I. Introduction: Privacy Framework (Specific to California)

Education Teknoloji A.Ş. is dedicated to protecting your privacy. Our Privacy Policy explains how we handle data protection and provides details on the types of information we may collect and process when you use our mobile application, Unitools by Unifeedback Brand by Education Teknoloji A.Ş.

This document pertains to any data concerning identifiable individuals. Such data may include, but is not limited to, elements that allow for direct or indirect identification, such as unique identifiers or characteristics tied to an individual’s physical, mental, economic, cultural, or social identity.

This Privacy Policy is applicable to all users, defined as any individuals who interact with the Application.

In accordance with the Law on the Protection of Personal Data (KVKK) of Turkey, Education Teknoloji A.Ş. is designated as the data controller, except in specific cases where stated otherwise.

We strongly encourage you to thoroughly review this Privacy Policy. By using the Application, you acknowledge that you understand and agree to the practices outlined herein.

Important Information for Residents of Turkey

As a resident of Turkey, under the Law on the Protection of Personal Data (KVKK), you have specific rights concerning your personal information. You are entitled to:

Understand Categories and Processing Reasons: Request detailed information on the types of personal information we process and the reasons for these processes.

Learn about Sources: Inquire about the origins of your personal data.

Identify Usage Purposes: Understand the specific purposes for which we use your personal data.

Know Sharing Practices: Discover the third parties with whom your personal information may be shared.

Access Specific Information: Request access to particular pieces of personal information we hold about you, contingent on verifying your identity.

For easier navigation of our Privacy Policy, please refer to the "PERSONAL INFORMATION" section, which provides insights into the data we collect, its sources, and our processing practices.

Please note that under the KVKK, data that has been anonymized or aggregated is not regarded as personal information.

Your Choices: You have various options available concerning the processing of your personal data.

If you prefer not to have your personal information processed, please contact us using our contact form. Be aware that opting out may impact the functionality of the Application, and it may become necessary to remove it from your device.

To opt out of sharing your device identifiers and geolocation data with service providers, please check and adjust your device’s settings accordingly.

REQUESTS: To request access to, portability of, or deletion of your personal data, please use our contact form and include "Confidentiality Rights Request in Turkey" in your message. When submitting your request, ensure that you:

Provide enough information to verify either your identity or that of your authorized representative.

Clearly specify the details of your request to enable us to process it efficiently.

To ensure the security of your information, we may need to request additional details to verify your identity or authority. This process helps protect against unauthorized access and fraudulent requests.

We commit to using any information provided in your requests exclusively for verification purposes. We will retain this information only as long as necessary to complete the verification process.

Response Time: We aim to respond to all verified requests within one month of their receipt. Should there be a need for more time, we will notify you of the reason and the extension period.

Equal Rights: Exercising your data protection rights will not subject you to any discriminatory treatment from us. However, please be aware that deleting your data may impact the functionality or availability of certain services.

Sale of Data: Education Teknoloji A.Ş. does not sell your personal data to any third parties.

II. Data Handling Practices

To ensure that Unitools by Unifeedback Brand by Education Teknoloji A.Ş App functions properly and meets our contractual obligations, we collect specific types of information:

User-Provided Content: This includes all materials you contribute to the App, such as text entries, uploaded PDFs, and content created through AI tools. You retain control over this content in line with our Terms of Service. Please be aware that any use of this content is at your own risk and requires compliance with applicable laws. We work with specialized third parties such as OpenAI, L.L.C., and Anthropic, PBC for AI content generation, and utilize Microsoft Corporation and Google LLC for integrating search results via the "Ask the Web" feature. More details on third-party data practices are provided in Section IV.

Contact Information: When you contact us through our support channels, we collect your name, email address, and any other details you choose to provide. This information is securely stored and managed through Amazon Web Services, primarily to respond to your inquiries, fulfill service requests, and communicate necessary information.

Automatically Collected Data

With your explicit consent, Education Teknoloji A.Ş. employs advanced third-party technologies to process data for advertising and analytics purposes within our Application. These tools analyze various data transmitted by your device, such as advertising identifiers, and engage in profiling to discern attributes like your preferences, interests, behaviors, and location. For detailed information on these technologies, please see Section IV of this policy. Your consent activates these tracking functionalities, and should you wish to withdraw it, you can find guidance on how to do so in Section VIII.

Beyond the data collected with your consent, we also gather and analyze information related to your device and your interactions with our App based on our legitimate interests. This information primarily includes aggregated, non-personal data that cannot be linked to any individual by itself. We use this data to continually improve our App, ensuring it delivers the best possible user experience.

Detailed Information Collection
Through Unitools by Unifeedback Brand by Education Teknoloji A.Ş, Education Teknoloji A.Ş. collects a variety of device and user activity data to enhance functionality and user experience:

Device Information:

Device Specifics: We collect data on your device's make and model, operating system, screen specifications, audio settings, battery status, and performance metrics such as loading times and memory usage.

Connectivity Data: Information about your internet service, including mobile network, provider, connection type, IP address, session lengths, and browsing speed, is analyzed.

Geolocation Data: With your consent, we gather location data based on your IP address and device settings, aiding in delivering localized content and analyzing user distribution.

Additional Identifiers: We collect other unique identifiers set by the App's ecosystem to enhance personalized experiences and support analytics.

Application Analytics

App Usage Metrics: We collect specific information about our app, such as the name, version, and usage statistics. This data helps us understand how users engage with the app, allowing us to continuously refine and improve its features.
Cookies and Tracking Technologies

Web Technologies: We employ web technologies such as cookies, pixels, and scripts to collect data on your interactions with our App. This information is crucial for optimizing the App’s functionality, enhancing our marketing initiatives, and customizing content and features to better suit the preferences of our users.
Logs and Advertising Data

Interaction Logs: We log every access request to the App, recording details such as the times and manner of your interactions. This logging is instrumental in troubleshooting and enhancing the quality of our service.

Advertisement Interactions: We track data related to your interactions with advertisements in our App, including views, clicks, and conversions. This tracking helps us assess the effectiveness and relevance of the advertisements presented.

User Engagement

Activity within the App: We document various activities within the App, including tutorial completions, level advancements, transactions, and other significant in-app behaviors. This documentation helps us understand how users engage with the App and their preferences, aiding in further development and customization.
Data shared with external advertising and analytics platforms often extends beyond our capacity to directly oversee or manage. External entities involved may engage in profiling activities, deriving insights about personal characteristics or device details through mechanisms not controlled by us. Furthermore, if your Unitools by Unifeedback Brand by Education Teknoloji A.Ş user ID interacts with social media platforms like Facebook, such platforms might link your device data with their existing demographic profiles.

We do not supervise or endorse the handling of your data by these external parties, as it is collected independently of our App. If you need more information or have concerns about how these entities manage your data, we recommend contacting them directly. Please see Section IV for additional details.

Payment Data Management

All transaction processing within our App, including billing and payment for in-app purchases, is securely handled by our designated e-commerce partner, Apple. This partnership guarantees that your payment details are managed with the highest level of security, which is essential for fulfilling our contractual obligations. Education Teknoloji A.Ş. does not directly access or handle your payment card details.

For detailed information on in-app transactions, including conditions and policies related to purchases, we recommend reviewing the terms provided within the respective app stores.

III. Objectives for Processing Personal Data

At Education Teknoloji A.Ş., we are committed to continually enhancing our App and enriching your experience through various uses of your data:

(a) Service Facilitation: We use essential and automatically gathered data to seamlessly deliver the services you request.

(b) Optimization and Maintenance: We analyze collected data to improve App performance, resolve technical issues, and upgrade functionality.

(c) Personalized Advertising and Content: We utilize your data to tailor marketing efforts and content to your interests, making the ads and information you see more relevant.

(d) User Engagement: Your contact details allow us to reach out with newsletters, marketing communications, feedback requests, policy updates, and provide support as needed.

(e) Security and Trust: Your data is crucial in maintaining a secure, spam-free, and reliable App environment, helping us prevent, detect, and address fraud, security breaches, and any activities contravening our policies or laws.

Education Teknoloji A.Ş. is dedicated to transparency and pledges to notify you prior to initiating any new data processing activities. Should there be new reasons for processing your personal data, we will update you beforehand and make the necessary modifications to this Privacy Policy.

IV. Disclosure and Sharing of Your Information

Education Teknoloji A.Ş. is dedicated to protecting your privacy and will only share your information as detailed in this Privacy Policy, ensuring full compliance with Turkey’s data protection regulations.

Education Teknoloji A.Ş. works with third-party services to improve our App's functionality, selecting partners who adhere to stringent data protection standards. Despite our rigorous criteria and efforts, we cannot fully secure the transfer of information to these third parties. Therefore, Education Teknoloji A.Ş. cannot be held liable for any data breaches or unauthorized access to your personal data that occur beyond our direct control.

Education Teknoloji A.Ş. does not sell or rent out your personal data. However, we may share data collected via cookies, log files, device identifiers, and location data with external organizations to facilitate automatic data processing for our App. The management and utilization of these tracking technologies by third parties are outside our control.

Education Teknoloji A.Ş. may work with third-party advertising partners, sharing data like cookie information to facilitate targeted advertising. This targeted advertising is designed to align with your preferences, providing you with ads that are likely to be of interest.

Education Teknoloji A.Ş. may disclose your personal information in situations deemed critical for public interest or under exigent circumstances, such as:

Compliance with legal requirements:

Ensuring the safety, security, and rights of Education Teknoloji A.Ş., our users, or the public, including actions like fraud prevention and responding to government requests.

Furthermore, in the event of significant business transitions like a merger, acquisition, or asset sale, we will provide a clear notice within our App detailing the change in ownership, how your personal data will be processed moving forward, and the choices available to you regarding your information.

V. Cross-Border Data Processing

Education Teknoloji A.Ş. operates on a global scale, providing our App to users internationally. Due to our worldwide operations, the transfer of data, including personal data, across international borders is necessary. This data is processed both by us and by our third-party service providers and advertising partners engaged in such activities.

For users in the European Union or other regions where data protection laws differ from those in the United States, please be aware that your data may be transferred to countries or jurisdictions with different data protection standards. It is important to understand that these standards may not be equivalent to those in your home country.

When transferring your personal information across international borders, it might be processed in regions where data privacy and security regulations may not provide the same level of protection as in your home country. Education Teknoloji A.Ş. is committed to ensuring that all recipients of your data abroad uphold an adequate level of data protection that aligns with applicable data protection laws.

Education Teknoloji A.Ş. stores data using reputable hosting providers, prioritizing your privacy by encrypting personal data whenever feasible before transmission. We ensure that our hosting service partners meet strict standards for security and reliability.

VI. Retention of Your Personal Data

Education Teknoloji A.Ş. commits to managing your personal information with utmost legality and care, retaining it only as long as needed to effectively deliver our App's services and meet our legal responsibilities. If you decide that you no longer want us to hold or use your data, you have the right to request the deletion of your personal information and to terminate your account with us.

Please be aware that even after you request the deletion of your personal data, certain categories may still be retained for a period necessary to fulfill specific purposes. This retention is limited to what is required and is primarily to comply with legal obligations such as taxation, accounting, and auditing requirements. It also supports system security, data recovery efforts, prevention of fraudulent activities, and protection against other potential threats.

VII. Your Data Protection Rights

Under Turkish data protection laws (KVKK), you have specific rights regarding the personal data we hold:

Access to Your Data: You can request copies of the personal information we maintain about you.

Updating Your Information: If you are unable to modify your information directly through your account, you can request that we make corrections, modifications, or updates.

Deletion of Your Data: You may request the deletion of your personal data under certain conditions, typically while your account is active or as needed for service delivery.

Restriction on Data Use: You have the option to restrict how we use your personal data in certain situations.

Insight into Data Sharing: You are entitled to detailed information about the sharing of your data with third parties, as outlined in Section IV of our Privacy Policy. For further inquiries about data sharing, please contact us directly.

Filing a Complaint: If you believe the processing of your personal data breaches the KVKK, you can lodge a complaint with the Turkish Data Protection Authority (Kişisel Verileri Koruma Kurumu, KVKK).

To exercise your data protection rights, please use our contact form. Note that these rights are applicable only to data that Education Teknoloji A.Ş. directly accesses and manages.

If you wish to object to automated data processing, particularly for direct marketing purposes, you are encouraged to reach out directly to the third-party services detailed in Section IV of our Privacy Policy. Many of these services offer comprehensive guidance on their privacy practices and provide mechanisms allowing you to directly object to such processing on their platforms.

VIII. Managing Your Preferences

Opting Out of Marketing and Tracking:

You can control your data tracking preferences, including opting out of targeted advertising, by adjusting settings on your iOS device:

To manage app-specific tracking permissions, go to Settings > Privacy & Security > Tracking and toggle the permissions for each app.

To opt out of app-based tracking activities, disable the “Allow Apps to Request to Track” option, which prevents apps from accessing your device’s Advertising Identifier.

To turn off Apple’s personalized advertising, switch off “Personalized Ads” found under Settings > Privacy & Security > Apple Advertising.

For more detailed instructions and assistance, visit Apple's support page.

For broader opt-out choices across various advertising platforms, you can visit the "Your Ad Choices" website. This resource provides comprehensive options for managing your advertising preferences on multiple platforms.

Opting Out of Targeted Advertising:

For comprehensive opt-out options across various platforms, consider visiting "Your Ad Choices." It's important to understand that opting out of interest-based advertising does not remove all advertisements; you will still encounter contextual ads. These ads are not tailored based on personal data but are related to the content of the digital products you use.

Opting Out of Location Data Use:

To restrict third-party service providers from accessing your precise location data on iOS devices (iOS 11 or later), follow these steps:

Open Settings > Privacy > Location Services.

Select the app for which you want to limit location access and choose “Never” for the “Share My Location” option.

For more detailed guidance, visit Apple's support site.

By adjusting the settings as described, you can effectively manage the use and sharing of your information, ensuring it aligns with your privacy preferences.

IX. Data Security Commitment

At Education Teknoloji A.Ş., protecting your personal data is a top priority. We follow recognized industry practices to secure the personal data you provide, both during its transmission and once it is under our control. Our security measures are designed to prevent data loss, unauthorized access, disclosure, alteration, and destruction, taking into account the inherent risks of processing and the sensitivity of the personal data we handle.

Education Teknoloji A.Ş. implements rigorous technical and organizational safeguards that are specifically tailored to uphold essential data protection principles. These include minimizing the amount of data we collect and embedding necessary protections directly into our data processing activities. Furthermore, we strive to ensure your data is secured using robust encryption techniques, and we apply hashing whenever feasible.

While Education Teknoloji A.Ş. is committed to protecting your personal information, it's important to recognize that no digital transmission or storage system is entirely secure. We cannot guarantee absolute security, but we are dedicated to applying the strongest possible safeguards. If a security breach occurs that affects your data, we will inform you promptly and in compliance with applicable laws.

If you have questions about the security measures in place for our App, please contact us using the provided contact form.

X. Protecting Children's Privacy

Our application is designed for individuals over eighteen years old. We do not knowingly collect personal data from those below this age limit. Minors aged thirteen to eighteen may use the app only with parental consent and oversight. We expressly forbid users under thirteen from submitting personal information. Should we find that we have inadvertently collected data from a minor under eighteen without proper parental consent, we will immediately remove such data. If you believe we possess information from or about a minor under this age without consent, please contact us without delay.

XI. Policy Updates

We frequently update our Privacy Policy to align with changes in our operations. Any modifications will be published on this page and other relevant locations. We will also issue notifications for any major changes as needed.

XII. Getting in Touch

Please direct any questions or comments about our Privacy Policy through our provided support form.

On this page

I. Introduction II. Data Handling Practices III. Objectives for Processing Personal Data IV. Disclosure and Sharing of Your Information V. Cross-Border Data Processing VI. Retention of Your Personal Data VII. Your Data Protection Rights VIII. Managing Your Preferences IX. Data Security Commitment X. Protecting Children's Privacy XI. Policy Updates XII. Getting in Touch