ARITHMETIC EDUCATION AND TRAINING CONSULTANCY AND PUBLISHING CO.
DISCLOSURE TEXT ON THE PROCESSING OF PERSONAL DATA

This Clarification Text has been prepared by ARİTMETİK EĞİTİM VE ÖĞRETİM DANIŞMANLIK VE YAYINCILIK A.Ş. (“Company”), which is the “Data Controller” within the scope of Article 10 of the Law No. 6698 on the Protection of Personal Data (“Law”) and the Communiqué on the Procedures and Principles to be Followed in the Fulfillment of the Disclosure Obligation, in order to provide information about your personal data that may be obtained and processed during the execution of the activities and services offered.

Our Company acts in the capacity of data controller and pays all necessary attention and care for the protection of personal data.

Our Company acts in accordance with the general principles set forth by Law No. 6698 in the processing of personal data.

PURPOSES OF PROCESSING PERSONAL DATA

Processing of personal data refers to all kinds of operations performed on personal data, such as obtaining, recording, storing, retaining, modifying, reorganizing, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data by fully or partially automatic means or by non-automatic means provided that they are part of any data recording system.

Your personal data may be processed when you call our call center, visit our website, use our digital applications, participate in trainings, seminars, organizations and meetings organized by our Company in order to use our Company’s products and services and/or receive information.

Personal data by our company;

• Improving the services offered, developing new services and providing information about them,
• Promotion and marketing of campaigns and services for existing and potential customers with commercial electronic message approval,
• To be able to contact you regarding the product or service you have received or will receive,
• Resolving customer problems and complaints,
• Updating customer information,
• Planning and execution of customer satisfaction activities and activities to improve the customer experience,
• Statistical evaluations and market research,
• Determining and implementing the company’s commercial and business strategies,
• Managing relationships with member merchants and business partners,
• Follow-up of accounting and payment transactions,
• Ensuring compliance with the custody obligations stipulated in the legislation,
• Responding to information requests from administrative and judicial authorities,
• Planning internal reporting and business development activities,
• Financial control and reporting and realization of legal notifications,
• Managing internal control and audit activities,
• Ensuring information and transaction security and preventing malicious use and fraud,
• Fulfillment of mutual rights and obligations regarding your transactions with our Company,
• Existing or new product studies and market research of our company, our business partners and our domestic or foreign subsidiaries and identification of target customer groups,
• Making the necessary arrangements to ensure that the processed data is up-to-date and accurate

and to carry out activities related to all these processes.

METHOD AND LEGAL REASON FOR COLLECTING PERSONAL DATA

Your personal data is obtained by using physical or electronic media such as all kinds of verbal, written, voice recording, call center in order to provide the products and services offered by our Company within the legal framework determined within the scope of the above-mentioned purposes and to fulfill our Company’s contractual and legal obligations in a complete and accurate manner. Your personal data collected due to our legal obligations can be processed within the scope of the personal data processing conditions specified in Articles 5 and 6 of the Law.

Without being limited to the aforementioned, the connection information recorded as required by the legislation when using our website, digital applications and social media accounts, the contact forms you fill in electronically, other forms you fill in at our workplace, office and representatives, written or verbal communications you have made with our Company through online channels, electronic mails you have sent to our Company through the electronic mail system, information and documents you have sent to our Company via tools such as fax or letter, Your personal data that you share verbally, in writing or electronically through the telephone channel or directly with our Company or the organizations that our Company cooperates with, the information and documents you share through the meetings and organizations organized by our Company, the information, surveys and documents you share through the meetings and organizations organized by our Company, the contracts you have signed with our Company and any other means, are collected by our Company in accordance with the Law, partially or completely by automated or non-automated methods.

TRANSFER OF PROCESSED PERSONAL DATA

Your personal data collected by our Company may be shared and transferred by our relevant business units for the realization of the commercial activities carried out by the Company in line with the above-mentioned data processing purposes; with our affiliates, shareholders, business partners, suppliers, auditors, service providers, legally authorized public institutions and organizations and private institutions and organizations, professional organizations and similar organizations, supervisory and regulatory authorities, private persons permitted by the provisions of the legislation and other persons and organizations within the framework of the conditions and purposes of transferring personal data and transferring personal data abroad specified in Articles 8 and 9 of the Law.

DURATION OF PROCESSING OF PERSONAL DATA

Your personal data will be processed for the periods required by the personal data processing purposes specified in this text. After the end of the said period, if there is any legislative provision or legal reason that allows the relevant data to be processed for a longer period of time, your personal data will continue to be processed during these periods. At the end of these periods, your personal data will be immediately deleted, destroyed or anonymized.

SECURITY MEASURES TAKEN REGARDING YOUR PERSONAL DATA

Our Company takes all necessary technical and administrative measures to ensure the appropriate level of security in order to prevent unlawful processing of your personal data, to prevent unlawful access to your personal data and to ensure the protection of your personal data.

YOUR RIGHTS REGARDING YOUR PERSONAL DATA

Personal Data Owners within the scope of Article 11 of the Law;

1. Learn whether personal data is being processed,
2. Request information if their personal data has been processed,
3. To learn the purpose of processing personal data and whether they are used for their intended purpose,
4. To know the third parties to whom personal data are transferred domestically or abroad,
5. To request correction of personal data in case of incomplete or incorrect processing,
6. To request the deletion or destruction of personal data in the event that the reasons requiring its processing disappear, although it has been processed in accordance with the provisions of the Law and other relevant laws,
7. To request notification of the transactions made pursuant to subparagraphs (e) and (f) to third parties to whom personal data are transferred,
8. To object to the emergence of a result to the detriment of the person himself/herself by analyzing the processed data exclusively through automated systems,
9. In case of damage due to unlawful processing of personal data, to demand compensation for the damage

rights.

Our Company will finalize your requests regarding your rights listed above in writing or by other methods to be determined by the Board within thirty days at the latest after the date of transmission. Your applications may be charged within the framework of the tariffs published by the Board.

In order to respond to the applications made, additional information and documents may be requested by our Company in order to verify your identity and clarify your request. If such information and documents are not shared, your application may not be answered to ensure the security of your data.

In order to exercise your rights listed above, you may submit your questions and requests within the methods and conditions described in Article 13 of the Law titled “Application to the Data Controller” on our Company’s website You can fill out the KVKK Application Form and submit it to our Company by the following methods.

Mailing Address : Kozyatagi Mah. Bayar Cad. No:74-1 Kadıköy IstanbulElectronic Mail Address : turkiye@theneweducator.com