Personal Data Protection Law (KVKK) Disclosure Notice

1. Data Controller

This Disclosure Notice has been prepared by the data controller under Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”):

• Urcan Onur Kılınç Sole Proprietorship
• Brand: MatematikOfisi
• Website: https://www.matematikofisi.net
• Email: onur@matematikofisi.net

This notice informs users of the MatematikOfisi website, student portal, mobile applications, online lesson systems, and all related digital services about how their personal data is processed.

2. Personal Data Processed

Depending on the scope of the services used, the following personal data may be processed.

Identity Information

• First name
• Last name

Contact Information

• Phone number
• Email address

Student Information

• Education level
• School information (if provided)
• Exam being prepared for
• Lesson preferences
• Mathematics proficiency level
• Study history

User Account Information

• Username
• Membership information
• Password (encrypted)
• Account creation date
• Account activity

Lesson Information

• Purchased lessons
• Attendance information
• Attendance status
• Lesson audio and video recording (where a recording is taken)
• Lesson transcript (the recording rendered as text)
• Lesson summary and the lesson summary shown to the parent
• Preparation tasks for the next lesson
• Whiteboard content
• Lesson notes
• Teacher evaluations

AI Analysis Data

Within the scope of MatematikOfisi's AI-supported education services;

• Problems solved
• Correct/incorrect answer analyses
• Topic-based success rates
• Learning tendencies
• Gaps in learning outcomes
• Study habits
• Recommended study plans
• Progress reports
• Lesson summaries generated from the lesson transcript
• Lesson summaries shown to the parent
• Preparation suggestions for the next lesson

may be processed. These analyses are used solely to personalize the educational services.

Financial Information

• Order information
• Payment amount
• Invoice information

MatematikOfisi does not store credit card information. Your card details are processed securely solely by the payment institution.

Technical Data

• IP address
• Browser information
• Operating system
• Device information
• Log records
• Cookie records
• Session information
• Error records

3. Purposes of Processing Personal Data

Your personal data is processed for the following purposes.

• Creating membership
• Managing the user account
• Providing online education services
• Planning private lessons
• Operating the digital question bank
• Generating AI-supported analyses
• Recording lessons and summarising those recordings
• Preparing post-lesson feedback and parent updates
• Tracking student progress
• Preparing lesson schedules
• Operating the student portal
• Providing technical support
• Carrying out payment transactions
• Carrying out invoicing processes
• Increasing customer satisfaction
• Ensuring information security
• Fulfilling legal obligations
• Meeting requests from authorized institutions and organizations
• Fulfilling obligations arising from legislation

Where separate explicit consent is required, it is obtained in order to provide;

• Campaign notifications
• Marketing activities
• Commercial electronic messages
• Personalized offers

4. Legal Grounds for Processing Personal Data

Your personal data is processed based on the legal grounds set out in Article 5 of the KVKK, namely;

• Being expressly provided for by law
• Being necessary for the establishment or performance of a contract
• The data controller fulfilling a legal obligation
• The establishment, exercise, or protection of a right
• The data controller's legitimate interests

Where explicit consent is required, your data is processed solely in accordance with your explicit consent.

Recording lessons and generating AI lesson summaries from those recordings rely on explicit consent. Without explicit consent this processing does not take place at all; consent that has been given can be withdrawn at any time from the Settings page in the portal.

5. Method of Collecting Personal Data

Your personal data is collected electronically via;

• The MatematikOfisi website
• Mobile applications
• The student portal
• Online lesson systems
• Contact forms
• The live support system
• Email correspondence
• Phone calls
• Payment systems
• Cookies
• Automatic recording systems

6. Transfer of Personal Data

Your personal data may be shared, only to the extent necessary for the provision of the service, with the following parties:

• Payment institutions
• Banks
• E-invoice and accounting service providers
• Technical infrastructure providers
• Cloud service providers
• Hosting service providers
• Authorized public institutions and organizations
• Legally authorized authorities

MatematikOfisi's infrastructure may make use of secure cloud services offered by third-party technology providers. In this context, your personal data may be processed or stored on these service providers' systems for the purpose of providing the service.

7. Transfer of Data Abroad

Some of the technology services and cloud infrastructures used by MatematikOfisi may operate through servers located abroad.

For this reason, your personal data may be transferred abroad within the framework of the relevant provisions of the KVKK, with the necessary technical and administrative measures taken.

Where transfer abroad is required, it is carried out in accordance with the applicable legislation.

8. Retention of Personal Data

Your personal data is retained;

• For the period stipulated by the relevant legislation
• For as long as required by the purpose of processing
• Taking statute-of-limitations periods into account, so it may serve as evidence in possible legal disputes

Data whose retention period has ended is deleted, destroyed, or anonymized in accordance with the applicable legislation.

Specific retention periods apply to lesson recordings: the audio and video recording is deleted automatically 90 days after the lesson and the transcript 365 days after it. The lesson summaries and preparation tasks produced from them form part of the student's educational record and are not subject to those periods.

9. Data Security

MatematikOfisi takes appropriate measures to ensure the security of personal data, including;

• SSL/TLS encryption
• Access authorization
• Firewalls
• Regular backups
• Monitoring of log records
• Up-to-date security software
• Technical and administrative security measures

10. Your Rights Under the KVKK

Pursuant to Article 11 of the KVKK, you have the following rights.

• To learn whether your personal data is being processed
• To request information about it if it has been processed
• To learn the purpose of processing
• To learn whether it is used in accordance with that purpose
• To learn the third parties to whom it is transferred
• To request correction if it has been processed incompletely or incorrectly
• To request its deletion or destruction
• To request that any correction or deletion be notified to third parties
• To object to a result arising against you solely from analysis by automated systems
• To claim compensation for damage suffered due to unlawful processing

11. How to Apply

You may submit your requests under the KVKK;

• Email: onur@matematikofisi.net

or through other methods specified in the applicable legislation. Applications will be evaluated and concluded within the periods stipulated by the KVKK and the relevant legislation.

12. Updates

MatematikOfisi reserves the right to update this Disclosure Notice in line with applicable legislation, the services offered, or technological developments. The updated notice takes effect as of the date it is published on the website.