LINGUA LEARN TURKEY
PERSONAL DATA PROTECTION LAW (KVKK) CLARIFICATION TEXT Last
updated: November 11, 2026
1. Data Controller
Lingua Learn Türkiye is a language education brand operated by Promere Software and Consultancy Trade Limited Company.
controller of your personal data within the scope of the Personal Data Protection Law No. 6698 (“KVKK”):
Trade Name: Promere Software and Consultancy Trade Limited Company
Brand: Lingua Learn Turkey
MERSIS No: 0733093692200001
Address: Esentepe Mahallesi, Keskin Kalem Sokak, Arya Plaza, No: 17/2, Şişli, Istanbul 34394, Turkey
E-mail: info@lingua-learn.com.tr
KEP: promereyazilimvedanismanlik@hs01.kep.tr
Website: https://lingua-learn.com.tr
2. Processed Personal Data
If you use the services offered by Lingua Learn Turkey or contact us, the following personal data may be processed depending on the nature of the transaction:
- Identification information: First name, last name, invoice, and identity or tax information when legal action warrants.
- Contact information: Email address, phone number, billing address, and contact preferences.
- Student and educational information: Student’s name, age, or age group, preferred language, language level, courses attended, syllabus, attendance, assessment results, educational progress, and required educational records.
- Parent or legal representative information: Identity, contact, and payment information of the parent or legal representative for minor students.
- Order and payment information: Services purchased, order amount, payment method, payment status, invoice and accounting records. Payment card transactions can be made through the contracted payment service provider; the entire number and security code of the card are not taken for storage by Lingua Learn Turkey.
- Communication records: Requests, messages, complaints and related transaction records transmitted via e-mail, WhatsApp, phone or forms.
- Website usage data: IP address, browser and device information, cookie identifiers, visit and transaction records, and data on analytics services used.
- Instructor information: Name, contact, expertise, qualification, and eligibility information required for the coordination of the training service.
Sensitive personal data is not requested as part of our ordinary course registration process. If it becomes necessary to process such data, the relevant regulatory requirements will also be considered.
3. Purposes and Legal Reasons for Processing Personal Data
Your personal data may be processed for the following purposes, based on the relevant processing conditions in Article 5 of the KVKK.
| Purpose of processing | Main legal reason |
|---|---|
| Course registration, student account, educational planning and delivery of courses | Necessity for the establishment or performance of the contract — KVKK art.5/2(c)Course |
| coordination with students and parents, program changes and service communication | Performance of the contract — art.5/2(c) |
| Keeping records arising from orders, invoices, accounting and legislation | Legal obligation — art.5/2(ç) |
| Consideration of customer claims and complaints | Performance of the contract or legitimate interest — art.5/2(c), (f) |
| Management of disputes and protection of rights | Establishment, exercise or protection of a right — art.5/2(e) |
| Ensuring website and system security | Legitimate interest or legal obligation — art.5/2(f), (ç) |
| Analytical, advertising and marketing activities requiring approval | Explicit consent depending on the nature of the transaction — art.5/1 |
The basis of legitimate interest is applied provided that the fundamental rights and freedoms of the person concerned are not harmed.
In terms of activities that require explicit consent, disclosure and explicit consent procedures are carried out separately from each other.
4. Methods of Collecting Personal Data
Your personal data;
- lingua-learn.com.tr website, WooCommerce order and registration forms,
- e-mail, phone and WhatsApp calls,
- online lessons and training organization,
- language level assessment and progress processes,
- payment and billing systems
- , cookies, server registrations and analytics technologies
electronically and, when necessary, verbally.
5. Recipients to whom Personal Data may be transferred
Your personal data may be shared with the following recipients to the extent necessary for the provision of the service and the fulfillment of legal obligations:
Instructors: Necessary information such as the name of the relevant student, contact details, language level and course schedule for the purpose of conducting the courses and communicating with the student.
Lingua Learn franchise center: Student, course and fee information required for the coordination of franchise activities, training organization and contractual reporting.
Payment institutions and banks: Transaction information necessary for the purpose of processing and verifying the payment and carrying out refund procedures when necessary.
Accounting and authorized public institutions: Information required for the fulfillment of billing, tax and other legal obligations.
Information technology service providers: Data required for the execution of website, e-mail, cloud infrastructure, security, backup and communication services.
Competent authorities: Information that is legally required or duly requested.
Data sharing is limited to the purpose and scope required by the relevant service.
6. Transfer of Personal Data Abroad
Due to the international nature of the online language education services offered by Lingua Learn Turkey, some personal data are transferred to recipients outside Turkey or processed through technology infrastructures originating from abroad.
In this context:
- Student names, country of residence, course information and fee information can be shared with the Lingua Learn franchise center in the United Arab Emirates for contractual reporting and training coordination purposes.
- Student name, contact information, language level and course schedule required for the conduct of courses can be shared with instructors working outside Turkey.
- Website, e-mail, system security and encrypted backup services can be carried out through server and cloud service providers abroad.
- services of Google, Microsoft, Meta/WhatsApp and similar technology providers are used, communication, usage or technical data can be processed in systems abroad depending on the nature of the relevant service.
The legal conditions for personal data transfers abroad are regulated in Article 9 of the KVKK. These transfers must be based on a legal mechanism in accordance with the relevant legislation.
This clarification text is intended to inform about international data transfers; it does not alone constitute explicit consent or legal transfer assurance for data transfer abroad.
7. Cookies and Website Analytics
Cookies and similar technologies may be used on our website to provide basic site functions, protect security, analyze usage, and carry out marketing activities if permitted.
Analytics services such as Google Analytics and Microsoft Clarity can be used. Visitor preferences and the application of consent management are taken into account according to the operation of the relevant technology.
More detailed information about cookie types, purposes and how preferences can be managed is provided in the Cookie Policy published on our website.
8. Personal Data of Children Course
registration and purchase procedures of students under the age of 18 can be carried out through parents or legal representatives.
Children’s personal data is processed limited to the scope necessary for the planning and delivery of educational services.
For the purpose of carrying out educational activities, the student’s name, age-appropriate educational information and necessary contact information may be shared with the relevant instructors.
The personal data processing conditions required for marketing activities for children are also evaluated.
9. Recording Online Lessons At
Lingua Learn Turkey, routine recording of online lessons is not essential.
Exceptionally, if a course is planned to be recorded, participants are informed before registration and necessary explicit consent is obtained when required by the relevant legislation. For underage participants, the requirements regarding parents or legal representatives are also observed.
10. Storage and Deletion of Personal Data Your
personal data is stored for the period required for the purpose for which they were collected and in accordance with the retention obligations stipulated by the relevant legislation.
Accounting, invoice and commercial transaction records are kept for the relevant legal periods.
Training, communication and application records are limited to the periods required for the execution of the service, the evaluation of possible requests and the protection of rights.
Personal data whose processing purpose and legal retention obligation have expired are deleted, destroyed or anonymized in accordance with the relevant legislation.
11. Security of Personal Data In
order to protect personal data against unauthorized access, loss, alteration or unlawful processing, technical and administrative measures appropriate to the nature of the processing activity are implemented.
These measures; may include limitation of access authorizations, system security, secure communication, backup and access controls.
12. Your Rights Under KVKK
Pursuant to Article 11 of KVKK, by applying to the data controller:
- To learn whether your personal data has been processed,To
- request information if it has been processed,To
- learn the purpose of processing and whether it is used in accordance with its purpose,To
- know the third parties to whom it is transferred domestically or abroad,To
- request the correction of incomplete or incorrectly processed personal data,To
- request the deletion or destruction of personal data within the scope of legal conditions,To
- request notification of correction, deletion and destruction to third parties to whom the data has been transferred,To
- object to the occurrence of a result against you as a result of the analyzes made exclusively with automated systems,To
- request compensation for the damage in case you suffer damage due to unlawful processing.
You have the rights.
13. Application Method
can submit your requests within the scope of KVKK through the following communication channels:
Data Controller: Promere Software and Consultancy Trade Limited
E-mail: info@lingua-learn.com.tr
KEP: promereyazilimvedanismanlik@hs01.kep.tr
Postal Address: Esentepe Mahallesi, Keskin Kalem Sokak, Arya Plaza, No: 17/2, Şişli, Istanbul 34394, Turkey
Your applications are evaluated within the framework of the methods and conditions in the Communiqué on the Procedures and Principles of Application to the Data Controller.
Applications are concluded as soon as possible and within 30 days at the latest, depending on the nature of the request.
Last updated: November 11, 2026
Data Controller: Promere Software and Consulting Trade Limited Company — Lingua Learn Türkiye
