We Care about Your Privacy

We, Elaves Education and Technology Inc., operating the www.elaves.com ("Website") and the application installed on mobile devices ("Mobile Application") (hereinafter collectively referred to as the "Platform"), respect and value the protection of the data of Platform users/members/visitors ("Data Subject") and their privacy. The Company highly respects the privacy of its users and members and has made it a principle. Please take a few minutes to review this Privacy Policy to learn about the terms and conditions regarding the use of your personal data through the Platform.

Users and members, by accessing and using this Platform, will be deemed to have expressly accepted this Privacy Policy. This Privacy Policy is only applicable to the relevant Platform and does not apply to links directed through the Platform.

1. Processed Personal Data

When this Platform is visited, certain personal data must be obtained directly or indirectly for the provision of necessary services. Your personal data processed by the Company is categorized in accordance with the Personal Data Protection Law ("Law") as follows. Unless explicitly stated otherwise, the term "personal data" in the context of this Privacy Policy will include the following information:

• Identity and Contact Information: Name, surname, telephone, address, email address
• ser Information, User Transaction Information, and Financial Information: Membership information, membership ID number, data related to the time and date of using Company services, reasons for contacting the Company, terms used when searching on the Website, filtering preferences, your ratings and comments, invoice and payment information, balance information (examples of invoices sent to users and receipts for payments received from users, invoice number, invoice amount, invoice issuance date, etc.). When you use a credit card to pay the product price, you agree that your credit card number, expiration date of your credit card, CVV2 code, and similar information will be shared with banks. However, credit card and/or bank card information used during order creation is not stored in our systems in any way.
• Transaction Security Information: Membership information, password information
• Marketing Information: Reports and evaluations showing your habits and preferences, targeting information, cookie records, etc. Marketing and communication data include your preferences for receiving marketing materials
• from us and our third parties as well as your communication preferences
• Request/Complaint Management Information: Your requests and complaints made through the Website and Mobile Application and your comments shared on the Website and Mobile Application
• Risk Management Information: IP address
• Audio Recording Information: Your participation in online and physical events, your participation in user research, and your voice recording during interactions with the call center.
• Visual Recording Information: Your participation in online and physical events, your participation in user research, and your visual recording during interactions with the call center.
• Legal Transaction Information: Information in correspondence with authorized individuals, institutions, and organizations, information in lawsuit and execution files, information on legal information requests,
• To detect potential malicious software, our Android application component may access the full list of applications installed on the phone.
• In addition, we collect, use, and share aggregate data, such as statistical or demographic data, for any purpose. Aggregate data may be derived from your personal data, but it is not considered personal data as it will not directly or indirectly identify you as an individual. For example, we may use your usage data to calculate the percentage of users accessing a specific feature of a website or mobile application. However, if we combine this type of aggregate data with your personal data in such a way that it can directly or indirectly identify you, we treat the combined data as personal data and process it in accordance with this Privacy Policy. Except for authorized units of the Website, only users/members concerned with personal data can access and modify this data. It is not possible for other users/members and third parties to change this data given by the user/member.

2. Purposes of Using Your Personal Data

The personal data you share with the Company may be processed for the following purposes in compliance with the purposes stipulated in the Law and other relevant legislation:

For you to benefit from the services provided through the Platform, to carry out your membership registration, to update your membership registration, to improve the services provided by the Company and through the platform and to introduce new services, to conduct commercial activities, to determine and implement commercial, scientific and business strategies, to ensure the legal and commercial security of the persons, including those abroad, who have a business relationship with the Company, and to provide the necessary information to you in this context, and to fulfill the obligations arising from the nature of these activities.

The personal data may be used to communicate with you or to improve your experience on the Platform. These data may also be used for internal reporting and business development activities, to make various statistical evaluations without disclosing your identity, to create a database, and to conduct market research. The said information may be processed by the Company for direct marketing, digital marketing, remarketing, targeting, profiling, and analysis purposes, stored, transferred to third parties including those abroad, and you may be contacted for notifications regarding the promotion, maintenance, and support activities of various applications, products, and services through these channels.

In addition, the Company may process personal data without obtaining your additional consent in accordance with Articles 5 and 8 of the Law and/or the existence of exceptions in the relevant legislation, and may share it with third parties. These situations are as follows:

• When explicitly prescribed by laws,
• When necessary for the protection of life or bodily integrity of the person or someone else who is unable to express his/her consent due to actual impossibility or whose consent is not legally valid,
• Provided that it is directly related to the conclusion or performance of any contract between the Data Subject and the Company, when it is necessary for the processing of personal data,
• When necessary for the Company to fulfill its legal obligations,
• When it has been made public by the Data Subject,
• When it is necessary to establish, exercise, or protect a right,
• Provided that it does not violate the fundamental rights and freedoms of the Data Subject, when it is necessary for the legitimate interests of the Company.

3. Changing the Purpose of Data Usage

The Company will only use your personal data for the purposes for which it was collected unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

​4. Transfer of Personal Data

The Company may transfer your personal data and any new data obtained through the use of your personal data to Company employees, affiliates, subsidiaries, including those abroad, branches and branch employees, business partners or intermediaries with whom we may do business, auditors, lawyers, and consultants, among other professional advisors, for the purposes specified under this Privacy Policy. In this context, the Company may also transfer your personal data to legally authorized public institutions, including those based abroad, as well as private legal entities. Anonymous or limited data transfer may also be made to our business partners and suppliers, subject to separate approval in such cases. The Company may share your personal data with third-party service providers, including but not limited to external service providers such as email and SMS senders, hosting service providers, and law firms, to improve your user experience (including enhancement and personalization), ensure your security, detect fraudulent or unauthorized use, conduct operational assessments, address errors related to platform services, and achieve any of the purposes stated in this Privacy Policy. As a Data Subject, you acknowledge that the aforementioned third parties may store your personal data on servers anywhere in the world, and you hereby consent to this. The individuals and legal entities, including those abroad, with whom your personal data may be shared, are as follows:

• External third parties: service providers, bankers and financial market infrastructure institutions, marketplaces, official, regulatory or similar institutions or industry organizations, competent courts or judicial authorities, law enforcement agencies, certifying authorities, notaries, administrators, trustees or other executive authorities, liquidator in any bankruptcy, preventive measure situation, trustee, trustee, trustee or temporary manager, external manager, administrator or similar or equivalent appointed authority, bankruptcy, liquidation, dissolution, or similar or equivalent any transaction), third-party service providers such as IT system management or information security service providers.
• Third parties to whom we may sell, transfer, or merge part of our business or assets. Alternatively, we may attempt to acquire or merge with other businesses. In the event of a change in our business, new owners may use your personal data as described in this privacy policy.

We mandate that all third parties respect the security of your personal data and process them in compliance with the law. We do not permit our third-party service providers to utilize your personal data for their own purposes and only allow them to process your personal data for specific purposes and in accordance with our instructions.

5. Storage Period of Your Personal Data

Your personal data shared with the Company is retained for the duration required by the purposes specified in this Privacy Policy and for the statutory limitation periods stipulated in the relevant legislation. Additionally, your personal data may be retained, to a limited extent, for the purpose of providing necessary defenses in the event of any dispute between you and the Company.

6. Ensuring the Security of Your Personal Data

The Company takes appropriate technical and administrative measures, considering the costs, to ensure the minimum level of security required by the relevant legislation or as stipulated in this Privacy Policy, in order to:

• prevent unlawful processing of personal data,
• prevent unauthorized access to personal data, and
• safeguard the confidentiality of personal data.

Furthermore, the Company refrains from disclosing the personal data obtained from you to any third party in violation of this Privacy Policy and the provisions of the Personal Data Protection Law, and it does not use them for purposes other than the intended processing. In case of linking to other applications through the website, the Company disclaims any responsibility for the privacy policies and contents of such applications and recommends reviewing their respective texts.

The data pertaining to users and members are securely stored by our Website. However, these data may be used to establish communication with users/members via mail, email, telephone, and other technological communication channels.

The user/member pledges to ensure that the data covered by this Privacy Policy are complete, accurate, and up-to-date, and agrees to promptly update them via the Website in case of any changes. The Company shall not be held liable for any direct or indirect damages arising from the failure of the user/member to provide complete, accurate, and up-to-date information. The user/member hereby acknowledges, declares, and undertakes this commitment.

7.  Changes to the Privacy Policy

By utilizing the services offered through the platform, users are deemed to have read and accepted all these terms. The Company reserves the right to modify the provisions of the Privacy Policy without prior notice in line with changes in legislation. The current Privacy Policy becomes effective as of the date it is presented to the User through any means.