Privacy Policy and KVKK Privacy Notice

This notice has been prepared by CND EDUTECH EĞİTİM TEKNOLOJİLERİ ANONİM ŞİRKETİ (the "Company"), in its capacity as data controller, under the Turkish Personal Data Protection Law No. 6698 ("KVKK"), in connection with the aprindo.com platform (the "Platform") operated by the Company.

1. Personal Data Processed

• Teacher (subscriber) data: full name, email address, phone number, billing and payment information (including bank transfer receipts), platform usage records.
• Teacher profile and directory data: the full name, photo, subjects taught, introduction text, city, lesson format and fee information entered by the teacher. This data is published on the teacher's public web profile and — once the profile is sufficiently complete, and unless the teacher turns it off in the panel — in the Tutors & Coaches directory, so that students can find a tutor. The teacher can turn off the directory listing from their panel at any time.
• Student data: the full name and username defined by the teacher, along with study/progress records. Creating a student account does not require an email address or phone number.
• Parent/student contact data: the contact email address and/or phone number entered (optionally) by the teacher. This data is processed through the email infrastructure for the purpose of sending login details and lesson reminders to the student or their parent. If a WhatsApp number has been entered and the teacher has confirmed that the student (or, if under 18, their parent) consented — or the student entered their own number and chose WhatsApp notifications — lesson reminders and informational messages such as lesson scheduling, assignments, payment requests and question replies are also sent to that number via WhatsApp. The sign-up verification code and lesson, lesson request, question, assignment and payment notifications are sent to the teacher's own number entered at sign-up or on their profile. Recipients can stop these messages at any time using "Stop notifications" in the message or by replying STOP, after which no further WhatsApp messages are sent to that number. Messages sent to our notification number are recorded in order to send an automatic information reply and to review them where necessary.
• Course buyer (platform learner) data: the full name, email address and phone number of a learner who opens their own account in the Tutors & Coaches / courses directory; course orders, order reference code, the uploaded bank transfer/EFT receipt, course access and progress records, and completion certificate details.
• Technical data: IP address, browser information, session cookies.

2. Purposes of Processing

• Providing the service, and creating and managing accounts,
• Receiving and verifying payments for the Company's own sales (subscription, student slots, AI tokens and other platform services),
• Forwarding teacher–student lesson fee requests and course orders to the relevant teacher and enabling them to be tracked (these payments are made directly to the teacher; the Company does not collect them),
• Sending login details to students; lesson reminders and platform notifications to students, parents and teachers (by email and, where consented, WhatsApp); sending the verification code at teacher sign-up,
• Fulfilling legal obligations (invoicing, accounting),
• Security, fraud prevention, and measuring and improving service quality.

3. Method of Collection and Legal Basis

Your personal data is collected by fully or partially automated means through membership/sign-up forms, student records created via the teacher panel, payment steps, cookies and electronic communication channels (email, WhatsApp, contact form).

Your data is processed on the following legal bases (KVKK Article 5):

• Processing is necessary for the conclusion or performance of a contract (Art. 5(2)(c)): providing the membership and subscription service, creating and managing accounts;
• Processing is necessary for the data controller to fulfill its legal obligations (Art. 5(2)(ç)): obligations under invoicing, accounting, tax and e-commerce legislation;
• Processing is necessary for the establishment, exercise or protection of a right (Art. 5(2)(e));
• The legitimate interests of the data controller, provided that your fundamental rights and freedoms are not harmed (Art. 5(2)(f)): security, fraud prevention, measuring service quality;
• Where none of the above conditions apply, your explicit consent (Art. 5(1)) — in particular with respect to non-essential cookies and marketing/informational communications.

4. Transfer of Personal Data

Your personal data may be transferred to the following groups of recipients, limited to the purposes of processing:

• Within Türkiye: to the payment institution (PayTR Ödeme ve Elektronik Para Hizmetleri A.Ş.) for the purpose of processing payments; and to authorized public institutions and organizations as required by legal obligations.
• The relevant teacher: the full name, email address, phone number, order and receipt details and course progress records of a learner who buys or enrolls in a course are transferred to the teacher selling the course, for the purposes of approving the order, granting access, invoicing and communicating with the learner. With respect to the course sale, the teacher is a separate data controller processing this data for their own purposes; the learner may also exercise their rights regarding this data against the teacher.
• Abroad: to the hosting/server service provider (the servers are located abroad), email notification infrastructure providers, Meta Platforms for WhatsApp notifications and ad measurement (WhatsApp Business and Meta Pixel / Conversions API; for measurement, email only in irreversibly hashed form) and the provider of AI-assisted content/verification services; only to the extent necessary for the service to be technically provided.

Transfers abroad are carried out under KVKK Article 9: directly to countries offering adequate protection, and otherwise on the basis of appropriate safeguards (data transfer/standard contracts) or your explicit consent. Under no circumstances is your personal data sold to third parties for marketing purposes.

5. Personal Data of Children (Students) and Parental/Guardian Consent

The Platform may process the data of students under the age of 18. Processing the personal data of a student under 18 (full name, username, contact details and study records) requires the explicit consent of the parent/legal representative.

A teacher who adds students to the Platform is obliged to obtain the necessary explicit consent from the relevant parent/legal representative before entering the data of the student and, if applicable, their parent. The Company acts as a "data processor" processing this data on the teacher's instructions; with respect to student data, the "data controller" that determines the purposes and means of processing is the relevant teacher/educational institution. The parent/legal representative may exercise the rights under KVKK Article 11 regarding the child's data through the teacher who entered the data or by applying to info@aprindo.com.

6. Cookies

The panels (teacher, student, admin) use only cookies that are strictly necessary for session management. Our public promotional pages use Meta Pixel measurement cookies to measure advertising performance; this tool does not run after you sign in. For details, please see the Cookie Policy.

7. Retention Period

Data is retained for the duration of the membership and for the statutory retention periods (e.g. under Law No. 6563 and tax legislation); at the end of these periods, it is deleted or anonymized. A teacher may request the deletion of their account and of their students' data at any time.

8. Your Rights under KVKK

Under KVKK Article 11, you have the right to access, rectify and erase your data, to object to its processing and to request information about transfers. You can send your requests to info@aprindo.com; applications are answered within 30 days at the latest.

9. Data Security

All traffic is encrypted with SSL/TLS, passwords are stored irreversibly (bcrypt), the database is backed up daily and access is restricted to authorized personnel only.

10. Data Controller and Contact

• Data Controller: CND EDUTECH EĞİTİM TEKNOLOJİLERİ ANONİM ŞİRKETİ
• Address: Bahçelievler Mah. 323/1 Cd. No: 10/50a/26, Gazi Üniversitesi Teknopark, Gölbaşı / Ankara
• Phone: +90 546 911 21 87
• Email: info@aprindo.com

You can submit your applications under KVKK in writing to the address above or by email from your registered email address to info@aprindo.com.

11. Automatic Detection of the Visitor's Language

When you visit the Platform's public pages, only the country you are in is determined from your IP address, so that the pages can be shown in the appropriate language (Turkish or English). This is done entirely locally, using the "DB-IP IP to Country Lite" database (https://db-ip.com, licensed under CC BY 4.0) hosted on our server. Your IP address is not stored for this purpose and is not sent to any third party; no location more precise than the country (such as city or address) is determined.

When you explicitly choose a language, that preference is stored in a cookie named aprindo_locale in your browser for 1 (one) year, so that the same language can be used on your future visits. This cookie contains only the language code ("tr" or "en"), and you can delete it at any time from your browser settings. This processing is based on our legitimate interest in presenting the service to you in a language you understand (KVKK Art. 5(2)(f)).

IP geolocation by DB-IP