§1 Who We Are
Wellness Vision is operated by Serkan Yüksel, an independent content creator based in the Republic of Turkey. Contact: privacy@wellnessvision.health. 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.
- Google Analytics 4 — depending on where you are: if you visit from the EU/EEA, the UK, Switzerland, Türkiye or Brazil, a banner first asks whether we may use Google Analytics; nothing is sent to Google until you press “Accept”, and if you press “Decline”, Google Analytics is not loaded at all. Elsewhere (for example in the US) Google Analytics runs by default and you can switch it off at any time via “Cookie settings” at the bottom of every page. We tell the regions apart by the country Cloudflare derives from your IP address for each request; we do not store it. If the country cannot be determined, the banner is shown. When active, Google Analytics sets two cookies (
_gaand_ga_<ID>, stored for up to 2 years) and records the pages you view, how long you stay, the referring page, browser, operating system, device type, screen size, language and approximate location (city/country). For visitors from the EU, Switzerland and the UK, Google Analytics does not log or store IP addresses; it uses them only to derive the approximate location. We have switched off Google signals and all advertising and personalisation features, so the data is not used to show you ads. You can withdraw your consent at any time via “Cookie settings” at the bottom of every page; the cookies are then deleted. - 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 Meta Pixel, advertising cookies or cross-site trackers. Google Analytics runs only with consent in the EU/EEA, UK, Switzerland, Türkiye and Brazil, can be switched off everywhere (see above), and has its advertising features switched off.
§3 Legal Basis (GDPR Art. 6)
- Newsletter: Art. 6(1)(a) — your explicit opt-in consent (double opt-in confirmation).
- Analytics (Cloudflare, Umami — cookieless): Art. 6(1)(f) — legitimate interest (aggregate only, no PII).
- Google Analytics: in the regions listed in §2, Art. 6(1)(a) — your consent via the banner; elsewhere, our legitimate interest in measuring how the site is used, with the right to object at any time via “Cookie settings”; storing and reading cookies on your device: § 25(1) TDDDG (Germany) and the corresponding ePrivacy rules in other EU countries. Withdrawing consent does not affect processing before the withdrawal.
- 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 Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland; Google Analytics 4, see §2 for when it runs; data may also be processed by Google LLC, USA) — Google Ads Data Processing Terms
- 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. Google LLC is certified under the EU-U.S. Data Privacy Framework, which the European Commission found adequate on July 10, 2023; Google Analytics data is transferred to the USA only with your consent. 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 privacy@wellnessvision.health. 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 privacy@wellnessvision.health and we will delete it.
§9 Retention
- Newsletter subscribers: until unsubscribe + 30-day grace period
- Analytics (aggregate, no PII): 24 months
- Google Analytics: event-level data deleted after 2 months; user-level data after 14 months without a new visit; cookies expire after at most 2 years or when you withdraw consent or switch it off
- 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 privacy@wellnessvision.health; 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) · v2.5 (2026-11-09 — Google Analytics 4 added: consent banner in the EU/EEA, UK, Switzerland, Türkiye and Brazil, opt-out elsewhere; advertising features off).
