Privacy Policy and KVKK Information Notice

This notice explains how your personal data is processed when you visit www.university.com.tr, contact us, fill in one of our forms, or use the university admission and student visa support services offered under the Turquoise Education brand. It is our information notice under Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK") and the Communique on the Procedures and Principles of the Obligation to Inform, and, for visitors in the European Economic Area, our notice under Articles 13 and 14 of the EU General Data Protection Regulation ("GDPR").

1. Data controller

Turquoise Education Group, operating under the brand Turquoise Education ("we", "us"). Address: Merkez Mahallesi Hasat Sokak No:12A Sisli, Istanbul, Turkey. Contact: contact@university.com.tr, +90 532 676 35 11.

Turquoise Education is a private university admission consultancy. We are not a university and not a government body: admission decisions are made by the universities, and visa and residence permit decisions are made by the Turkish authorities.

2. Personal data we process

• Identity: name and surname, father's and mother's names, gender, date of birth, nationality, passport details and the copy of your passport photo page.
• Contact: email address, telephone and WhatsApp number, postal address, country of residence.
• Education: diplomas, transcripts, exam results (for example YOS, SAT or language tests), the universities and programs you want to apply to, and admission results.
• Enquiry and customer transaction data: your messages and questions, the advice we give, offers, acceptance and invitation letters, and the progress of your application.
• Visa and residence: information needed to prepare your student visa or residence permit file, such as travel history, appointment details and the documents the authorities ask for.
• Financial: where a university or the authorities require it, proof of tuition payment or financial means (for example a bank statement or sponsor letter).
• Marketing preferences: whether you agreed to receive updates from us, and when.
• Transaction security and technical data: IP address, browser and device information sent with a form, server and error logs, and, only with your consent, analytics cookie data (see the Cookie Policy).
• Records of what you were told and chose: the version, date and time of the notice you acknowledged on our forms, and your cookie choice.

We do not ask for special categories of personal data (such as health, religion or criminal records). Please do not include them in your messages or documents unless a university or authority specifically requires them; if one does, we will ask for your explicit consent first.

3. How we collect it

Partly by automated means (the forms on this website, cookies and server logs) and partly by non-automated means: email, telephone, WhatsApp, documents you send us, meetings at our office, and information we receive from universities and the authorities while we work on your application.

4. Purposes and legal bases

• Answering your enquiry, assessing your profile and recommending universities and programs: necessary to take steps at your request before a contract (KVKK Art. 5/2(c); GDPR Art. 6(1)(b)).
• Providing our services (preparing and submitting your university applications, following up acceptance and invitation letters, supporting your student visa and residence permit applications): performance of a contract (KVKK Art. 5/2(c); GDPR Art. 6(1)(b)).
• Legal obligations such as commercial, tax and accounting record keeping and answering requests from authorities (KVKK Art. 5/2(ç); GDPR Art. 6(1)(c)).
• Establishing, exercising or defending legal claims (KVKK Art. 5/2(e); GDPR Art. 6(1)(f)).
• Keeping the website and our forms secure, preventing spam and abuse, keeping records of the notices we gave and the choices you made, and improving our services: our legitimate interests, which do not override your rights (KVKK Art. 5/2(f); GDPR Art. 6(1)(f)).
• Analytics cookies and sending you updates (application deadlines, scholarship news and tips by email or WhatsApp): only with your explicit consent, which you can withdraw at any time without affecting earlier processing (KVKK Art. 5/1; Law No. 6563; GDPR Art. 6(1)(a)).

We do not make decisions about you by automated means alone, and we do not sell personal data.

5. Who we share it with

Only the data each recipient needs, for the purposes above:

• the Turkish universities you choose to apply to, and the application systems they use;
• Turkish public authorities, such as Turkish consulates, the Ministry of Foreign Affairs, the Presidency of Migration Management and the Council of Higher Education (YOK), when your visa, residence permit or diploma recognition requires it;
• certified translators and notaries, insurers and courier companies, when your file requires them;
• our IT service providers: hosting of this website, storage of forms and uploaded documents and delivery of form emails (Amazon Web Services, servers in Frankfurt, Germany), and our email provider;
• only with your consent, Google (Google Analytics and Google Tag Manager) and Microsoft (Clarity) for website statistics;
• Meta (WhatsApp), if you choose to contact us on WhatsApp, and Google (Maps), if you choose to load the map on our contact page;
• our legal and financial advisers, and courts or authorities where the law requires.

6. Transfers abroad

Some of these recipients are located outside Türkiye (for example our hosting provider in Germany, Google, Microsoft and Meta), and you may yourself be abroad when you contact us. Personal data is transferred abroad only in line with KVKK Article 9 (as amended by Law No. 7499): on the basis of an adequacy decision, appropriate safeguards such as standard contracts notified to the Personal Data Protection Authority, or, for incidental transfers, one of the exceptions in Article 9/6, including your explicit consent. Transfers out of the EEA follow Chapter V of the GDPR.

7. How long we keep it

• Enquiries and applications that do not lead to a service, including documents uploaded through this website: 2 years after our last contact.
• Client files and service records: for the duration of the service and then for the statutory limitation and record keeping periods (generally 10 years under the Turkish Commercial Code and the Turkish Code of Obligations).
• Accounting and tax records: the periods set by commercial and tax law.
• Server and error logs: about one month, unless needed to investigate a security incident.
• Records of notices acknowledged and consents given: as long as the related processing continues, then for the limitation period.
• Marketing preferences: until you withdraw your consent, then as proof of the withdrawal.

When a period ends, or the reason for processing no longer exists, we delete, destroy or anonymise the data under the Regulation on the Deletion, Destruction or Anonymisation of Personal Data, at the latest in the next periodic destruction cycle.

8. How we protect it

Encrypted connections (HTTPS) for every page and form; uploaded documents stored in a private storage area that is never public and is reached only through short-lived signed links; access limited to the advisors who work on your file; confidentiality obligations for staff and service providers; and reputable providers bound by data protection terms. If personal data is obtained by others unlawfully, we notify the Personal Data Protection Board within 72 hours and the persons concerned as soon as possible.

9. Your rights

Under KVKK Article 11 you have the right to: learn whether your personal data is processed; request information about it; learn the purpose of processing and whether it is used accordingly; know the third parties in Türkiye or abroad to whom it is transferred; request correction of incomplete or inaccurate data; request deletion or destruction under Article 7; request that third parties to whom data was transferred are notified of a correction or deletion; object to a result against you arising exclusively from automated analysis; and claim compensation for damage caused by unlawful processing.

If the GDPR applies to you, you also have the rights of access, rectification, erasure, restriction, data portability and objection, the right to withdraw consent at any time, and the right to lodge a complaint with your supervisory authority.

10. How to apply

Use our data subject application form and send it in writing to the address in section 1, by email to contact@university.com.tr from the email address you gave us, with a secure electronic or mobile signature, or by registered electronic mail (KEP). We reply free of charge within 30 days at the latest (a fee under the Board's tariff may apply only if the reply involves an extra cost). If you are not satisfied with the reply, or receive none in time, you may complain to the Personal Data Protection Board (www.kvkk.gov.tr) within the periods in KVKK Article 14.

To stop receiving updates, reply "stop" to any message, use the unsubscribe link in our emails, or write to contact@university.com.tr.

11. Applicants under 18

Many students apply to university before they turn 18. If you are under 18, please involve a parent or legal guardian: we may ask for their contact details, and for their approval before any service agreement is signed.

12. Versions and changes

We may update this notice; the date of the current version is shown at the top of this page. The Turkish version is the prevailing text: KVKK Aydınlatma Metni.