Privacy Policy

Privacy Policy

Emko Eğitim Çözümleri A.Ş. ("we," "us," or "Emkotech") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, process, and share your personal data when you use Emkotech digital services. It also informs you of your privacy rights under applicable laws, including the General Data Protection Regulation (GDPR) and Turkish Personal Data Protection Law (KVKK).

By using Emkotech services, you agree to the collection and use of your information as described in this policy.

Definitions

• User Account: Your personalized digital profile enabling access to our services.
• Personal Data: Any information relating to an identified or identifiable natural person.
• Device: Any electronic device used to access our services (computer, smartphone, tablet, etc.).
• Application: Software, platform, or mobile solutions provided under the Emkotech brand.
• Service: All digital services provided by Emkotech.
• Service Provider: Any Turkish or foreign entity processing personal data on our behalf.
• You/User: Any individual or institution using the services and covered by this Privacy Policy.

Data We Collect

hCaptcha

We use the hCaptcha security service (hereinafter “hCaptcha”) on our website. This service is provided by Intuition Machines, Inc., a Delaware US Corporation (“IMI”). hCaptcha is used to check whether user actions on our online service (such as submitting a login or contact form) meet our security requirements. To do this, hCaptcha analyzes the behavior of the website or mobile app visitor based on various characteristics. This analysis starts automatically as soon as the visitor enters a part of the website or app with hCaptcha enabled. For the analysis, hCaptcha evaluates various information (e.g. IP address, how long the visitor has been on the website or app, or mouse movements made by the user). The data collected during the analysis is forwarded to IMI.

hCaptcha analysis in the “invisible mode” may take place completely in the background, and visitors may not be notified that such an analysis is happening if the user is not shown a challenge.

Data processing is based on Art. 6(1)(b) of the GDPR: the processing of personal data is necessary for the performance of a contract to which the website visitor is party (for example, the website terms) or in order to take steps at the request of the website visitor prior to entering into a contract. Our online service needs to ensure that it is interacting with a human, not a bot, and that the actions performed by the user are not fraudulent or abusive. In addition, processing may also be based on Art. 6(1)(f) of the GDPR: we have a legitimate interest in protecting our service from abusive automated crawling, spam, and other forms of abuse that can harm our service or its users.

IMI acts as a “data processor” on behalf of its customers under the GDPR, and as a “service provider” under the California Consumer Privacy Act (CCPA). For more information about hCaptcha’s privacy policy and terms of use, please visit:

https://www.hcaptcha.com/privacy and
https://www.hcaptcha.com/terms.

During your interaction with our services, we may collect the following personal data:

• Name and surname
• Email address
• User account information (profile details, login credentials)
• Technical data (IP address, device information, browser type, timestamps)
• Data collected through application permissions (camera, gallery, etc.)

Purposes for Using Your Data

We process your personal data for the following purposes:

• To ensure proper functioning and optimization of our platforms
• To create, manage, and secure user accounts
• To communicate with you and share relevant information and content
• To provide technical support and respond to requests
• To analyze user behavior and improve service quality and user experience

Legal Basis for Processing Personal Data

We process your personal data based on:

• Your explicit consent
• Performance of a contract to which you are a party
• Compliance with legal obligations
• Protection of our legitimate interests

Data Retention

We retain your personal data only as long as necessary to fulfill the purposes stated above. After this period, data is securely deleted or anonymized.

Sharing of Your Personal Data

We may share your personal data only when necessary for service provision with:

• Business partners and service providers who process data on our behalf
• Authorized public authorities as legally required

If data is transferred internationally, we ensure compliance with applicable regulations, including using Standard Contractual Clauses or similar safeguards.

Data Security

Protecting your personal data is important to us. We implement robust technical and administrative measures to ensure the confidentiality, integrity, and security of your data.

Your Privacy Rights

Under applicable law (GDPR/KVKK), you have the right to:

• Access your personal data
• Request correction of inaccurate or incomplete data
• Request deletion of your personal data
• Restrict or object to the processing of your data
• Request data portability
• Withdraw consent at any time (where consent is the legal basis for processing)

You can exercise these rights by contacting us using the information below.

Cookies and Similar Technologies

Our website uses cookies and similar technologies to enhance user experience, analyze site usage, and facilitate services. For detailed information, please see our Cookie Policy (linked separately on our website).

Children’s Privacy

Our services are not intentionally directed at children under the age of 13. We do not knowingly collect personal data from children under 13. If we become aware that we have inadvertently collected such data, we will promptly delete it.

Policy Updates

We may update this Privacy Policy periodically. Any changes will be published on this page with the updated effective date.

Contact Us

If you have any questions or requests regarding this Privacy Policy or our privacy practices, please contact us:

• Email: info@ee.com.tr
• Address: Emko Eğitim Çözümleri A.Ş., Hadımköy Yolu Caddesi No:147, 34500 Büyükçekmece / İstanbul, Türkiye
• Website: https://www.emkotech.com/contact

Effective Date: April 2025