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KVKK Disclosure Notice

Pursuant to Law No. 6698 on the Protection of Personal Data ("KVKK"), we would like to inform you about the processing of the personal data of users of the Project Atlas platform ("the Platform") by DERİN AKADEMİ EĞİTİM VE DANIŞMANLIK HİZMETLERİ LTD. ŞTİ. ("Derin Akademi" / "the Company") in its capacity as data controller.

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
+902162660391
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: by the essential nature of the service, your voice recording and the text of your conversation (transcript) during rehearsal conversations are processed; this content is evaluated by the artificial intelligence coach in order to produce feedback for you.
  • 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 (spoken rehearsal + 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.

4. Legal bases for processing

Your personal data are processed pursuant to Article 5 of the KVKK on the legal bases of being directly related to the conclusion or performance of a contract, the fulfilment of a legal obligation, and legitimate interest, provided that this does not harm your fundamental rights and freedoms.

The processing of voice recordings and conversation content, and the transfer of those data to service providers abroad, rest on your explicit consent. If you do not give explicit consent, the spoken rehearsal feature cannot be offered; you can, however, continue to make use of the other general content.

5. Transfer of personal data

Your personal data may be transferred, limited solely to the purposes above;

  • In Turkey: to the payment institution (iyzico), to hosting/infrastructure service providers, and to authorised public institutions and organisations;
  • Abroad: to the artificial-intelligence-based voice processing and language model service providers and the cloud infrastructure providers used to operate the service,

within the framework of Articles 8 and 9 of the KVKK and, as regards voice and conversation content, on the basis of your explicit consent. A current list of service providers will be sent to you on request.

6. Method of collection

Your personal data are collected electronically through the Platform's membership and purchase forms, the voice recording taken through the microphone during a rehearsal, and automatic log systems.

7. Retention period

Your personal data are retained for as long as the purpose of processing requires and for the limitation/retention periods laid down in the relevant legislation; at the end of that period they are erased, destroyed or anonymised. For voice recordings, the retention period is limited to the period determined for the provision of the service and for proof in any dispute.

8. 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.

9. Applications

You may send requests concerning your rights to derin@derinakademi.net or in writing to the address above. Your applications are concluded within the periods laid down in the KVKK and the relevant legislation.