KVKK Disclosure Notice · Atlas Talks

1. Data controller

Legal name: DERİN AKADEMİ EĞİTİM VE DANIŞMANLIK HİZMETLERİ LTD. ŞTİ.
MERSIS number: 0293-1103-5790-0001
Tax office: Kozyatağı
Tax identification number: 2931103579
Address: İçerenköy Mah. Topçu İbrahim Sk. Quick Tower No: 8 / 10D, Ataşehir, İstanbul, 34752
Telephone: +905397983969
Email: derin@derinakademi.net
Website: https://atlastalks.com

2. Personal data processed

The following personal data of yours may be processed in connection with your use of the Platform:

Identity and contact data: name and surname, email address, telephone number.
Membership and transaction data: account details, subscription/credit packs purchased, usage history, order and invoice records.
Payment data: payment is taken through the infrastructure of the payment institution (iyzico); your card details are not seen or stored by the Company.
Voice and conversation content data: during a rehearsal you talk to a character voiced by artificial intelligence. Your voice is processed in real time for the length of the conversation, the text of the conversation (transcript) is produced, and the artificial intelligence Coach produces feedback for you from that text. The Company does not keep voice recordings.
Preference data: the consents you give or withdraw for the two optional purposes.
Transaction security and technical data: IP address, device/browser information, log records.

3. Purposes of processing personal data

Creating and managing your membership of the Platform,
Providing and performing the service you have purchased, or your organisation has purchased for you (spoken rehearsal and artificial intelligence Coach feedback),
Carrying out payment and invoicing processes,
Managing request, complaint and refund processes,
Measuring and improving the quality of the service,
Ensuring information security and fulfilling legal obligations,
If you consent: sending you reminders and repetition suggestions after your rehearsals (follow-up practice), and analysing your rehearsal performance solely for your own development tracking (personal development analysis).

4. Legal bases for processing

Your personal data are processed on the following legal bases under Article 5 of the KVKK:

Conclusion and performance of a contract (Article 5(2)(c)): your membership; running the spoken rehearsal, transcribing the conversation, and producing the Coach's evaluation and keeping it in your account; payment and invoicing. Because the spoken rehearsal is the service itself, no separate explicit consent is asked for this processing.
Fulfilment of a legal obligation (Article 5(2)(ç)): keeping invoices and records for the periods the legislation requires, and requests from authorised institutions.
Legitimate interest (Article 5(2)(f)): ensuring information security, preventing misuse, and measuring and improving the quality of the service. On this basis, the message our voice infrastructure provider sends when a conversation ends (transcript included) is kept encrypted for 30 days to improve the evaluation, and is then deleted.
Explicit consent (Article 5(1)): only for the two optional purposes, follow-up practice and personal development analysis. These options appear separately in your account settings and are off by default; leaving them off does not affect your use of the Platform or of spoken rehearsal. The details are in the Explicit Consent Statement.

5. Transfer of personal data

Your personal data are transferred to the following recipients, limited solely to the purposes above:

In Turkey: to the payment institution iyzico, to take payment; and to authorised public institutions and organisations under our legal obligations.
Abroad, to ElevenLabs (USA): your voice, the transcript and rehearsal details, to run the spoken rehearsal, transcribe the conversation and produce the evaluation.
Abroad, to Amazon Web Services (Germany, Frankfurt region): your data on the Platform, for hosting, the database, file storage and sending email.
When an organisation provides the service, to your organisation: the usage details listed in section 8.

6. Method of collection

Your personal data are collected electronically through the Platform's membership and purchase forms, your voice taken through the microphone during a rehearsal, your organisation's invitation or system (API, LMS) when an organisation provides the service, and automatic log systems.

7. Retention period

Your personal data are retained for as long as the purpose of processing requires and for the retention periods laid down in the legislation; at the end of that period they are erased, destroyed or anonymised. The periods applied today:

Voice recordings are not kept. Our voice infrastructure provider deletes its own copy within 30 days.
Transcripts, the Coach's evaluations and person-linked usage records are kept for 18 months, then erased or anonymised.
The message the provider sends when a conversation ends is deleted after 30 days.
Data processed for the two optional purposes are kept for 12 months.
When you ask for your account to be deleted, it is deleted after a 14-day waiting period, during which you can change your mind.
Invoice and accounting records are kept for the periods the legislation requires.

8. When an organisation provides the service

If you use the Platform through the invitation or system (API, embedded window, LMS) of an organisation, for example your employer:

Your organisation is the data controller for your rehearsal data within the training it has purchased; the Company processes those data on its behalf, as data processor. Your organisation informs you of the purpose and legal basis of that processing.
For the rehearsals you run in the organisation's space, your organisation sees which product and case you practised, when and for how long, whether you completed it, whether you reached the goal in each rehearsal, and the credits used.
Your organisation never sees the content of the rehearsal's analysis or of the Coach's evaluation, the transcript or the voice recording. Nothing you do in your personal space is shown to your organisation linked to you; credits used in your personal space appear in the organisation's statement only as a monthly, anonymous total. This boundary is enforced technically in the Platform and cannot be changed on your organisation's instruction.
When you accept your organisation's invitation, the rehearsals you run in its space are shared with it; it sees, for each rehearsal, only the case, when it was completed and whether you reached the goal. You can leave the organisation's space whenever you like; when you leave, sharing stops and the rehearsals you ran there stay with the organisation.
The Company is the data controller for your account, your session and security records, purchases you make in your own name, and the two optional purposes; the other sections of this notice apply to those data.

9. Contact and corporate request forms

The name, email address, telephone number (on the corporate request form) and message you send through the contact form and the corporate request form on our site are processed to answer your request and contact you, on the legal bases of steps towards concluding a contract (Article 5(2)(c)) and our legitimate interest (Article 5(2)(f)). Your message is not kept in our database or records; it is delivered as an email to our team's mailbox. Email is sent through Amazon Web Services (Germany). The form on the English version of the site writes to Scormy Inc. (USA); Scormy's privacy policy applies to that form.

10. Your rights as a data subject (KVKK Article 11)

You have the right to learn whether your personal data are processed; to request information if they have been; to learn the purpose of processing and whether they are used in accordance with that purpose; to know the third parties to whom they are transferred in Turkey or abroad; to request correction where they have been processed incompletely or inaccurately; to request their erasure or destruction where the conditions are met; to request that correction and erasure be notified to the parties to whom the data were transferred; to object to a result arising against you from analysis carried out exclusively by automated systems; and to claim compensation for any loss you suffer.

11. Applications

You may send requests concerning your rights to derin@derinakademi.net or in writing to the address above. For data processed on behalf of an organisation, you may apply to your organisation; we forward such applications that reach us to your organisation. Your applications are concluded within the periods laid down in the KVKK and the relevant legislation.