Privacy Policy
TTURKISH PRIVACY POLICY
TTurkish is dedicated to safeguarding your personal data. We have strived to articulate this Privacy Policy in clear and straightforward language, ensuring transparency and accessibility in communicating our privacy commitments. It is our sincere hope that you gain a comprehensive understanding of how we prioritize the security of your personal data.
Before you grant us consent for processing your personal data or furnish any personal information through forms on our website, we kindly urge you to thoroughly read this Privacy Policy. This ensures mutual understanding of the terms governing our collaboration.
This Privacy Policy pertains to your utilization of the services provided by TTurkish, as delineated in our Terms of Service. The document elucidates the circumstances under which we process personal data for users of the TTurkish Platform, the methods employed, conditions for potential disclosure, user rights concerning personal data, and the measures implemented to maintain its security.
GENERAL Access to the TTurkish Platform (including the Website, related software, and TTurkish mobile device application) is available with or without the obligation to register an account. Browsing the Website is possible without registration. However, to utilize the TTurkish mobile device application, account registration is a prerequisite. Limited use of the services is achievable without divulging personal details (e.g., browsing the Website, exploring how TTurkish operates, perusing the tutor list, reading the TTurkish Blog, reviewing service offerings, etc.). Nonetheless, when accessing the Website, we collect log information and employ cookies on your device to track your activity. Opting out of cookies is possible, excluding those essential for the Website's functionality.
For registered users, TTurkish may collect and process cookie identifiers, as well as data provided during registration. This may include first name, last name, email, phone number, Skype ID, or social network ID (if linked through Facebook or Google Calendar access), time zone, interface language, IP address, and device type. For tutors, additional data such as zip code, gender, year of birth, city of residence, and education experience may also be collected and processed.
We appreciate your commitment to understanding the conditions under which we operate and value your trust in us to responsibly handle your personal data.
Data Collection and Processing
Registered users have the option to provide profile pictures and select their preferred currency for actions aligned with our Refund and Payments Policy. Detailed information about the specific instances of data collection and the purposes of processing such data is available in a dedicated section of this Privacy Policy.
We reserve the right to modify this Privacy Policy periodically, and it is advisable to review this page regularly to ensure your satisfaction with any alterations. Changes will be posted on this page, with the modification date at the top. Additional notifications regarding amendments will be sent to your email.
Occasionally, we may experiment with different features on the TTurkish Platform that could impact the scope, purposes, or other aspects of personal data processing. In such cases, we will provide prior notification and, if necessary, obtain your consent.
For any inquiries regarding this Policy and our services, please direct them to legal@tturkish.com.
Definitions of Personal Data and Processing of Personal Data
a. Personal data: Any information related to you that, either alone or in conjunction with other information, enables a person collecting and processing such information to identify you as an individual.
b. Processing of personal data: Any operation involving your personal data, whether automated or not, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or other means of making available, alignment or combination, restriction, erasure, or destruction.
c. Data subject: Any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing; in this context, referring to you as a user of TTurkish.
d. Consent of the data subject/user: Any freely given, specific, informed, and unambiguous indication of the data subject/user’s wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Lawful Bases for Processing
TTurkish processes your personal data only when there are lawful bases. Specifically, we process your personal data when:
a. Processing is based on the consent you have given. This includes newsletters, collection, analysis, and publication of user feedback and reviews, analysis of video lessons, your participation in events and webinars, and the placement of different types of cookies.
b. Processing is necessary to provide our services to you according to our Terms of Service, constituting a contract between you and us for information services on TTurkish.
c. Processing is based on explicit consent you have given to process your biometric information for tutor identity verification and fraud identification.
d. Processing is necessary for our legitimate interests. These interests may include compliance with U.S. financial and accounting legislation, assessing TTurkish’s business efficiency through traffic and financial performance analysis, promoting TTurkish through various channels, performance of contracts with TTurkish Business customers, user session control and fraud prevention, tutor verification, and enhancing the learning experience for tutors and students through AI-powered personalized recommendations, improved lesson planning, and interactive learning tools.
e. Compliance with applicable legislation (e.g., data subject request processing).
f. In exceptional cases, to protect your vital interests or those of another natural person; or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
In all cases, we will notify you about the applied legal basis for processing and other relevant details before initiating the processing of your personal data on a specific legal basis, unless unable to do so in accordance with our obligations under any applicable legislation.
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Data We Collect: Scope
TTurkish collects specific information from you for the purposes outlined below:
(1) Account for Students TTurkish collects and processes personal data provided by you during registration and subsequent profile adjustments in your Student Account. For registration, you provide login credentials (username and password), first name, last name, and email. Additional information can be added to your account, such as syncing with Google and Preply Calendars. This supplementary data may aid in scheduling with a tutor or enhancing visibility of your schedule. The provision of additional information beyond the necessary registration details is optional.
(2) Account for Tutors TTurkish collects and processes personal data submitted during registration and profile editing for Tutors. Registration involves providing login credentials (username and password), first name, last name, and email. Similar to Student Accounts, additional information can be added, and syncing with Google and Preply Calendars is an option. Tutors have the choice to include extra details in their profiles, such as zip code, country, language skills, education, and work experience.
Certain personal data, such as users' names and locations, may be publicly visible on the Services or the web. Privacy settings within the "Edit My Profile" section of the Service allow users to choose which information is made public.
(3) Subscription to the TTurkish Blog Subscribing to the TTurkish Blog for newsletters and updates requires providing your email address.
(4) Posting of Information TTurkish processes personal data freely submitted on the platform, including surveys, online forms, questions, comments in the Q&A section, and feedback. Information posted on the platform, including personally identifiable information, may be visible to other users. TTurkish retains this information for dispute resolution, customer support, and troubleshooting, as permitted by law.
(5) Service Use, Cookies, and Other Technologies Monitoring and analyzing web traffic, as well as tracking user behavior, are carried out when you use TTurkish Services. Refer to the Cookie Policy for detailed information on the use of cookies and similar technologies.
(6) Billing Information Details of transactions conducted through the TTurkish Platform, such as ID, date, and time of the transaction, are processed.
(7) TTurkish Business To provide information about TTurkish Business Services, TTurkish may collect your name, email, company name, and phone number, as defined in TTurkish Business Terms.
(8) Sensitive Data TTurkish does not process sensitive data unless expressly agreed upon by the user.
(9) Pages on Social Networks TTurkish maintains official pages on social networks like Facebook, TikTok, Instagram, and LinkedIn. Interaction with these pages, such as subscribing or leaving comments, allows for analysis to measure efficiency and evaluate social media marketing campaigns.
(10) Tutors Community (for Tutors Only) A Tutors Community accessible through the website via Single-Sign-On (SSO) involves the collection and processing of interaction data and usage data for specified purposes.
(11) Tutors Academy (for Tutors Only) Tutors can access the Tutors Academy for various courses by registering. Activity data, comments, reviews, and survey results are collected and processed to optimize courses.
(12) Information Required for Submitting Tax Documentation To comply with tax and accounting legislation, TTurkish may process personal data for submitting various tax documents containing details such as full name, country of citizenship, address, date of birth, U.S. taxpayer identification number, or foreign tax identifying number.
(13) Information Required for Marketing and Promotion For promoting Tutoring Services, TTurkish may collect the tutor’s postal address to assist in reaching prospective students within a specific geographical area.
(14) Analysis of Speech Activity During lessons on the TTurkish Platform, microphone activity may be analyzed to measure sound volume. This feature, based on legitimate interest, does not record voice, words, or content of conversations. Users within the European Economic Area (EEA) or Switzerland can opt out of this feature.
Please note that the processing of personal data is carried out based on legal bases as outlined in the Privacy Policy.
(15) Language Assessment TTurkish processes personal data to assess language proficiency, which may include name, email address, and language assessment results. This assessment can occur before or after registration on the TTurkish Platform.
(16) Video Lessons, Sales Calls, Events, and Webinars TTurkish may process your likeness and interactions in videos during group classes, sales calls, webinars, or events. Recording will only happen with prior notice and consent if required.
(17) Information Processed by AI-Powered Tools Integration of AI-powered tools involves using text prompts and, with consent, lesson transcripts to provide personalized learning recommendations, generate lesson plans, offer grammar explanations, enhance vocabulary cards or messages, suggest exercises and homework, assess language proficiency, and enable chatbot functionality for vocabulary practice and grammar inquiries.
(18) Tutor Verification (for Tutors Only) Tutor facial biometrics and ID are processed for identity verification and fraud prevention through a third-party online verification provider.
4. Data We Collect: Purposes
(1) Provision of Services The primary purpose is to authorize access to TTurkish Services and fulfill obligations under the Terms of Service. Personal data is used for registration, scheduling lessons, tracking learning progress, and facilitating communication between users. Payment details are processed through third-party payment providers, and language assessment tests may be conducted.
(2) Payment Services Third-party payment providers are used to bill users securely through online account payments. Payment card transaction data may be used to confirm transactions and verify eligibility for promotional offers.
(3) Referral Programs TTurkish has "Tell-A-Friend" and B2B referral programs. Personalized referral links and shared colleague information are processed for these programs.
(4) Communications Contact may occur via email and other methods for Services-related purposes, user communication, and notifications. Users can adjust notification settings.
(5) User Research Contact data may be used for user research to enhance product features, marketing, customer support, and service updates.
(6) Marketing and Promotion of TTurkish First name, last name, and email may be processed for newsletters, commercial messages, and promotional information. Consent is sought, and users can opt out. Phone numbers may also be used for promotional contact. Postal addresses may be used for search engine marketing and optimization. Feedback provided by users may be used by TTurkish without additional compensation.
Please note that the processing of personal data is based on specified lawful bases as outlined in the Privacy Policy.
(7) Behavioral and Social Media Marketing TTurkish may share users' email addresses with Google and Meta for personalized advertising, behavioral, and social media marketing. This is conducted based on legitimate interests while considering user privacy.
(8) Identifying Influencers for Potential Collaborations Third-party services like Captiv8, Inc. and LiveRamp Holdings, Inc. may analyze user-provided information to identify influential students. A joint controllership over data may be formed. If collaboration is proposed, a privacy notice will be provided.
(9) Analytics and Development TTurkish monitors and analyzes personal data, including registration information, web traffic, cookies, and usage data, for analytics and development. Services like Google Analytics for Firebase, Hotjar, Amplitude Analytics, Branch.io, Braze, and Intercom are used. Research activities and occasional A/B tests may be conducted to enhance user experience.
(10) Tutor Verification and Program Preparation Tutor credentials are collected to verify eligibility, and biometric information and ID are processed for identity verification. Analytics are used to automate and improve tutor verification. The information is utilized to help tutors develop learning programs.
(11) Improvement of Tutors’ Ranking Algorithm Various metric-based data, including personal data from tutors and students, is gathered to enhance the tutors' ranking algorithm and improve user experience.
(12) Managing Tutors Community Email, interaction, and usage data of tutors in Tutors Community are processed for community building, moderation, statistics, and to enhance the tutor's user experience.
(13) Support and Platform Supervision Data, including communications, may be used to resolve disputes, supervise user behavior, and respond to complaints or requests related to TTurkish and its services.
(14) Events and Webinars Conducted by TTurkish Personal data collected during event or webinar registration is used to provide access, send confirmations, reminders, materials, or requested information about services.
(15) Competitions and Sweepstakes Information collected for competitions and sweepstakes is processed to organize and conduct events, verify eligibility, contact winners, and administer prizes. Winners' names may be posted on the website with consent.
(16) Compliance with Legal Requirements Certain payment information is processed to comply with financial and accounting legal requirements. Data collected on the TTurkish Platform may be processed to comply with legal requests and to exercise, defend, and establish legal rights.
(17) Fraud Prevention Log information, payment information, and user behavior are monitored to prevent fraudulent activities and assist users in managing their sessions.
(18) Changes TTurkish may update its Privacy Policy. Changes will not reduce users' rights unless explicit consent is provided, and users will be notified of substantial changes via email.
5. How Is Personal Data Shared? TTurkish shares personal data with individuals, independent contractors, and service providers under data processing agreements (DPA) or Standard Contractual Clauses (SCCs). Data is stored securely on AWS servers in Ireland, Germany, and the United States.
(1) Categories of Third-Party Service Providers
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Analytics Services: These providers process personal data, including information outlined in subsections 5 and 14 of section 3, to help TTurkish monitor and analyze user behavior and enhance the platform's features.
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Social Network Platforms and Search Engines: TTurkish engages with these providers to manage its social media presence and deliver personalized advertisements. The shared personal data aligns with subsection 7 of section 4 and subsection 2 of section 5, respecting user privacy and interests.
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Customer Communication Solutions: Third-party providers in this category handle personal data mentioned in subsection 4 of section 3. This ensures effective communication between TTurkish and its users, including essential notifications and updates.
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User Research Tools: For feedback gathering and internal improvement purposes, these tools process personal data in line with subsection 5 of section 4, contributing to the enhancement of the user experience.
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Services for Emails and Push Notifications: Providers managing email communication and push notifications process contact details and personal identifiers, facilitating effective communication with TTurkish users.
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SMS Providers for Mobile Marketing and Notifications: Similar to email services, SMS providers handle contact details and personal identifiers for mobile marketing and notifications.
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Payment Services Providers: Personal data, as described in subsection 6 of section 3, is processed by these providers to ensure secure and seamless financial transactions on the TTurkish platform.
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AI-Powered Service Providers: This category of providers processes personal data outlined in subsections 16 and 17 of section 3, utilizing AI tools to enhance user experience, provide personalized recommendations, and offer language proficiency assessments.
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Providers of Video Conferencing, Speech-to-Text, and Conversation Analytics Tools: Personal data mentioned in subsection 16 of section 3 is processed to support video lessons, sales calls, and events, ensuring user interactions are optimized without compromising privacy.
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Influencer Marketing Solution Providers: These providers assist TTurkish in identifying and engaging influencers by processing personal data such as names and identifiers, as described in subsections 1 and 2 of section 3.
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Language Assessment Tools: TTurkish employs third-party tools to assess users' language proficiency levels, processing personal data outlined in subsection 15 of section 3.
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Search Engine Optimization and Marketing Tools: Personal data, as described in subsection 13 of section 3, is shared with providers to optimize TTurkish's visibility and reach through search engine marketing.
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Services to Manage Tutors Academy: Personal data in subsection 11 of section 3 is processed by these providers to enhance the learning experience for tutors and optimize the Tutors Academy.
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Services to Manage Tutors Community: Providers in this category process personal data outlined in subsection 10 of section 3 and subsection 10 of section 4, fostering a sense of community among tutors and improving user experience.
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Online Verification Providers: For tutor verification purposes, facial biometrics and ID information are processed by these providers in line with subsection 18 of section 3.
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Tax and Accounting Compliance Software Providers: Providers in this category process personal data mentioned in subsection 12 of section 3 to ensure compliance with applicable tax and accounting legislation.
(2) Use of Social Network Platforms
TTurkish utilizes social network platforms such as Facebook, Instagram, LinkedIn, and TikTok to maintain its social media presence. Notably, LinkedIn acts as both a processor engaged by TTurkish and an independent controller, while TikTok and TTurkish independently process user data. Meta is a joint controller for Facebook and Instagram pages, ensuring a collaborative and privacy-respecting approach to data processing.
These platforms help TTurkish engage with its audience, share relevant content, and foster a sense of community. Additionally, service providers play a crucial role in ensuring the security of user data within the TTurkish social media ecosystem.
(3) Data Transfer in Case of Change of Control or Asset Disposition
In scenarios involving mergers, acquisitions, sales, or changes of control, TTurkish prioritizes user data confidentiality. Users are informed in advance of any potential data transfer or changes in privacy policies, upholding transparency and user trust.
(4) Companies Using TTurkish Business Services
TTurkish may share Authorized Users' language learning progress and language assessment results with their respective employers. This collaborative approach aims to provide employers with insights into the educational progress of their employees.
(5) TTurkish Independent Contractors
Independent contractors play a vital role in supporting TTurkish across various functions, including data analytics, software development, customer support, promotion, marketing, and user research. These contractors adhere to strict privacy obligations and access personal data on a need-to-know basis, ensuring the security and confidentiality of user information.
(6) Other Users of the TTurkish Platform
User data may become visible to other users within the TTurkish platform through personal contacts, group classes, or social features. Profile pictures and names may be displayed in these contexts, fostering transparency and community interaction.
6. How Long Will the Personal Data Be Processed and Stored by TTurkish?
TTurkish follows a comprehensive data retention policy:
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Personal data is stored as long as the user account is active. If there's no activity for over 2 years, the account is considered expired.
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In conflict situations, data may be retained longer to establish, exercise, or defend legal claims.
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Certain personal data may be retained longer to comply with legal, regulatory, tax, accounting, or other requirements.
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Data collected for newsletters is stored as long as the user is interested. Unsubscribing removes the data.
This approach reflects TTurkish's commitment to responsible data management, privacy, and compliance with applicable regulations.
(7) Your Rights as Data Subject Regarding Your Personal Data TTurkish Processes
Right of Confirmation: You can confirm whether TTurkish is processing personal data concerning you.
Right of Access: You have the right to access the personal data processed by TTurkish.
Right to Rectification: You can request corrections for incomplete personal data.
Right to Erasure (Right to Be Forgotten): You can request the erasure of personal data, except where legislation requires otherwise. Deletion options include contacting TTurkish via email, deleting specific items from your account settings, or deleting your entire account through the account settings page.
Right of Restriction of Processing: You can contest data accuracy or restrict processing when TTurkish is no longer interested in processing your data but there are other reasons to keep it.
Right to Data Portability: You can have your personal data transmitted directly from TTurkish to another controller where technically feasible, without adversely affecting the rights and freedoms of others.
Right to Object to Processing of Your Personal Data by TTurkish: You can object to the processing of your personal data for tasks carried out in the public interest, the exercise of official authority, or legitimate interests. TTurkish will cease processing unless compelling legitimate grounds are demonstrated.
Right to Withdraw Consent at any Time by Contacting Us: Upon receiving a withdrawal request, TTurkish will promptly process it, and personal data will no longer be processed unless required by law. These requests are free of charge.
In case of a perceived violation of your rights, you can lodge a complaint with the relevant data protection authority.
Note: When personal data processing is for direct marketing purposes, you have the right to object at any time without providing justification.
(8) Other Privacy Commitments
Cross-border Transfers: TTurkish processes personal data both within and outside the United States, maintaining high standards of data privacy and compliance across different jurisdictions.
Time for Reply and Reaction: TTurkish commits to providing information on action taken regarding rights requests within one month, with possible extensions under specific circumstances.
Security: Technical and organizational measures are implemented to ensure the security of information, protecting against unauthorized processing, accidental loss, destruction, or damage. Verified contractors with signed data processing agreements contribute to this effort.
Accessing Account to Provide Support: In exceptional circumstances requiring customer support, support specialists may access accounts with user permission. Users are encouraged to edit privacy settings to control information visibility.
Children’s Privacy: TTurkish Services are not intended for users under 18 without parental supervision. Users under 18 must have a parent or legal guardian set up an account.
Breach Notifications: TTurkish commits to informing users and data protection agencies of any personal data breach likely to result in a high risk of adversely affecting users' rights.
“DoNotTrack” Requests: TTurkish does not share personal data for third-party direct marketing and does not support “Do Not Track” requests.
(8) California Privacy Rights: California residents have specific rights under the California Consumer Privacy Act, including the Right to Know, Right to Correction, Right to Deletion, and Right to Opt-Out. TTurkish undertakes not to discriminate against users exercising these rights.
(9) Automated Decision-Making and Profiling: TTurkish engages in profiling using machine-learning algorithms to enhance the matching efficiency between tutors and students. Users can request human intervention or contest algorithmic decisions by contacting TTurkish.
(10) Sale of Personal Data: TTurkish does not sell personal data, including that of minors under 16 years of age.
9. Legal Matters
TTurkish may disclose personal data stored in its databases to:
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Comply with the law or legal processes.
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Enforce and investigate potential violations of this Privacy Policy.
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Investigate potential fraudulent activities.
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Protect the rights, property, or safety of TTurkish, its employees, customers, or the public.
TTurkish values your privacy and encourages questions. For inquiries, contact support@tturkish.com.
Your TTurkish Team