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KVKK privacy notice

Privacy notice for KOCHUM users under the Turkish Personal Data Protection Law No. 6698.

DraftLast updated: [date]

This text is a placeholder draft with no legal effect. Before publishing it must be completed with the company's details and reviewed by a legal advisor. Fields in square brackets are to be filled in. The Turkish version is the binding one.

1. Data controller

Under the Personal Data Protection Law No. 6698 ("KVKK"), your personal data is processed by [Company name] ("KOCHUM") as the data controller, within the scope described below.

Address: [Full address] · MERSIS no: [MERSIS number] · Email: [email protected]

2. Personal data we process

While providing the service, the following categories of personal data may be processed:

  • Identity: first name, last name, [year of birth].
  • Contact: email address, [phone number].
  • Education: grade, field, goals and study preferences.
  • Usage and performance: questions solved, answers given, mock exam results, durations, analytics and study plan.
  • Transaction security: IP address, session and device information, login records.
  • [Once payments start: invoice and payment transaction details. Card details are not stored by KOCHUM.]

3. Purposes of processing

Your personal data is processed to:

  • Create your membership and manage your account,
  • Provide and personalise question solving, mock exams, analytics, the study plan and the preference robot,
  • Share your study data with a teacher or coach whose invitation you accepted,
  • Keep information secure and prevent misuse,
  • Answer support requests and improve the service,
  • Meet legal obligations.

4. Collection method and legal grounds

Your personal data is collected electronically through the KOCHUM website and apps, both when you provide it and automatically while you use the service.

Your data is processed on the legal grounds in Article 5 of the KVKK: the establishment or performance of a contract, compliance with a legal obligation, and the data controller's legitimate interest provided it does not harm your fundamental rights and freedoms. [Any processing requiring explicit consent will be listed here.]

5. Transfer of personal data

Limited to the purposes above, your personal data may be transferred to suppliers that provide services such as hosting, email and SMS, to a teacher or coach whose invitation you accepted, and to legally authorised public institutions.

[If data is transferred abroad, the country, the recipient and the basis under Article 9 of the KVKK will be stated here.]

6. Your rights under Article 11 of the KVKK

By applying to the data controller, you have the right to:

  • Learn whether your personal data is processed,
  • Request information if it has been processed,
  • Learn the purpose of processing and whether it is used accordingly,
  • Know the third parties in Turkey or abroad to whom it is transferred,
  • Request correction if it is incomplete or inaccurate,
  • Request deletion or destruction under the conditions of Article 7 of the KVKK,
  • Request that corrections, deletions and destructions be notified to third parties it was transferred to,
  • Object to a result against you that arises solely from analysis by automated systems,
  • Claim compensation for damage caused by unlawful processing.

7. How to apply

You can send requests about your rights, in line with the Communiqué on the Procedures and Principles of Application to the Data Controller, from your registered email address to [email protected] or in writing to [postal address]. Your application is concluded free of charge within 30 days at the latest.

For questions about this text, write to [email protected].