As Ayasis Yazılım ve Bilişim Teknolojileri Anonim Şirketi (the "Company"), we hereby present this Clarification Text on the Processing of Personal Data in order to fulfill our obligation to inform you within the scope of the Law No. 6698 on the Protection of Personal Data ("Law") and the Communiqué on the Principles and Procedures to be followed in the Fulfillment of the Obligation to Inform. The matters we are obliged to inform you on are as follows:
1. Identity of the Data Controller and Its Representative, if Any
The data controller is Ayasis Yazılım ve Bilişim Teknolojileri Anonim Şirketi , registered with the Istanbul Trade Registry under registration number 744964, with its registered address at Çifte Havuzlar Mahallesi Eski Londra Asfaltı Cad. Kuluçka Mrk. D2 Blok Apt. No: 151/1f/1b06 Esenler/İstanbul.
2. The Purpose of Processing Personal Data
Your personal data, including but not limited to your name, surname, email address, telephone number, educational background, audio recordings, performance data, reading/speaking/comprehension skills resulting from your use of the FeduAI application accessed through the website www.fedu.ai ("Fedu.AI"), account information transmitted when logging in via Google, Microsoft or other integrations, the date and time of access to FeduAI, the pages visited during your use, device information (device type, operating system, browser type, etc.), as well as any other data you transmit via FeduAI or generated as a result of its use, are processed for the purposes of creating a membership, verifying member information, carrying out membership procedures, providing you with the services, customizing and improving your user experience during access, offering personalized content and services, tailoring FeduAI to your preferences and needs, monitoring student member progress and contributing to their learning process, providing newsletters and surveys, informing you on updates or special offers related to the services, ensuring that proper consents are obtained from parents/legal guardians if the user is under 18 years, evaluating your communication request and contacting you accordingly, following up on your requests and complaints, fulfilling our legal obligations arising from consumer protection legislation, e-commerce legislation, commercial electronic message regulations and other applicable laws, fulfilling our obligations in the event of requests or notifications by authorized institutions or organizations, storing your personal data in accordance with legal retention periods, and conducting the Company's archiving and data retention activities.
During your visit to and use of FeduAI, certain personal data—such as information on the browser you use, your IP address, your internet connection, your interactions with the site, and similar data—are collected through small text files (Cookies) sent to your hard drive by the website server. These personal data are processed for the purposes of enabling access to our website and benefiting from its features, carrying information between pages on our site, eliminating the need to re-enter information, and—where you provide consent—collecting information on how you use our site in order to improve its performance, remembering your preferences on our site to provide you with convenience, and customizing our website and advertisements according to your interests and preferences. For more detailed information, you can review the Clarification Text on Cookies.
3. To Whom and for What Purpose the Processed Personal Data May Be Transferred
Your personal data may be transferred to (i) fulfill our legal obligations arising from consumer protection legislation, e-commerce legislation, commercial electronic message regulations and other relevant legislation, (ii) comply with requests from authorized institutions or fulfill notification obligations to such institutions, (iii) in case the member is a student, monitor their development within FeduAI. Accordingly, your data may be shared with (a) Teacher Users in the case of Student Users, (b) other Student Users through the FeduAI leaderboard, and (c) service providers from whom the Company receives support and authorized public institutions and organizations.
Additionally, your personal data specified in this Clarification Text may be transferred to companies located abroad providing infrastructure, cloud (server), and technical support services, limited to the purposes stated above and in accordance with the Law and the Regulation on the Procedures and Principles Regarding the Transfer of Personal Data Abroad.
4. Method and Legal Grounds for Collecting Personal Data
Your personal data, obtained through electronic channels such as the website, membership form, contact form or through physical means such as postal mail, are collected by fully or partially automated means and processed on the following legal grounds: (i) where necessary for the establishment or performance of a contract for services provided via FeduAI between the Company and the user; (ii) where necessary for the establishment, exercise, or protection of a right; (iii) where processing is necessary for the legitimate interests of the Company, provided that it does not violate the fundamental rights and freedoms of the data subject; (iv) your explicit consent.
5. Rights of the Data Subject Under the Law
As personal data subjects, you may submit your requests concerning your rights listed below to the Company through the methods set forth below. The Company shall respond to such requests free of charge as soon as possible and within thirty (30) days at the latest, depending on the nature of the request. However, if the process requires an additional cost, the Company may charge a fee in accordance with the tariff determined by the Personal Data Protection Board. Accordingly, personal data subjects have the right to:
• Learn whether his/her personal data has been processed;
• Request information if his/her personal data has been processed;
• Learn the purpose of processing his/her personal data and whether it has been used in accordance with its intended purpose;
• Know the third parties to whom his/her personal data has been transferred, whether domestically or abroad;
• Request the correction of his/her personal data if it has been processed incompletely or inaccurately;
• Request the deletion or destruction of his/her personal data if the reasons requiring its processing no longer exist;
• Request the correction, deletion, or destruction of his/her personal data be notified to third parties to whom the data has been transferred;
• Object to any result that is to his/her detriment arising from the analysis of processed data exclusively through automated systems; and
• Request compensation for damages in case s/he incurs harm due to the unlawful processing of their personal data.
Pursuant to Article 13(1) of the Law, you may submit your requests regarding the above rights in writing or through the methods determined by the Personal Data Protection Board. To exercise your rights, you may send your request, including the necessary identifying information and your explanation regarding the right you wish to exercise, by using your e-mail address that is previously registered with the Company to info@ayasis.com or to ayasisbilisim@hs01.kep.tr (registered electronic mail address – KEP).
For your information.
Ayasis Yazılım ve Bilişim Teknolojileri Anonim Şirketi