Privacy Policy

Massa, risus vestibulum malesuada tellus.

Urna convallis gravida mauris in eget. Pretium etiam molestie et, purus arcu at turpis tempor rhoncus. Lectus turpis tristique vitae auctor massa dictum eu lectus. Pellentesque risus volutpat placerat ipsum ac quam justo. Vitae nullam habitasse id massa id at ultrices. Purus vel in vestibulum, diam ac. Tincidunt velit euismod elit, in aliquet faucibus. Sed nunc duis viverra facilisis posuere cum. Elit a, leo interdum facilisi purus. Nibh quisque sed aenean elit mauris iaculis. Amet faucibus sit nullam id elementum, quisque consequat. Tellus tempor suspendisse a lacus, suscipit in ac. Fermentum dui imperdiet sed fermentum lectus velit. Cursus iaculis magna quis porttitor cras lorem amet.

Static and dynamic content editing

Sit enim dictum non, sapien urna, ultrices eget. Eget velit at porta dolor placerat malesuada mauris. Tortor adipiscing diam ipsum condimentum amet, in risus nunc purus. Id scelerisque consectetur pulvinar gravida adipiscing.Venenatis nec euismod bibendum nunc lacinia sed pretium volutpat lectus. Mattis placerat vel elementum tellus viverra vitae.

“Est ullamcorper sit magna odio tincidunt posuere nunc. Sed sed faucibus morbi at id. Lacus duis tellus rutrum feugiat duis.”

In tincidunt nulla ante augue eu leo non molestie. Malesuada elementum cras orci diam gravida sed. Sed feugiat elementum elit tortor, odio vel, est dui scelerisque. Porttitor nibh posuere venenatis viverra. At id dolor tortor mauris. Dignissim morbi sed justo integer pellentesque. Fringilla velit, risus venenatis sit tristique volutpat. Pretium pretium, lectus egestas mi nulla fringilla elit eu. Etiam nisi, in suscipit sapien, consectetur proin tincidunt commodo. Cursus ornare id nisl, quam ultrices.

Nullam bibendum at diam amet varius nulla.

Fusce natoque nisl rhoncus tortor in egestas ultricies feugiat habitant. Iaculis gravida volutpat, sed aliquam, commodo platea id odio. Porttitor dui arcu viverra mattis libero augue sit erat. Phasellus viverra habitasse consequat amet facilisis placerat amet, ipsum. Id adipiscing a, in tellus pretium mi donec sit eu. Auctor viverra vestibulum in malesuada non est dictum.

Welcome to Tutoray’s website.

As Tutoray, we always respect and uphold the privacy of our users and their accompanying privacy rights. This Privacy Policy explains how we handle your personal data (including its collection, use, disclosure, and safeguarding) and how we protect your privacy.
This Privacy Policy applies to data collected across our website, apps, services, events, and more.
If you do not accept the terms of the Tutoray Privacy Policy presented herein, please do not access the Tutoray website/application or subscribe to, buy, or benefit from Tutoray's services.

1. Parties

a. Company
Our company name is EducationTeknoloji A.Ş.Our registered office address is: Kustepe mah. Mecidiyeköy yolu cad.Trump tower No: 12 iç kapi no: 18 şişli/ Istanbul. When we reference "we", "us", "our" or"Tutoray” in this Privacy Policy, we are referring to Tutoray acting as a data controller with respect to your personal data. If you have any questions about this Privacy Policy or how we process your personal data, please contact our Data Protection Officer at contact@tutoray.com.

b. User
The term "user" refers to potential and existing users who benefit from our services through our website, mobile application, or any other medium.

2. Terms and definitions

Descriptions of the terms used in this Privacy Policy are as follows:
“Authority” means the Personal Data Protection Authority.
“Board” means the Personal Data Protection Board.
“Data subject” means the natural person whose personal data is processed.
“Disposal” means the erasure, destruction, or anonymization of personal data.
“Law” means the Personal Data Protection Law No. 6698 dated 24/3/2016.
“Personal data” means any information relating to an identified or identifiable natural person.
“Processing of personal data” means any operation performed on personal data wholly or partially by automated means, or by non-automated means provided that they form part of a data filing system, such

as collection, recording, storage, protection, alteration, adaptation, disclosure, transfer, retrieval, making available for collection, categorization, or preventing its use.
“Recording medium” means any environment in which personal data is stored, wholly or partially, by automated means, or by non-automated means, provided that they form part of a data filing system.
“User” means any potential and existing users who benefit from our services through our website, mobile application, or any other medium.

3. Principles of processing of personal data

When processing your personal data under this Privacy Policy, we comply with applicable laws, this Privacy Policy, and the following principles:

We process personal data only for specific, legitimate purposes and with your consent. Through this Privacy Policy, we transparently explain these purposes and the scope of data processing in a clear and understandable manner.
We process personal data only when it is relevant, limited, and proportionate to the intended purpose.
We take due care to ensure your personal data remains accurate and up to date.
We store or retain personal data only for as long as necessary to fulfil the processing purpose and to comply with applicable legal requirements.

4. Legal grounds and applicable law

We process personal data in accordance with the Personal Data Protection Law No. 6698 (dated 24/03/2016), based on the legal grounds set out in Articles 5 and 6 of the Law. The full text of the legislation is available at https://www.kvkk.gov.tr/Icerik/6649/Personal-Data-Protection-Law.

In line with the applicable legislation, we process your personal data when:

It is expressly provided for in the law.
It is necessary for and directly related to the establishment or performance of a contract.
It is mandatory for compliance with a legal obligation to which the data controller is subject.
The personal data has been made public by the user or provided by the user directly.
It is necessary for the establishment, exercise, or protection of a legal right.

In the absence of the above-listed grounds, we process personal data only with your explicit consent. When requesting your explicit consent for data processing, we clearly specify the particular processing activity.

5. Your rights under the Personal Data Protection Law No. 6698 (dated 24/03/2016)

Pursuant to Article 11 of the Personal Data Protection Law No. 6698 (dated 24/03/2016), you have the right to:
‍

Learn whether your personal data has been processed;
Request information regarding the processing of your personal data;
Learn the purpose of data processing and whether your personal data is used in compliance with that purpose;
Be informed about third parties, domestic or international, to whom your personal data has been transferred;
Request rectification of incomplete or inaccurate personal data;
Request erasure or destruction of your personal data;
Request confirmation that rectification, erasure, or destruction of your data has been communicated to relevant third parties;
Object to decisions made solely based on automated processing if such decisions produce negative consequences for you;
Seek compensation for damages incurred due to the unlawful processing of your personal data;
Restrict processing under certain circumstances;
Object to processing;
Withdraw consent when processing relies upon your explicit consent;
Lodge a complaint with the Kişisel Verileri Koruma Kurumu (KVKK).

You can submit your requests under this article as per the information provided below under the heading of “Contact”. We will respond to and address all requests free of charge in compliance with applicable laws. However, if additional costs arise when fulfilling your request, charges may be applied in accordance with the tariff promulgated by the Authority.

6. Personal Data Processes

Personal Data We May Collect
‍

We may collect and process the following personal data about you:
‍

● Information you provide directly to us: This includes data you provide through forms, surveys, registrations, submissions, events, feedback, queries, applications, and other interactions via our websites, apps, in-person meetings, postal mail, email, telephone, or other means.
● Correspondence data: Includes records of correspondence and interactions you have with us through email, chat, phone, support tickets, or other communication channels.
● Transaction and billing data: Includes details about payments, subscriptions, event tickets, invoices, billing addresses, and related information.
● Website and app activity data: We may use tracking technologies, such as cookies, to understand how you use our websites and apps. This helps us evaluate and enhance performance, navigation, marketing efforts, and your overall experience.
● Social media activity: Interactions and content you share with us on social media may result in the collection of personal data, depending on your privacy settings.
● Publicly available information: We may collect publicly available information about you from directories, professional sites, news outlets, and other online or offline sources.

We do not knowingly collect or solicit personal data from anyone under the age of 16. If we become aware that we have unintentionally collected personal data from a child under 16, we will delete that information promptly. If you believe we may have collected information from or about a child under the age of 16, please contact us immediately.

How We Collect Your Personal Data

‍We collect your personal data through the Tutoray website and application via automatic and partially automatic methods.

How We Use Your Personal Data

‍We use your personal data to provide our services, enhance user experience, communicate with you, perform analytics, and comply with legal requirements. Specifically, we use collected personal data to:

Communicate with you
Tailor our offers and available options to your preferences;
Compile anonymous statistical data and conduct internal analyses;
Perform age restriction checks;
Prevent fraud and abuse of our systems;
Resolve disputes and troubleshoot issues; and
Comply with our legal obligations.

Data Retention
‍
We retain your personal data for as long as necessary to fulfil the purposes outlined in this Privacy Policy and to comply with applicable legal obligations.
‍
When your personal data is no longer needed, we securely delete, destroy, anonymize, or de-identify it in accordance with best practices. We regularly review our stored data to ensure it is not retained longer than necessary or legally permitted.

How We Protect Your Data

We use appropriate technical and organizational safeguards to protect your personal data, and regularly updateand test these measures. Examples include:

Encryption of data in transit and at rest
Strict access controls for data and systems
Ongoing privacy and security training for staff
Regular evaluation and testing of security measures and practices

Although we strive to protect your personal data to the best of our ability, no data security measures can guarantee complete security at all times.

Who We Share Your Data With

‍We do not sell, rent, lease, or otherwise disclose your personal data to third parties, except in the following circumstances:

Competent authorities: Any law enforcement authority, regulatory or government agency, court, or other third party, as required by applicable law.
Vendors and service providers: We share data with vendors and service providers who perform services based on our instructions and are required to protect your data.
Professional advisors: We may disclose data to professional advisors in connection with our business operations and transactions.
Corporate transactions: In the event of a business transaction or proceeding, your data may be transferred as permitted by law. Any purchaser or successor will be required to honour the commitments outlined in this policy.
Other cases: We may share your data when necessary to protect your interests or as otherwise permitted by law, with appropriate safeguards in place.

7. CONTACT US

The Data Controller of your personal data is Tutoray If you have any questions, comments, or requests relating to your rights of privacy or about our privacy practices or this policy, please contact our Data Protection Officer at contact@tutoray.com or by mail to Education Teknoloji A.Ş., Kustepe mah. Mecidiyeköy yolu cad. Trump tower No: 12 iç kapi no: 18 şişli/ Istanbul.

Last Updated: 7th April 2025