PRIVACY POLICY AND PERSONAL DATA PROTECTION NOTICE
1 - Introduction
The privacy and security of your personal data are among our top priorities. In accordance with the Personal Data Protection Law No. 6698 (“KVKK”) and applicable legislation, we take care to process your personal data securely.
This notice has been prepared to inform you about the personal data we store and process as part of our Level Test service. Level Test is an AI-powered assessment system that provides guidance on our members’ English speaking skills. You must register on our website to use the service.
2 - What Personal Data Do We Process?
When you use the Level Test service, the following personal data is processed:
User Account Information: First name, last name, email address, and membership information.
Test Data: Your spoken responses during the test and their written transcripts.
Test Result Information: Assessment reports generated with the help of artificial intelligence.
Your test data is processed solely to provide guidance on your level and feedback, and is stored in our Supabase database. You may delete your data at any time.
3 - Legal Grounds, Purposes, and Methods for Collecting and Processing Your Personal Data
Your personal data is processed for the following purposes:
3.1 Membership and Testing Process
Processing membership applications and creating your user account,
Carrying out the processes necessary for you to use the Level Test service,
Generating and presenting your test results and providing you with access to them.
Ensuring system security and improving the testing process.
Legal Ground: Necessity for the performance of a contract pursuant to Article 5/2(c) of the KVKK.
3.2 Improving the User Experience
Analyzing the testing process to improve the user experience,
Conducting reporting and analysis to improve service quality and enhance algorithms.
Legal Ground: Our legitimate interests pursuant to Article 5/2(f) of the KVKK.
3.3 Fulfillment of Legal Obligations
Fulfilling our legal obligations when requested by authorized institutions,
Implementing legal requirements related to personal data security.
Legal Ground: Necessity for compliance with legal obligations pursuant to Article 5/2(ç) of the KVKK.
3.4 Data Processing Based on Explicit Consent
To provide the Level Test service, we use service providers located abroad, such as Supabase and OpenAI. These services are essential for the test to operate and for results to be generated. However, since transferring your personal data abroad requires your explicit consent under Article 9 of the KVKK, we must obtain your explicit consent before you use the Level Test application.
Accordingly, the following processes will be carried out only with your explicit consent:
Your spoken responses during the test and their written transcripts will be processed through OpenAI’s speech recognition and assessment systems to determine your level,
Your test result information will be stored on Supabase and presented to you.
If you do not give your explicit consent, you will not be able to use our Level Test service. You may withdraw your explicit consent at any time. However, please note that after withdrawing your consent, you will no longer be able to use the Level Test service and your previously processed data may continue to be stored for the period required by law.
Legal Ground: Your explicit consent pursuant to Article 5/1 of the KVKK.
KVKK Article 9: Your explicit consent must be obtained to transfer your personal data abroad.
KVKK Article 5/2(c): Although data processing may be necessary to perform the service contract, transferring data abroad is subject to explicit consent.
4 - To Whom and for What Reasons Is Your Personal Data Transferred?
Your personal data is shared only in the following circumstances, in accordance with the principles of need to know and need to use:
IT and Technology Service Providers: Data is shared with service providers named Supabase and OpenAI to enable Level Test to operate. These service providers are located abroad, and your data will be transferred abroad.
Authorized Public Institutions and Organizations: Your data may be shared with authorized authorities upon request to fulfill legal obligations.
5 - Measures We Take to Protect Your Personal Data
We take the following measures to protect your personal data:
Data encryption: Your data is protected using secure encryption methods.
Access controls: We use strong authentication and access control systems to prevent unauthorized access.
Regular audits: We conduct regular security analyses to ensure data security.
6 - Your Rights Regarding Your Personal Data
Under the KVKK, you have the following rights:
To learn whether your personal data is being processed,
To request information about it if it has been processed,
To learn the purpose of processing and whether the data is being used in accordance with that purpose,
To request correction if the data has been processed inaccurately or incompletely,
To request deletion of the data under Article 7 of the KVKK,
To object to adverse outcomes resulting from the analysis of processed data solely by automated systems.
You can contact us using the methods below to exercise your rights.
7 - Contact for Your Rights and Requests
You can submit requests regarding your personal data through the following contact channels:
Email: info@rethaco.com
Address: Esentepe Mh. Talatpaşa Cd. No:5/1, Levent, Şişli, İstanbul / P.K.: 34394
Your applications will be answered within 30 days at the latest, as required by the KVKK.
8 - Updates and Changes
This notice may be updated in line with changes to legislation and service updates. The updated notice will take effect when published on our website.
Update Date: 10.03.2025