GENERAL CLARIFICATION TEXT WITHIN THE SCOPE OF THE LAW ON THE PROTECTION OF PERSONAL DATA NO. 6698

1- Protection of Personal Data

Elit Dil Okulu Danışmanlık ve Eğitim Hizmetleri Ltd. (Elite Dil Okulu), under Article 10 of the Personal Data Protection Law (KVKK) No. 6698, We would like to inform and enlighten you about our personal data processing activities.

2- Identity of Data Controller

Elit Dil Okulu Danışmanlık ve Eğitim Hizmetleri Ltd. Sti. has the title of data controller in accordance with the LPPD. As Elite Dil Okulu, we pay utmost attention to the security of your personal data as a data controller. With this awareness, we pay minimum attention to the processing, recording, storage of all kinds of personal data belonging to you in accordance with the rules of law and honesty and to the transfer/disclosure of our responsibility to third parties limited to the purpose for which they are processed within the limits permitted by the legislation.

3- Purpose of Personal Data Processing

In order to provide the products and services (for example, English courses) offered by Elit Dil Okulu to its customers under the best conditions, to provide products or services in a reliable and uninterrupted manner, maximize customer satisfaction, make payments, fulfill various transactions related to the aforementioned services, carry out and develop operations, promote the aforementioned products and services or different products and services, carry out promotional, marketing, advertising and campaign activities, inform you about opportunities, campaigns and other services, and fulfill the requirements of the contracts concluded with you, your identity information, address information, contact information and other personal data that are directly or indirectly related are obtained, recorded, stored securely in physical or electronic environment for processing purposes in accordance with the basic principles stipulated in the LPPD, are stored, maintained, changed, rearranged, disclosed and transferred in accordance with the legislation, taken over, classified, processed or prevented from using the data.

4- Persons to whom the Processed Personal Data can be Transferred and Purpose of Transfer

Elit Dil Okulu may transfer your personal data processed within the scope of the purposes described above to its employees, officers, auditors and consultants, independent audit companies, affiliates and group companies of Elit Dil Okulu, business partners and service providers, public institutions and organizations that receive services or work together to carry out the services or activities to be provided to you; to provide the products or services provided by Elit Dil Okulu personally or through subcontractors, to provide products or services in a reliable and uninterrupted manner, to maximize customer satisfaction, make payments, carry out various transactions related to the aforementioned services, carry out and develop operations, promote the aforementioned products and services or different products and services, carry out marketing, advertising and campaign activities, inform you about opportunities, campaigns and other services, fulfill the requirements of the contracts concluded with you, keep statistics, make internal plans and carry out information research activities. In addition, Elit Dil Okulu reports the information required to be reported and the information requested by the public authorities to the aforementioned authorities to the extent necessary and in accordance with the relevant legislation in order to comply with the information obligations of Elit Dil Okulu. Your data transferred within the scope of this article may be obtained, recorded, stored, changed, rearranged, disclosed, transferred, taken over, classified, processed or the use of the data may be prevented by third parties to whom the transfer takes place in accordance with the legislation on the protection of personal data.

5- Data Transfer Abroad

Your personal data by Elit Dil Okulu is provided by obtaining explicit consent in the light of the principles stipulated in Article 4(2) of the PDPL, or in case of the existence of the situations stipulated in Articles 5(2) and 6(3), without obtaining explicit consent and by complying with the rules in Article 9 of the Law. After the declaration of foreign countries with sufficient protection to be determined by the Personal Data Protection Board (“Board”) to the persons and organizations mentioned above and residing abroad, only the countries residing in these countries and the above-mentioned persons and organizations, which are determined and declared not to have sufficient protection for the data controllers in Türkiye and in the relevant foreign country, on the condition that an adequate protection is committed in writing and the permission of the Board can be obtained in terms of the relevant transfer.

6- Foreign Language Level Determination

Before starting foreign language education, the current level of the person should be determined and training plans should be created accordingly. For this reason, online and speaking exams are held to determine the levels of the students. Speaking exams are held visually and audibly via telephone or online platforms. The records of the placement exams are kept to be used for quality control and to improve the quality of the trainings given.

Method and Legal Reason of Collecting Personal Data:

Your personal data may be collected verbally and/or in writing or through secure electronic media through call centers, web pages, service points of Elit Dil Okulu and in accordance with the contracts concluded for the performance of the service. Your personal data collected for this legal reason may also be processed and transferred for the purposes specified in Articles (1) and (2) of this text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 7 of the LPPD.

8- Pursuant to Article 11 of the PPDL, Your Rights Specified in Article

If you, as the data owner, submit your requests regarding your rights to Elit Dil Okulu by the methods regulated below in this Clarification Text, Elit Dil Okulu will conclude the request free of charge as soon as possible and within 30 (thirty) days at the latest, depending on the nature of the request. However, if a fee is stipulated by the Personal Data Protection Board, the fee in the tariff determined by our Company will be charged.   Pursuant to Article 11 of the KVKK, The rights you have in accordance with the article are as follows;

a) Learning whether your personal data has been processed,

b) Requesting information regarding the personal data if they have been processed

c) Learning the purpose of the data processing and if this data is used for intended purposes,

d) To know about the third parties to whom personal data are transferred domestically or abroad,

e) Requesting the rectification of the incomplete or inaccurate data, if any,

f) Requesting the deletion or destruction of your personal data in accordance with the relevant article of the LPPD,

g) Requesting notification of the operations carried out in compliance with subparagraphs (d) and (e) to third parties to whom their personal data has been transferred,

h) Objecting to consequences to their detriment, arising from the analysis of the processed data exclusively via automatic systems,

i) Claiming compensation in case of suffering loss due to illegal processing of the personal data

In accordance with paragraph 1 of Article 13 of LPPD, you can submit your requests to our company to use your  aforementioned rights in written or through other methods determined by Personal Data Protection Board. Since the Personal Data Protection Board has not determined any method at this stage, you must submit your application to Elit Dil Okulu in writing in accordance with the Personal Data Protection Law. In this context, to exercise your above-mentioned rights, your request, which includes the necessary information to determine your identity and your explanations about your right that you request to exercise from the rights specified in Article 11 of the LPPD, shall be sent to Elit Dil Okulu Danışmanlık ve Eğitim Hizmetleri Ltd. Sti. at Levent Mahallesi Yosun Sokak No:7 Besiktas/Istanbul. Sti. You can personally hand it in to the Directorate with identity documents, send it through a notary public or other methods specified in the KVKK. This Clarification Statement was prepared on 20.02.2024. In the event of any change in the text of the Statement, the effective date and content of this Clarification Statement will be updated.

EXPRESS CONSENT DECLARATION UNDER THE LAW ON THE PROTECTION OF PERSONAL DATA

Elit Dil Okulu Danışmanlık ve Eğitim Hizmetleri Ltd. Ltd. Within the framework of the General Clarification Text within the scope of the Law on the Protection of Personal Data, submitted to your information by (Elit Dil Okulu) in accordance with the relevant provisions of the Law on the Protection of Personal Data No. 6698 (KVKK),

To provide the products and services offered by Elit Language School to its customers under the best conditions, provide products or services in a reliable and uninterrupted manner, maximize customer satisfaction, make payments, carry out various transactions related to the aforementioned services, carry out and develop operations, promote the aforementioned products and services or different products and services, carry out marketing, advertising and campaign activities, that the identity information, address information, contact information and other personal data directly or indirectly related to the purposes of informing the campaigns and other services and fulfilling the requirements of the contracts concluded with the customers can be processed in accordance with the general principles stated in Article 4 of the Law on the Protection of Personal Data No. 6698 (KVK Law), especially the principle of preservation for the period stipulated in the legislation or required for the purpose for which they are processed; that they can be obtained, recorded, stored securely in physical or electronic environment for the purpose of processing, can be changed, rearrangedited, disclosed and transferred in accordance with the legislation, can be taken over, classified may be processed or the use of the data may be prevented; I accept and declare that I have been informed by Elit Dil Okulu about the above-mentioned issues and that I have given my explicit consent within the framework of the PPD Law.

I accept and declare that my personal data may be transferred by the Company to the Company's employees, officers, group companies (Company and/or business partners, shareholders), legally authorized public institutions and organizations, independent audit companies within the framework of legal obligations and legal limitations in order to perform its activities, survey companies, business partners and service providers from whom the Company receives services or with whom it works for the execution of the services and/or activities to be provided to me, provided that they are bound by the above-mentioned purposes, and that I have express consent in this regard.

However, in accordance with Article 11 of the KVK Law and the relevant legislation; I have the right to apply to Elit Dil Okulu to learn whether personal data has been processed, request information about it if my personal data has been processed, learn the purpose of processing my personal data and whether it has been used in accordance with its purpose, know the third parties to whom my personal data has been transferred in the country or abroad, request their correction if the personal data has been processed incompletely or incorrectly, request the deletion or destruction of my personal data in the event that the reasons requiring the processing of these data disappear, request the notification of these correction and deletion requests to third parties to whom personal data has been transferred, object to the emergence of a result against me by analyzing the processed data exclusively through automated systems, request the compensation of the damage in case of damage due to the unlawful processing of my personal data, and to use these rights, I request my request the necessary information and explanations regarding my right to use my identity at the address of Levent Mahallesi Yosun Sokak No:7 Besiktas/Istanbul I accept that I have the right to submit my identity documents personally or through a notary public or other methods specified in the PPD Law.

In addition, I accept and declare that the personal data I have shared with Elit Dil Okulu is accurate and up-to-date, and that I will notify Elit Dil Okulu of any changes in this information.

That I have given my explicit consent to the processing of my relevant personal data, including my sensitive personal data defined in the PPD Law, to its use and sharing limited to the purpose of processing within the scope of the relevant process, to its storage within the required period, and that I have been given the necessary clarification in this regard; I have read and understood this text, the Company's Regulation on the Protection and Processing of Personal Data and the Clarification Text;

Data Owner