PERSONAL DATA PROTECTION — TURKISH KVKK
Athlete & Creator Application Privacy Notice
Information on how applicant personal data is collected and used for the Harmanin Athlete & Creator Program, administered by the Turkish legal entity.
01 — Data controller
The registered details of the Turkish company determining the purposes and means of application handling:
02 — Personal data and collection methods
The online application may collect your name, contact details, over-18 declaration, country and city, sport discipline, social media and portfolio links, follower range, content formats, past brand collaborations, motivation, work preferences, and optional commercial expectations. We may record submission time, notice version, and technical anti-abuse data. Public profiles you provide may be reviewed for this application. Please do not include health, biometric, or other sensitive-category information.
Social media insights and portfolio images
As part of their application, candidates may optionally upload statistics relating to their Instagram, TikTok or YouTube accounts, such as follower numbers, reach over the last 30 days, average video and story views, and engagement rate; screenshots showing these statistics; and portfolio photographs from their content creation work. This information is used to assess a candidate’s content creation experience and suitability for a potential collaboration. The statistics are self-reported by the candidate and are not considered automatically verified by the social media platforms.
Uploaded screenshots and photographs are protected for review only through authorized application-review accounts; they are not used in advertising, campaigns or public promotions without a separate appropriate legal basis or agreement. Candidates are asked to remove or obscure unnecessary personal data about third parties, private messages or other sensitive information from images. Uploaded files are subject to the retention and deletion rules for application data described below.
03 — Purposes and legal grounds
Data may be used to receive and review an application, communicate with applicants, discuss potential brand-athlete or content-creator collaborations, protect the platform and meet legal obligations. The actual legal conditions under Article 5 of Turkish Law No. 6698 (KVKK), mapped to each purpose and data category, must be specified below:
04 — Recipients of personal data
List authorized Harmanin applicant-review staff and actual hosting, email or other service providers, together with the recipient categories and disclosure purposes:
05 — International transfers
Clearly state whether information is transferred outside Türkiye through servers, service providers, or remote staff access. Where transfers occur, identify the recipient, destination, purpose and lawful safeguards under Article 9 of KVKK:
06 — Retention and deletion
Specify actual retention and deletion rules for unsuccessful applications, selected collaborators and records required for legal disputes:
07 — Your rights
To exercise rights under Article 11 of Turkish Law No. 6698 (KVKK), please contact the Turkish data controller using the address below. Requests are handled under Article 13 and applicable procedures. Where legally available, you may lodge a complaint with the Turkish Personal Data Protection Authority.
08 — Optional community updates
Application review is separate from promotional or community messages. Any option to receive marketing communications must be separate and optional; declining marketing is not a reason to reject an application. A method for withdrawing marketing permission must also be provided.
09 — Application review
Applications are reviewed by authorized people. Social-media details and experience should only be used for the stated assessment purposes. Any future solely automated decision-making with significant effects would require appropriate further disclosure and safeguards.
Privacy notice version: 2026-10-v1
