Privacy Policy

1. Identity of the Data Controller

This Privacy Policy has been prepared by CTM Informatics Software INC. ("Company") in its capacity as data controller, within the scope of the Law on Protection of Personal Data No. 6698 ("Law"). This text aims to inform you, within the framework of the disclosure obligation regulated under Article 10 of the Law, about the methods of collection, purposes of processing, legal grounds, transfer, and your rights as a data subject with respect to your personal data.

2. Personal Data Processed and Their Categories

During your visit to the Website and/or your use of our Services, the following personal data are processed:

3. Purposes of Processing Personal Data

Your personal data are processed for the following purposes:

• Creation and management of your user account,
• Providing a personalized learning experience and AI-driven educational guidance based on your preferences,
• Operating and improving the AI-powered tutoring and learning platform services,
• Generating relevant and contextual AI responses to support your academic progress and learning goals,
• Processing your subscription and payments,
• Monitoring and optimizing the user experience and service quality,
• Ensuring and improving the technical functionality of the Website,
• Generating anonymous statistics on the use of the Website and learning trends,
• Carrying out information security processes and protecting the Website,
• Fulfilling legal obligations and providing information to authorized persons, institutions, and organizations.

4. Method of Collection of Personal Data

Your personal data are collected electronically and by automated means through the Website and also through cookies. For detailed information about cookies, you may review our Cookie Policy.

5. Legal Grounds for Processing Personal Data

Your personal data are processed based on the following legal grounds specified in Article 5 of the Law:

6. Transfer of Personal Data

Your personal data may be transferred to the following parties in accordance with the conditions set out in Articles 8 and 9 of the Law, limited to the purposes stated above:

• Service Providers and Business Partners: Cloud-based infrastructure and hosting services, third-party payment processors for subscription management, website analytics services, and service providers used to power the AI tutoring system and process your messages to generate educational responses,
• Legal and Professional Advisors: Audit firms, information security consultants, and legal advisors,
• Authorized Public Institutions and Organizations: Authorized authorities, courts, and law enforcement agencies upon legal request or to fulfill our legal obligations.

7. Retention Period of Personal Data

Your personal data are retained for the periods required by the purposes of processing and in any case for the statute of limitations periods stipulated in applicable legislation. Following the expiry of the retention periods, your personal data are deleted, destroyed, or anonymized in accordance with Article 7 of the Law and the provisions of the Regulation on Deletion, Destruction, or Anonymization of Personal Data.

8. Measures Taken for the Protection of Personal Data

Our Company takes the necessary technical and administrative measures pursuant to Article 12 of the Law in order to prevent the unlawful processing of and access to your personal data, and to ensure its preservation.

9. Your Rights as a Data Subject

Pursuant to Article 11 of the Law, as a data subject you have the following rights:

• To learn whether your personal data are being processed,
• To request information regarding the processing of your personal data if it has been processed,
• To learn the purpose of processing your personal data and whether they are used in accordance with that purpose,
• To know the third parties to whom your personal data are transferred, domestically or abroad,
• To request the correction of your personal data if they are incomplete or incorrectly processed,
• To request the deletion or destruction of your personal data within the framework of the conditions stipulated in Article 7 of the Law,
• To request that the correction, deletion, or destruction operations be notified to the third parties to whom your personal data have been transferred,
• To object to a result that is detrimental to you arising from the analysis of processed data exclusively through automated systems,
• To request the compensation of damages in the event that you suffer damage due to the unlawful processing of your personal data.

10. Method of Application

In order to exercise the rights stated above, you may submit your application, prepared in accordance with the conditions set forth in the Communique on Procedures and Principles for Applications to the Data Controller, to our Company through one of the following methods:

• By personally submitting a wet-signed petition to the Company's address or through a notary public,
• Through a registered electronic mail (KEP) address,
• By sending a petition signed with a secure electronic signature or mobile signature via e-mail.

Your applications shall be concluded free of charge within the shortest possible time and no later than 30 (thirty) days, depending on the nature of your request. However, in cases where the transaction requires an additional cost, a fee may be charged at the tariff determined by the Personal Data Protection Board.

11. Data Controller Contact Information

12. Policy Changes

Our Company reserves the right to make changes to this Privacy Policy as it deems necessary. Changes to the Policy shall enter into force on the date they are published on the Website.