of young children is especially important to us. The services are not intended for individuals under eighteen (18) years of age, and we ask that such individuals not provide us with their Personal Data. We will not knowingly collect Personal Data from anyone under eighteen (18) years of age unless we have first obtained permission from the child's parent or legal guardian. If we become aware that we have collected Personal Data from anyone under eighteen (18) years of age without the permission of the child's parent or legal guardian, we will take steps to remove such data.
We may update this Privacy Policy at least annually to reflect changes in our information practices. If we make any significant changes, we will notify you by email (to the email address specified in your account) or via a notice in the mobile applications before the changes take effect. We recommend that you periodically review this page for the latest information regarding our privacy practices.
Under Article 11 of the KVKK (Law on Protection of Personal Data), you have the following rights regarding your personal data:
• To request information regarding the processing of your personal data, if it has been processed,To exercise your rights mentioned above, you can send your written request, along with the necessary information to identify you and your explanations regarding the right you wish to exercise, to the address “Macun mah. 198. Cad. no:5/1 Yenimahalle/ANKARA”, clearly stating that the matter is related to the Personal Data Protection Law (KVKK), and with your wet signature to info@swordspace.com, as specified in the Communiqué on the Procedures and Principles for Applications to the Data Controller. Applications must be made in Turkish. Applications must include your name, surname, signature (if the application is in writing), residential or business address for notification purposes, email address (if any), telephone or fax number, and the subject of the request. This information is necessary for identity verification and obtaining accurate data. We request this information from you for identity verification purposes. Therefore, please refrain from transmitting data that you believe is not processed by our company.
In your application to exercise your rights as a personal data owner, as mentioned above, and to include your explanations regarding the right you wish to exercise; The matter you request must be clear and understandable, the subject of your request must relate to you personally, or if you are acting on behalf of someone else, you must be specifically authorized to do so and your authorization must be documented. The application must include your identity and address information, and supporting documents verifying your identity must be attached.
Applications submitted within this scope will be processed as soon as possible, and no later than 30 days. If the response to the applicant's application is to be given in writing, no fee will be charged for up to ten pages. A processing fee of 1 TL may be charged for each page exceeding ten pages. If the response to the application is provided on a recording medium such as a CD or flash drive, the fee that "Sword Space" may request cannot exceed the cost of the recording medium.
This privacy policy/information text regarding the processing of personal data is an integral part of the user registration agreement.