Notice on the Processing of Personal Data

The “data controller” of the personal data collected through this website (akillikapsul.com) is Allurion Technologies, Inc. (“Allurion”).

• Data Controller: Allurion Technologies, Inc.
• Address: 11 Huron Drive, Natick, MA 01760, USA
• Website: https://www.allurion.com

Pursuant to Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”) and its secondary legislation, Allurion has appointed a data controller representative in Türkiye to facilitate the exercise of the rights of data subjects residing in Türkiye and communication with the Turkish Personal Data Protection Authority.

Our data controller representative in Türkiye pursuant to Article 11 of the KVKK:

• Representative: Kavlak Law Office (Att. Fırat Barış Kavlak and Partner Att. Aygen Kavlak)
• Address: Nispetiye Caddesi Seher Yıldızı Sokak No: 23 D:11, Etiler 34340 Beşiktaş / İstanbul
• E-mail: info@kavlak.av.tr
• Phone: +90 212 324 55 00

Persons residing in Türkiye may submit all their requests and applications under the KVKK through our data controller representative.

Allurion has authorized Alzey Partners Danışmanlık ve Ticaret Ltd. Şti. (“Alzey Partners”) as data processor to operate this website in Türkiye and to process the personal data collected in accordance with Allurion's instructions. Alzey Partners acts within the framework of the Data Processing Agreement signed with Allurion and does not determine any independent processing purpose for your personal data.

• Data Processor: Alzey Partners Danışmanlık ve Ticaret Ltd. Şti.
• Capacity: Authorized Master Distributor and Data Processor of Allurion Technologies in Türkiye

The following personal data is processed through this website:

• Identity Data: First name, last name
• Contact Data: Phone number, city
• Health Data (Special Category Personal Data): Height, weight, and age information you share
• Transaction Security Data: IP address, browser information, device information, visit date/time
• Marketing / Channel Data: UTM parameters, referring link information
• Preference Data: Communication channel preference (WhatsApp / phone)

Height, weight, and age information is health data classified as “special category personal data” under Article 6 of the KVKK and is processed only with your explicit consent.

• Conducting the free pre-assessment consultation you requested
• Providing health information about the Allurion program
• Referral to the relevant Allurion-certified authorized clinic and specialist physician
• Measuring and improving service quality
• Fulfilling legal obligations
• Ensuring website security and protecting the technical infrastructure

Your personal data is not used for direct marketing; commercial electronic messages are sent only if you have separately given explicit consent.

• KVKK Art. 5/2-(c): Establishment or performance of a contract
• KVKK Art. 5/2-(f): Legitimate interests of the data controller
• KVKK Art. 5/1: Explicit consent (health data, commercial electronic messages)
• KVKK Art. 6/2: Explicit consent for special category personal data

Domestic Transfers

• To Allurion-certified authorized clinics and physicians: only name, city, and contact information, for referral purposes. Health data only with explicit consent.
• Alzey Partners (Data Processor): within the scope of operational services.
• Public institutions and authorities where legally required.

International Transfers

As the data controller Allurion is established in the USA, your personal data may be transferred to the USA and to EU countries where technical infrastructure providers are located. Transfers are carried out under safeguards within the framework of Article 9 of the KVKK.

Your personal data is not shared with third-party advertising networks or data brokers.

• Lead form records: 24 months
• Records containing health information: 24 months (until explicit consent is withdrawn)
• Logs and technical records: 12 months
• Within the scope of legal obligations: the period prescribed by the relevant legislation

• Database servers hosted in the EU (Frankfurt) region
• Restriction and logging of access rights
• TLS/HTTPS encryption
• Confidentiality undertakings at employee and subcontractor level
• Regular security audits

• To learn whether personal data is being processed
• To request information if it has been processed
• To learn the purpose of processing
• To know the third parties to whom data is transferred domestically or abroad
• To request correction if processed incompletely or inaccurately
• To request erasure or destruction
• To request notification of these operations to third parties to whom data has been transferred
• To object to a result unfavorable to you arising from analysis exclusively by automated systems
• To claim compensation for damages arising from unlawful processing

Türkiye Data Controller Representative (Primary Contact)

• Mail: Kavlak Law Office — Nispetiye Caddesi Seher Yıldızı Sokak No: 23 D:11, Etiler 34340 Beşiktaş / İstanbul
• E-mail: info@kavlak.av.tr (subject: “Allurion KVKK Application — akillikapsul.com”)

Directly to Allurion

• E-mail: privacy@allurion.com

Applications are concluded within 30 days at the latest.

For cookies, please see the /cerez-politikasi page.

Allurion updates this notice when necessary. The current version is always available at akillikapsul.com/kvkk.