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Privacy Policy

Privacy Policy & KVKK Information Notice

Effective Date: June 30, 2026

I, Cagri Adal, operating under the name Empress English, respect the privacy of students, website visitors, and individuals who contact me.

This Privacy Policy and KVKK Information Notice explains what personal data I may collect, why I process it, how it may be shared, how long it may be retained, and the rights available to individuals under Law No. 6698 on the Protection of Personal Data (KVKK) and other applicable legislation.

1. Data Controller

For the purposes of Law No. 6698, the data controller responsible for the processing of personal data described in this Privacy Policy is:

Cagri Adal
Empress English
Email: classes@empressenglish.com
Website: www.empressenglish.com

I determine the purposes and means of processing personal data in connection with Empress English and the one-on-one online English lessons I provide.

2. Personal Information I May Collect

Depending on how you interact with Empress English, I may collect and process the following categories of personal data:

Identity and Contact Information

  • Full name;

  • Email address;

  • Telephone number, if provided;

  • Country of residence, where provided; and

  • Other contact information provided by you.

Lesson and Learning Information

  • English language level;

  • English-learning goals;

  • Lesson preferences;

  • Information necessary to personalise one-on-one online lessons;

  • Examination preparation requirements;

  • Information provided during lessons; and

  • Communication history relating to lessons.

Booking and Transaction Information

  • Booking information;

  • Individual lesson or lesson package purchased;

  • Payment and transaction details;

  • Transaction date and amount; and

  • Information necessary to process refunds, credits, or other transactions.

I do not normally collect or store your complete credit or debit card number or card security code on my own systems.

Payments may be processed through PayTR, which may independently process payment information in accordance with its own privacy policies and applicable legislation.

Technical and Website Information

When you use the Empress English website, certain technical information may be collected automatically, including:

  • IP address;

  • Browser type;

  • Device information;

  • Operating system;

  • Website pages visited;

  • Approximate usage information;

  • Cookie information; and

  • Similar technical or usage information.

The use of cookies and similar technologies is described in my Cookie Policy.

3. How I Collect Personal Data

I may collect personal data through:

  • The Empress English website;

  • Contact forms;

  • Trial lesson or placement assessment forms;

  • Lesson booking forms;

  • Lesson-package purchase forms;

  • Email correspondence;

  • Direct communications with me;

  • Online lesson platforms;

  • Payment and transaction systems;

  • Cookies and similar technologies; and

  • Other communications through which you voluntarily provide information.

4. Purposes of Processing Personal Data

I may process personal data for the following purposes:

  • Responding to enquiries and requests;

  • Providing one-on-one online English lessons;

  • Assessing learning needs and English level;

  • Personalising individual lessons and learning materials;

  • Scheduling and managing lessons;

  • Managing bookings and lesson packages;

  • Processing payments and refunds;

  • Sending lesson confirmations and reminders;

  • Communicating important information about lessons;

  • Providing customer support;

  • Managing website functionality;

  • Improving my one-on-one online lesson arrangements and website;

  • Analysing website usage where legally permitted;

  • Managing security and preventing fraud or misuse;

  • Complying with legal and regulatory obligations;

  • Establishing, exercising, or protecting legal rights; and

  • Sending promotional or marketing communications where the applicable legal requirements have been satisfied.

5. Legal Grounds for Processing

Under KVKK, personal data may be processed where one of the legal conditions set out in the legislation applies.

Depending on the circumstances, I may process personal data where processing is necessary for purposes such as:

  • Establishing or performing a contract;

  • Fulfilling a legal obligation;

  • Establishing, exercising, or protecting a legal right;

  • Processing data that has been made public by the individual in accordance with applicable law;

  • Processing that is necessary for my legitimate interests, provided that this does not harm the fundamental rights and freedoms of the individual; or

  • Obtaining explicit consent where explicit consent is legally required.

The applicable legal basis depends on the nature and purpose of the particular processing activity.

Providing information through this Privacy Policy does not itself constitute explicit consent where separate explicit consent is legally required.

6. Payment Processing

Payments for one-on-one online English lessons and lesson packages may be processed through PayTR.

I do not normally collect, process, or store complete credit or debit card details on my own servers.

Payment information necessary to complete a transaction may be processed directly by PayTR or other relevant payment service providers.

PayTR may process personal data in accordance with its own terms, privacy practices, security procedures, and applicable legislation.

Information relating to a transaction may be retained by me where necessary for accounting, contractual, legal, refund, or record-keeping purposes.

7. Online Lessons and Third-Party Services

Empress English may use third-party service providers to provide or support one-on-one online English lessons and website functions.

Depending on the services currently used, these may include:

  • PayTR – payment processing;

  • Zoom – one-on-one online lessons and video communication;

  • Website hosting and website-management services;

  • Booking and scheduling services;

  • Email communication services;

  • Analytics and website-performance services; and

  • Other technical service providers necessary to operate Empress English.

Where necessary, limited personal data may be shared with these providers so that they can provide the relevant service.

8. International Transfers of Personal Data

Some third-party service providers used by Empress English may be located outside Türkiye or may process personal data outside Türkiye.

Where personal data is transferred abroad, I will comply with the applicable requirements of Article 9 of Law No. 6698 and relevant legislation concerning international transfers of personal data.

Depending on the circumstances, an international transfer may be made where an applicable legal mechanism or safeguard under Turkish data-protection legislation exists.

9. Marketing Communications

I may send promotional emails or other marketing communications where the applicable legal requirements have been satisfied.

Where consent is required, I will request the appropriate consent separately.

You may unsubscribe from marketing communications at any time by using the unsubscribe option included in the relevant communication or by contacting me at:

classes@empressenglish.com

Unsubscribing from marketing communications will not necessarily stop service-related communications that are necessary to provide a lesson, manage a booking, process a payment, or administer an existing service.

10. Cookies and Similar Technologies

The Empress English website uses cookies and similar technologies for purposes such as website functionality, preferences, analytics, security, and other purposes described in my Cookie Policy.

Where explicit consent is legally required for a particular cookie or processing activity, the applicable consent mechanism will be used.

11. Data Sharing

I do not sell, rent, or trade personal data.

Personal data may be disclosed or transferred, where necessary and legally permitted, to:

  • Payment service providers;

  • Online lesson and communication platforms;

  • Booking and scheduling providers;

  • Website hosting and technical service providers;

  • Email and communication service providers;

  • Analytics and website service providers;

  • Professional advisers where necessary;

  • Public authorities and governmental institutions where legally required;

  • Courts or other authorised bodies where legally required; and

  • Other persons or organisations where disclosure is necessary to establish, exercise, or protect legal rights.

I only share personal data to the extent reasonably necessary for the relevant purpose.

12. Data Retention

I retain personal data only for as long as reasonably necessary for the purposes for which it was collected or for the periods required by applicable law.

Retention periods may depend on:

  • The type of information;

  • The nature of the one-on-one online lesson arrangement;

  • The duration of the student relationship;

  • Accounting and tax requirements;

  • Legal obligations;

  • Potential disputes or legal claims;

  • Security requirements; and

  • Other legitimate business requirements.

When personal data is no longer required and there is no legal reason to retain it, I will take reasonable steps to delete, destroy, or anonymise it in accordance with applicable legislation.

13. Data Security

I take reasonable technical and organisational measures to protect personal data against unauthorised access, unlawful processing, accidental loss, destruction, alteration, or disclosure.

However, no internet transmission or electronic storage system can be guaranteed to be completely secure.

14. Children's Personal Data

Empress English may provide one-on-one online English lessons to students of different ages.

Where personal data relating to a child is collected, I will process personal data in accordance with applicable Turkish legislation and any additional requirements that apply to the circumstances.

Where parental or legal guardian involvement or consent is legally required, I will take reasonable steps to obtain it.

15. Your Rights Under Article 11 of KVKK

Under Article 11 of Law No. 6698, individuals may have the right to:

  • Learn whether their personal data is being processed;

  • Request information about the processing of their personal data;

  • Learn the purpose of processing and whether their personal data is being used in accordance with that purpose;

  • Learn the third parties to whom their personal data has been transferred, in Türkiye or abroad;

  • Request correction of incomplete or inaccurate personal data;

  • Request deletion or destruction of personal data where the applicable legal requirements are met;

  • Request notification of correction, deletion, or destruction to third parties to whom the relevant personal data has been transferred, where applicable;

  • Object to a result arising against them through analysis of processed data exclusively by automated systems, where applicable; and

  • Request compensation for damage arising from unlawful processing of personal data.

16. How to Exercise Your Rights

Requests concerning your rights under Article 11 of KVKK may be submitted to me using the contact details below.

Cagri Adal
Empress English
Email: classes@empressenglish.com

To protect personal data and prevent unauthorised access, I may need to verify the identity of the person making a request.

Requests will be handled in accordance with the procedures and time limits established under applicable Turkish legislation.

17. Third-Party Websites

The Empress English website may contain links to websites or services operated by third parties.

These websites operate independently from Empress English and may have their own privacy policies, cookie policies, and terms.

I am not responsible for the privacy practices or content of third-party websites.

18. Changes to This Privacy Policy

I may update this Privacy Policy from time to time to reflect:

  • Changes to my one-on-one online lesson arrangements;

  • Changes to the personal data processed;

  • Changes to third-party service providers;

  • Changes to website functionality;

  • Changes to applicable legislation; or

  • Changes to regulatory guidance.

The latest version will be published on the Empress English website together with its applicable effective date.

19. Contact

If you have any questions about this Privacy Policy, the processing of your personal data, or your rights under KVKK, please contact me:

Cagri Adal
Empress English
Website: www.empressenglish.com
Email: classes@empressenglish.com

Data Controller: Cagri Adal

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