KVKK

KVKK Information Text

Data controller, categories of personal data processed, purposes, legal grounds, transfers and data subject rights under Turkish Law No. 6698.

Last updated: 7 August 2026

1. Data Controller

Under Turkish Law No. 6698 on the Protection of Personal Data ("KVKK"), your personal data is processed by the company operating under the SoloRota brand in its capacity as data controller, within the framework explained below.

The data controller's registered company name, address and contact details are set out in the Company information section at the end of this page.

2. Categories of Personal Data Processed

Category	Data processed
Identity	Name and surname; student's name and grade/level; parent's name. An identity number only where the relevant payment method requires it (retained for invoicing and accounting records for 1 year from the order date).
Contact	Email address, telephone number; parent/student contact details.
Customer transaction	Order number, package purchased, quantity, amount, currency, payment method and payment status; order note; request and complaint records.
Transaction security	IP address, session records, device and browser information, sign-in/sign-out records, access logs.
Legal action	Agreement approval records (approval date/time and document version), request and application correspondence, records relating to legal proceedings.
Educational process	Learning plan, lesson planning and attendance records; progress and performance assessments depending on the package.
Marketing	Only where you have given separate consent: commercial electronic message permission record and communication preferences.

Collection of special categories of personal data is not intended. If such data reaches us through channels such as support correspondence, it is processed solely to conclude the request and only for as long as necessary.

3. Purposes of Processing

Creating the membership record and maintaining account security
Concluding and performing the distance selling agreement
Providing the digital education service, creating the learning plan and planning lessons
Carrying out teacher matching according to the package
Tracking progress and reporting to the parent
Executing payment transactions and recording them in the accounts
Managing requests, complaints, withdrawal and refund processes
Ensuring information security and preventing misuse
Measuring service quality and improving the Platform
Meeting legal obligations and complying with retention periods
Sending commercial electronic messages where consent has been given

4. Legal Grounds

Your personal data is processed on the following legal grounds set out in Article 5 of the KVKK:

Legal ground	Applied to
Necessary for the conclusion or performance of a contract (Art. 5/2-c)	Membership, ordering, payment, provision of the service, lesson planning, support processes.
Compliance with a legal obligation (Art. 5/2-ç)	Invoice and accounting records, statutory retention periods, requests from competent authorities.
Establishment, exercise or protection of a right (Art. 5/2-e)	Agreement approval records, dispute and request management.
Legitimate interest (Art. 5/2-f)	Information security, prevention of misuse, measuring and improving service quality.
Explicit consent (Art. 5/1)	Only for commercial electronic messages and non-essential cookies.

Processing necessary for the conclusion and performance of the contract is not based on explicit consent. Explicit consent is obtained only in the limited cases stated above and may be withdrawn at any time. Withdrawing consent does not affect the provision of the service you purchased.

5. Method of Collection

Your personal data is collected electronically and by partially automated means through:

Membership, order and payment forms;
The contact form, support requests and email correspondence;
System and session records generated automatically during use of the Platform;
Educational records generated during lessons and guidance sessions.

6. Recipient Groups

Your personal data may be transferred to the following recipient groups, limited to the processing purposes and in accordance with Article 8 of the KVKK:

Payment service providers: order and contact details, in order to execute the payment and manage refunds.
Hosting and technology service providers: within the scope of operating the Platform and data storage services.
Email delivery infrastructure providers: in order to transmit order and information emails.
Teaching staff: student information, limited to what is necessary, to the relevant teacher or education adviser so that lessons can be delivered.
Measurement and tag management service providers: site usage measurement data, where you have consented to non-essential cookies.
Accounting and legal advisers: in order to meet legal obligations and protect rights.
Competent public authorities: within the scope of requests arising from legislation.

Where a service provider's servers are located abroad, the transfer is carried out in accordance with the conditions set out in Article 9 of the KVKK.

7. Retention Period

Your personal data is retained for as long as the purpose of processing requires and for the limitation and retention periods prescribed by applicable legislation.

Upon expiry of the period, data is deleted, destroyed or anonymised.

8. Your Rights as a Data Subject

Under Article 11 of the KVKK, by applying to the data controller you have the right to:

Learn whether your personal data is being processed;
Request information if it has been processed;
Learn the purpose of processing and whether the data is used in accordance with that purpose;
Know the third parties to whom the data is transferred in Turkey or abroad;
Request correction if the data is incomplete or inaccurate;
Request erasure or destruction within the conditions prescribed by law;
Request that correction, erasure and destruction be notified to third parties to whom the data was transferred;
Object to a result adverse to you arising from analysis exclusively by automated systems;
Claim compensation if you suffer damage due to unlawful processing.

9. How to Apply

You may submit requests concerning your rights, in accordance with the Turkish Communiqué on the Procedures and Principles of Application to the Data Controller, by:

Sending an email to the address in the Company information section from the email address registered in our systems;
Sending a written application to the registered address in the Company information section, in person or through a notary;
Sending a message with a secure electronic signature to the registered electronic mail (KEP) address, where one is stated.

Your application must clearly state your name and surname, the contact details on which the application is based, and the subject of your request. Additional information may be requested in order to verify your identity.

Requests are concluded free of charge as soon as possible and within thirty (30) days at the latest, depending on their nature. Where the process entails an additional cost, the fee in the tariff set by the Turkish Personal Data Protection Board may be charged.

If your application is rejected or you do not receive a response within the period, you retain the right to lodge a complaint with the Turkish Personal Data Protection Board.