Mindbuddy Privacy Policy

Important Notice: This article is originally written in Turkish Language, according to the Turkish Law. See Original.

SUMMARY OF OUR POLICY

  1. WHO ARE WE?
    We, as Akide Teknoloji Yazılım ve Ticaret Limited Şirketi, process your personal data. This means we are responsible for how your data is processed and protected.
  2. WHAT IS YOUR DATA USED FOR?
    The data collected from you online and in person is used to manage your registration as a user, handle your product and service purchases, answer your inquiries, and provide personalized communication services if you wish.
  3. WHY DO WE USE YOUR DATA?
    We have legal grounds for processing your data for different reasons. The main reason for using your data is to fulfill the contract you accepted when registering, making a purchase, or using any of our services or functions. Additionally, your data is used for other reasons such as responding to your inquiries and sending newsletters you requested.
  4. WHO IS YOUR DATA SHARED WITH?
    Your data is shared with service providers who support and assist us.
  5. YOUR RIGHTS.
    You have the right to access, correct, or delete your personal data. In some cases, you also have other rights, such as objecting to the use of your data or transferring your data as detailed below.

BEFORE WE START…

  • You will find all relevant information about our use of personal data of users and customers, regardless of the method used to interact with us (online or in person), in the Privacy and Cookie Policy.
  • If you want to know more about cookies or similar devices that can be installed on your devices, we recommend checking our Cookie Policy.
  • We operate with transparency to help you understand what we do with your personal data, the implications of how your data is used, and your rights regarding your data. We provide permanent access to all information in this Privacy and Cookie Policy for you to consult whenever you need. Additionally, as you interact with us, you will find more information on how we use your data.
  • Some terms regularly used in this Privacy and Cookie Policy: When we refer to our Platform, we mean any digital or in-person channel or tool you may use to interact with us. Our main platform is our website.

1. WHO IS RESPONSIBLE FOR YOUR DATA?

The data controller responsible for processing and protecting your personal data is Akide Teknoloji Yazılım ve Ticaret Limited Şirketi (“Mindbuddy” or “Company”):

  • Postal address: Büyükdere Mah. Çayırbaşı Cad. No: 58 İç Kapı No: 1 Sarıyer / Istanbul
  • Data Protection Officer’s email address: info@akidetech.com

2. WHY DO WE PROCESS YOUR PERSONAL DATA?

Depending on how you interact with our Platform, we may need to process certain data as described below. These purposes generally vary depending on the situation but include:

  • Identification data (e.g., your name, surname, image, language, country of contact, contact details, etc.);
  • Transaction data (e.g., course usage history, preferred instructor details, etc.);
  • Connection, location, and/or navigation data (e.g., location data, device ID, or advertising ID, etc.);
  • Advertising data (e.g., subscription to our newsletter);
  • Information about your preferences and interests.

When we ask you to provide personal data to access any feature or service on the Platform, certain fields will be marked as mandatory because they are necessary to provide the service or give you access to the feature in question. If you do not provide these data, you may not be able to complete your user registration or benefit from these services or features.

In some cases, a third party may provide us with information about you when using a feature or service on the Platform. For example, they may send you a gift card or ship an order to your address. In these cases, your data will only be processed as described in this Privacy and Cookie Policy and only in relation to the specific feature or service.

In other instances, we may passively collect information about you using navigation cookies or other similar technologies tracking tools in our Platform and communications.

Depending on how you interact with our Platform, for example, based on the services you use, your personal data will be processed for the following purposes:

PURPOSEINFORMATION
1. To manage your registration as a Platform userIf you decide to register as a user on our Platform, we need to process your data to identify you as a user and grant you access to different functions and services available to you as a registered user. You can cancel your registered user account by accessing the “Edit Profile” section and clicking on the “Delete Account” button on our Mobile Application.
2. For the development, implementation, and execution of the service contractThis purpose includes: <ul><li>Contacting you for updates or informational notices related to the contracted functions and services, including determining customer satisfaction with the provided service.</li><li>Activating necessary mechanisms to prevent and detect unauthorized uses of the Platform, such as potential fraudulent activities. If we believe the transaction may be a fraudulent action or detect abnormal behavior indicating fraudulent use of our features or services, the transaction may be blocked, or your user account may be deleted.</li><li>Managing service availability information requests and reservations through the Platform.</li></ul>
3. To fulfill requests or applications you make through Customer ServiceWe will only process the personal data necessary to manage or resolve your request or application. If you contact us via email, our conversations may be recorded to ensure service quality and address your requests.
4. For marketing purposesThis purpose includes processing your data mainly for: <ul><li>Personalizing the services we offer and providing you with recommendations based on your interactions with the Platform.</li><li>If you are a social media user, sharing certain information with the companies we collaborate with so they can show you advertisements of our brand and offer you personalized ads based on your profile and interests. We recommend reviewing the privacy policies of the social media sites where you have an account to understand how your data is used and how social media advertising works.</li><li>Combining your personal data collected from various sources to better understand your needs and preferences regarding our services, including analysis, user profiling, quality research, and improving our interactions with customers.</li><li>With your explicit authorization, publicly sharing photos or images you have posted on our social media channels or Platform.</li></ul>
5. To improve our services through usability and quality analysisIf you access our Platform, we inform you that we will process your navigation data for analytical and statistical purposes to understand how users interact with our Platform and improve our services.

3. LEGAL BASIS FOR PROCESSING YOUR DATA

The legal basis allowing us to process your personal data depends on the purpose for which the data is processed, as outlined in the table below:

PURPOSELEGAL BASIS
1. To manage your Platform user registrationWe process your data because it is necessary for the performance of the contract regulating the use of the Platform. In other words, to register as a user on the Platform, we need to process your personal data; otherwise, we cannot manage your registration. <br><br>We consider it in our legitimate interest to link data related to your activities and services used on the Platform through different channels to your account.
2. For the development, implementation, and execution of the service contractWe process your data because it is necessary to execute the service contract with you. <br><br>Processing certain data related to the service you receive from us only takes place upon your request or authorization.
3. For marketing purposesWe have the legal right to process your data for marketing purposes based on the consent you provide us. Examples include accepting personalized information through different channels, consenting to cookies, participating in a promotional activity, or accepting legal terms and conditions to have your images published on our Platform or social media channels. <br><br>We consider it our legitimate interest to create a profile with the information we have about you (such as browsing data, preferences, and purchase history) and the personal data you provide us (such as age range or language) to offer personalized services or show you personalized information on our Platform or third-party platforms. We believe processing this data benefits you by improving your user experience and providing access to information based on your preferences.
4. For usability and quality analysisWe consider it our legitimate interest to analyze the usability and satisfaction levels of users on the Platform for the purpose of improving user experience and providing higher quality services.

4. HOW LONG DO WE KEEP YOUR DATA?

The duration for which we retain your data depends on the purpose for which it is processed, as outlined below:

PURPOSEDATA RETENTION PERIOD
1. To manage your Platform user registrationWe will process your data as long as you remain a registered user (i.e., until you decide to cancel your registration).
2. For the development, implementation, and execution of the service contractWe will process your data for the duration necessary to manage your service usage, including any complaints or claims related to the mentioned services.
3. For marketing purposesWe will process your data until you cancel your registration. Likewise, we will show you personalized advertisements until you change your device, browser, and/or cookie settings to withdraw this permission. If you participate in promotional activities, we will retain your data for six (6) months following the end of the activity.
4. For usability and quality analysisWe will process your data from time to time while conducting specific quality activities or surveys, or until we anonymize your navigation data.

While your data will be processed for the time necessary to achieve the stated purpose, it will be retained and protected as required by applicable laws to meet any resulting obligations from processing the data. Once the period for potential activities expires, personal data will be deleted.


5. SHARING YOUR DATA WITH THIRD PARTIES

Information Regarding Mindbuddy AI Services: We may provide the Mindbuddy AI service via OpenAI, our service provider located abroad (OpenAI Inc., 3180 18th St, San Francisco, California, USA; privacy statement: https://openai.com/api-data-privacy). OpenAI servers are located in the United States. Your conversations are limitedly transferred to OpenAI based on your explicit consent and stripped of personal data to provide you with the Mindbuddy AI service. However, since we cannot intervene in the content of your conversations, any information you provide during your interactions with Mindbuddy AI may be transferred to OpenAI.
To achieve the purposes stated in the Privacy and Cookie Policy and support our services, we may need to provide access to your personal data to third parties and organizations that support us. Examples include:

  • financial institutions,
  • fraud detection and prevention organizations,
  • technology and analytics service providers,
  • marketing and advertising service providers and partners, such as advertising agencies, advertising partners, or social media, which may sometimes act as joint data controllers.

For service efficiency purposes, some of these suppliers are located outside the European Economic Area and do not offer a level of data protection comparable to that of the European Union. In such cases, we ensure adequate measures to protect your data by using the most appropriate international data transfer tools and any applicable additional measures, such as Standard Contractual Clauses (SCC). You can view the content of these Standard Contractual Clauses here: https://commission.europa.eu/publications/standard-contractual-clauses-international-transfers_en.

If we sell or transfer part or all of our business or assets to another company, or in case of corporate reorganizations resulting in another business operation, your personal data may be disclosed to the prospective buyers of such business or assets. In such a sale or transfer, we will use reasonable efforts to direct the receiving party to use your personal information in a manner consistent with this Privacy and Cookie Policy. We believe we have a legitimate interest resulting from the reorganization of our corporate structure.


6. YOUR RIGHTS WHEN PROVIDING US WITH YOUR DATA

We are committed to keeping your personal data confidential and ensuring that you can exercise your rights. You can exercise your rights by sending us an email at info@akidetech.com, indicating the reason for your request and the right you wish to exercise. We may ask you for a copy of a document identifying you if necessary.

We also provide you with the opportunity to set your privacy preferences while accessing certain channels on our Platform or using some of our services. Regardless of the purpose or legal basis for which we process your data, you have the following rights:

  • Request access to the personal data we hold about you. If you are a registered user of the Platform, you can view this information in the relevant section of your online account.
  • Request correction of your personal data. If you are a registered user of the Platform, you can also access the relevant section of personal data in your online account to modify or update your personal data. In any case, remember that you guarantee the accuracy and completeness of any personal data you provide to us through any means and agree to notify us of any changes or modifications. You will be responsible for any loss or damage caused by the provision of any incorrect, inaccurate, or incomplete information in the registration forms to the Platform, the Platform’s responsible person, or third parties. As a general rule, remember that you should only provide us with your own personal data and not those of third parties, except as permitted by this Privacy and Cookie Policy.
  • Request deletion of your personal data where such data is no longer necessary for the purposes for which it was processed or where we are no longer legally authorized to process it.
  • Request cancellation or restriction of the processing of your personal data. This includes temporary suspension of processing or retaining data longer than necessary in certain cases.

You also have the right to withdraw your consent at any time if you have given us permission to process your data for any reason. Section 2 explains the purposes for which we process your data and provides detailed information on circumstances where you can withdraw your consent.

If you do not want us to send your information to third parties for advertising purposes, you can do so in several ways. You can change your device preferences, browser, and/or cookie settings, review the privacy policies and settings of social media sites where you have a profile, or send an email to the address mentioned above with your request.

As explained in Section 3, you also have the right to request the transfer of your personal data if we are legally authorized to process your data based on your consent or for contractual purposes. This right allows you to receive your personal data in a structured, commonly used, and machine-readable format and transfer it to another entity without hindrance from us.

You also have the right to object to the processing of your data if it is based on our legitimate interest.

Finally, if we do not resolve your request within the shortest possible time and no later than thirty days, you have the right to file a complaint with the Personal Data Protection Authority.


7. IF YOU PROVIDE US WITH THIRD-PARTY DATA OR IF A THIRD PARTY PROVIDES US WITH YOUR DATA

In certain situations where we offer features or services requiring you to provide third-party personal data (e.g., authorizing a third party to receive your order), or where a third party provides us with your data, such data will always be used within the scope of the specific feature or service and according to the purposes outlined in this Privacy and Cookie Policy.

If a third party provides us with your data, or if you provide us with such data in response to a feature or service requested by one of our users, such data will be used solely for managing the specific feature or service and within the scope of the purposes listed in this Privacy and Cookie Policy, to which you have access through all our communications.


8. CHANGES TO THE PRIVACY POLICY

The content of this Privacy and Cookie Policy may be amended as deemed appropriate. In such cases, you will be informed through different channels on the Platform or, if the changes significantly affect your privacy, a notification will be sent to your email address to review, evaluate, and possibly contest the changes or terminate your subscription if necessary.


9. INFORMATION ABOUT COOKIES

We use cookies and similar devices to facilitate your navigation on the Platform, understand how you interact with us, and, in some cases, show you advertising based on your browsing habits. Please read our Cookie Policy to understand more about the cookies and similar devices we use, their purposes, how you can manage your preferences, and other information of interest.


COOKIE POLICY

Akide Teknoloji Yazılım ve Ticaret Limited Şirketi (“Mindbuddy” or “Company”) may use cookies on our website https://www.mindbuddy.io/ (“Website”) within the scope of our online activities. This Cookie Policy explains which types of cookies we use, their purposes, how we manage them, and how you can perform actions against cookies.

The Cookie Policy contains information about the use of cookies and similar devices installed on users’ connection units. In some cases, the use of cookies may involve the processing of personal data, so we recommend reviewing our Privacy Policy available on our website to understand how your personal data is used, your rights, and the terms we refer to on this platform.

You can change or withdraw your consent at any time in the Cookie Declaration on our website by adjusting your browser settings.


1. WHAT ARE COOKIES?

Cookies are text files, generally consisting of letters and numbers, stored on your computer, tablet, smartphone, or other similar devices via browsers by the websites you visit. Cookies are created by servers managing the visited website and do not contain personal data such as names, genders, or addresses of visitors. When a connection is established between your browser and the server, the site recognizes you through cookies. This allows the website to determine the content to be delivered to you. Cookies are necessary and important as they make the site more user-friendly and facilitate web usage. Cookies are also used for purposes such as displaying advertisements according to user preferences and other detailed purposes mentioned below. Cookies do not harm your computer or device.


2. PURPOSES OF USING COOKIES

The main purposes of using cookies on the website are:

  • Enhancing the functionality and performance of the website to improve the services offered to you,
  • Collecting statistical data about how the website is used, which helps improve the content and operation of the website,
  • Determining how you use the website, including the content you view and the duration of your visit, and personalizing your future usage,
  • Ensuring the legal and commercial security of the website, you, and our Company.

3. TYPES OF COOKIES

Cookies are classified according to their purposes, storage durations, and sources.

According to their sources:

  • First-Party Cookies: Cookies created by the visited website.
  • Third-Party Cookies: Cookies created by other sites, partners, or service providers due to the presence of plugins from other sites on the visited website.

According to their purposes:

  • Essential (Technical) Cookies: Cookies necessary for the proper functioning of the website. These cookies cannot be used for marketing purposes, and some parts of the website will not function if they are blocked by the visitor.
  • Functional (Personalization) Cookies: Cookies that personalize the website content for visitors and remember their preferences. Visitors can block these cookies at any time. However, rejecting these cookies may slow down the website or result in less personalized recommendations.
  • Performance (Analytical) Cookies: Cookies that help improve the website by analyzing user behaviors and providing statistical measurements, including information on how the website is used and for how long.
  • Marketing (Behavioral Advertising) Cookies: Cookies stored to display appropriate content and behavioral advertisements based on visitors’ interests. It is possible to block the use of these cookies.

According to their storage durations:

  • Session Cookies: Cookies that recognize visitors’ actions during their use of the internet browser and are not stored on the device when the browser is closed.
  • Persistent Cookies: Cookies used to remember visitors’ preferences and stored until they are automatically deleted on a specific date or after a certain period or until the visitor deletes them. Visitors can delete these cookies at any time.

4. COOKIE MANAGEMENT

You can change your cookie preferences at any time by clicking on the icon on our website. You can configure the buttons in the cookie management panel according to your preferences by setting them to open or close.

In addition, you can delete cookies via browser settings or view the list and values of cookies stored in your browser. Information on cookie management in popular browsers can be accessed through the following links:

Besides the above options, you can learn more about all cookies and manage them by visiting: All About Cookies or Your Online Choices or using the “Privacy Badger” application (Privacy Badger).

For cookie or SDK management in mobile applications, you can follow the instructions in the Privacy or Settings section of your device or use the Lumen Privacy Monitor (Lumen Privacy Monitor) application on your phone.

If you completely remove cookies using your browser settings, you will also block some cookies necessary for the proper functioning of the website. This may cause the site or parts of it to malfunction. Therefore, we recommend updating your cookie preferences using the website instead of browser settings.


5. YOUR RIGHTS REGARDING PERSONAL DATA PROCESSED THROUGH COOKIES

To exercise your rights regarding personal data obtained and processed through cookies as listed in Article 11 of KVKK, you can send your request to:

  • info@akidetech.com using the email address registered in our systems,
  • or by sending it in writing, including identity verification documents, to “Büyükdere Mah. Çayırbaşı Cad. No: 58 İç Kapı No: 1 Sarıyer / Istanbul.”

Mindbuddy will conclude your application requests according to Article 13 of KVKK within the shortest time possible and no later than 30 (thirty) days, depending on the nature of your request. If the transaction requires a cost, the tariff determined by the Personal Data Protection Board will be applied. If your request is rejected, the reason(s) for rejection will be communicated to you within 30 (thirty) days at the latest.


CONTACT US

This Policy may be updated to comply with changes in cookie usage on the website or legal regulations. Changes to the Policy will be communicated to our visitors through the website.

For any questions or comments about the Policy, please visit our website: https://www.mindbuddy.io/.


Last Updated: 18.05.2024