§1 Who We Are
Wellness Vision is operated by Serkan Yüksel, an independent content creator based in the Republic of Turkey. Contact: [email protected]. Wellness Vision is the data controller for personal data described below.
§2 What Data We Collect
We collect only the minimum data needed for each surface you interact with:
- Newsletter signup (Beehiiv widget): email address, optional first name — for newsletter delivery only.
- Website analytics (Cloudflare Web Analytics): aggregated page views, country and referrer — cookieless, no cross-site tracking, no profile of individual visitors.
- Visit statistics (Umami Cloud): page views, time spent on the site, referrer, browser, operating system, device type and approximate location (country). On top of page views, it counts a few anonymous interaction events — whether a page was scrolled halfway or to the end, whether it was read for 30 seconds, 1 or 3 minutes, and whether a video, the comparison tool, a calculator, a short-answer box or a link to our newsletter, YouTube or our tools and data was used — so we can see whether pages are actually read. These events carry no personal data. Umami uses no cookies and does not store IP addresses in its analytics records — it processes them only briefly to deliver the request, calculate an anonymous visitor identifier and derive the approximate location. Browsers that send a “Do Not Track” signal are not counted. We see only aggregated statistics.
- Fonts and videos: fonts are served from our own domain, so loading a page sends nothing to Google. Article videos stay a static image until you press play; only then does the YouTube player (youtube-nocookie.com) load and YouTube receive your request.
- Contact form / mailto: whatever you write in your email — to reply to your message.
- YouTube channel: all viewer interactions governed by Google's YouTube Terms of Service. Wellness Vision has no direct access to YouTube viewer PII.
We do NOT use Google Analytics, Meta Pixel, advertising cookies, or cross-site trackers.
§3 Legal Basis (GDPR Art. 6)
- Newsletter: Art. 6(1)(a) — your explicit opt-in consent (double opt-in confirmation).
- Analytics: Art. 6(1)(f) — legitimate interest (aggregate only, no PII).
- Email reply: Art. 6(1)(b) — performance of pre-contractual contact.
§4 Sub-Processors
We rely on the following sub-processors (all GDPR Art. 28 Data Processing Agreements in place):
- Beehiiv Inc. (newsletter platform, USA NY) — DPA · 17 sub-processors
- Cloudflare Inc. (hosting, CDN, security and cookieless Web Analytics, USA CA) — DPA
- Umami Software, Inc. (cookieless visit statistics, USA; analytics data stored in Umami Cloud's EU data region) — DPA
- Google LLC (YouTube) (video hosting, separate platform ToS, USA) — Google YouTube ToS
§5 International Data Transfers — Schrems II
Beehiiv processes data in the United States. Transfers are protected by EU Standard Contractual Clauses (Module 2, Commission Decision 2021/914) plus UK SCC Addendum. We perform a Transfer Impact Assessment annually. Cloudflare processes traffic data only (no PII). Umami stores analytics data in its EU data region; IP addresses are processed only transiently and are not stored in analytics records.
§6 Your Rights (GDPR Articles 12–22)
You may request access, correction, deletion, portability, restriction, or objection at any time by emailing [email protected]. We reply within 30 calendar days (Art. 12). Identity verification may be required for legitimate request fulfilment. You have the right to lodge a complaint with your supervisory authority (EU) or the KVKK (Türkiye).
§7 EU AI Act Article 50 — AI-Generated Content
Wellness Vision uses AI tools to produce educational cost-comparison content. All AI-generated assets are disclosed per EU AI Act Article 50 (effective 2 August 2026):
- Voice: Azure Neural TTS Dragon HD Emma2 (Microsoft)
- Thumbnails: DALL·E gpt-image-1.5 (OpenAI) — C2PA-signed
- B-roll visuals: Grok Imagine (xAI)
- Music: Soundraw AI Creator licence
Per-video provenance manifests are published at /transparency/ hub.
§8 Children's Privacy
Wellness Vision content is not directed at children under 16. We do not knowingly collect personal data from minors. If you believe a minor has submitted personal data, please email [email protected] and we will delete it.
§9 Retention
- Newsletter subscribers: until unsubscribe + 30-day grace period
- Analytics (aggregate, no PII): 24 months
- Email correspondence: 24 months
§10 Notice for users in Türkiye (KVKK, Article 10)
For users resident in Türkiye, the data controller under the Turkish Personal Data Protection Law (KVKK) is Serkan Yüksel. The personal data we process and your rights are described in §2–§6. To exercise your KVKK rights, write to [email protected]; a Turkish version of this notice is available on request. You can also complain to the Turkish Personal Data Protection Authority: kvkk.gov.tr.
§11 Changes
Material changes to this policy will be announced via newsletter and a footer banner at least 30 days before they take effect. Version log: v1.0 (March 2026) · v2.0 (2026-05-22 — GDPR + KVKK + EU AI Act Article 50 compliance update) · v2.1 (2026-10-21 — analytics corrected to Cloudflare Web Analytics; fonts self-hosted; videos load only on click) · v2.2 (2026-10-25 — cookieless visit statistics via Umami Cloud added) · v2.3 (2026-10-26 — anonymous reading and interaction events in Umami described) · v2.4 (2026-10-27 — list of interaction events completed: calculators, short-answer box, links to tools and data) · v2.4.1 (2026-11-02 — §10 Türkiye notice translated into English; content unchanged).