Rustem Eyuboglu Egitim Kurumları A.S and Eyuboglu Egitim Kurumları Confidentiality Policy and Enlightenment Text

The Law No. 6698 on Protection of Personal Data, which was prepared as based on article no. 20 of the Constitution of Republic of Turkey, has entered into the force by being published in the Official Gazette No: 29677, dated April 7th, 2016. According to the mandatory provisions of both our constitution and the Law No 6698 on Protection of Personal Data, everybody is entitled to ask for the protection of the personal data related to himself / herself.

Primarily, we wish you to know that as Rustem Eyuboglu Egitim Kurumları A.S and Eyuboglu Egitim Kurumları, which is owner of Rustem Eyuboglu Egitim Kurumları A.S, we show maximum care and sensitivity on the matter of security of the personal data.

According to the law No. 6698 on Protection of Personal Data, our institution has the capacity of “Data Supervisor”.

In this context, with our capacity of Data Supervisor and as conscious of our aforesaid sense of responsibilities, the personal data, that belongs to our esteemed parents, guardians, students, graduates, employees, guests and all other persons, who have relation with our institution, is processed and kept in the manners for the purposes and scopes, mentioned below in accordance with the principles and procedures, specified in the Law No. 6698 on Protection of Personal Data (KVKK) and other relevant legislation.

1 - General Principles Dominate The Processing of Personal Data

As Rustem Eyuboglu Egitim Kurumları A.S. and Eyuboglu Egitim Kurumları, the processing of personal data is realized according to the article no. 4 of KVVK and in accordance with the following basic principles;

1. Being in compliance with the law and regulations of good faith,
2. Being accurate and updated when it is required,
3. Being processed for specific, clear and legal purposes,
4. Being related, restricted and measured with the purpose, they are processed for,
5. Being kept as much as the period, required the purpose, they have been processed or for the period, anticipated in the relevant legislation.

2 - The Processed Personal Data

Although they may differ pursuant to your relation with our institution, your personal data, which is processed by our institution within scope of the KVKK No: 6698 and relevant legislation, covers name & surname, address, telephone number, e-mail address, date of birth, place of birth, T.R. Identity Number, occupation, marital status, communication information, vehicle plate information, your images, which have been obtained from security camera records, your personal data, shared during the applications, you made online from our institution’s internet web site, your IP address, information shared in accordance with the agreement, you have signed or will sign with our institution and other personal information. The aforesaid personal data of yours is processed in a restricted manner related to the following purposes and transmitted within frame of the conditions, specified in article no 8 and 9 of KVKK.

Your personal data is collected through the schools, departments, units, alumni association, internet website, social media applications of our institution and similar other means in written, electronically or verbally with automatic and non-automatic methods. In the same manner, your personal data may also be collected during the visits you will make to our schools or institution or when you attend the various events, which are organized in our schools.

3 - The Purposes of Processing of Your Personal Data

Your personal data will be processed for carrying out the service policies and activities of our institution regularly and completely; to manage the relation between our students, parents, guardians, graduates and our school; to increase our service quality more by reviewing and assessing the statistical results, that will be obtained from the collected information; to communicate and to maintain communication with our students, parents, guardians and graduates; monitoring and carrying out human resources processes of our employees and candidates who will make job application to our institution, using them in accounting transactions, which are required in accordance with the legislation; to make investigations and to provide legal and commercial security to the persons, who will communicate with our institution; developing and forming infrastructure of current information technology system; reviewing and developing of our institution’s service policies and providing of information security; carrying out the liabilities, arising from the legislation and similar other purposes in accordance with the terms and purposes, mentioned in article no 5 and 6 of KVKK.

4 - Transmission of Personal Data

Our institution will be able to transmit your personal data to other Eyuboglu companies, such as EYB Holding A.S., Ebitek Iletisim ve Teknoloji A.S., Ebitas Insaat A.S., EYB Invest A.S. and/or Burcak Rustem Eyuboglu Saglık ve Egitim Vakfı, and/or other institution in the country, our business partners, to the real and legal persons, that give service to our institution or gets service from our institution by taking necessary measures in line with the relevant arrangement of KVKK and taking into the consideration of the relations between the parties and characteristics of the information, which will be transmitted.

5 - Transmission of the Personal Data Within Scope of Remote Education Services and/or Online (remote) Exam, Interview Applications

In case it is required or in the event of mandatory circumstances, our Institution is able to give remote education service via programs/applications such as Google Meet, Google Classroom, Google Forms, Adobe Connect and/or to make online (remote) exam, interview application. In this case, the personal data of yours and/or the student, of whom you are acting as his/her guardian or the relevant persons, who take part in the application, is processed by our institution and transmitted to out of the country via remote access programs/applications of Google Meet, Google Classroom, Google Forms, Adobe Connect etc. During this period, our institution acts within frame of the terms and conditions, anticipated in article no 9 of KVKK and necessary measures and security measures are taken by our institutions.

In this context, we hereby present to your information that all kind of audio, image, video etc. records, that will be obtained with the applications, such as Google Meet, Google Classroom, Google Forms, Adobe Connect etc. are in the characteristic of personal data and they will be used in the process of remote education and/or live course broadcasting and/or exam, interview applications by our teachers, who use exam, interview application and make live course broadcasting, our employees during these online education (remote) and/or live course broadcasting and/or exam, interview applications. Furthermore, we hereby present to your information with this Enlightenment Text that these audio, image and course recitation, which are in the characteristic of personal data, are required to be kept within scope of KVKK and from the angle of Intellectual Property Rights, thus the applications of online (remote) live course broadcasting, exam and interview must never be recorded in any manner by you and/or shared in any media and/or they must not be brought into as form, where third persons will be able to reach; you are required to take care and pay attention to the personal information and intellectual property that belongs to our institution, acting contrary to this provision will be considered as violation of personal data security and/or intellectual rights and cause serious sanctions within frame of Personal Data Protection law and legislation related to the foregoing issues.

6 - Rights of Personal Data Owners

In accordance with article no 11 of KVKK, you may use your rights, listed below by applying to our institution with your capacity of personal data owner. According to this, the persons, whose data have been processed, have the right of;

1. Learning whether the personal data has been processed or not,
2. Request information related to the personal data if they have been processed,
3. Learning the purpose of processing of personal data and whether they have been used in accordance with their purpose or not,
4. Knowing the third persons in and abroad, whom the personal data has been processed,
5. In case of incomplete or wrong processing of the personal data, requesting their correction,
6. Despite of the fact that the personal data has been processed according to the provisions of the law and other legislation, asking them to be deleted or destroyed,
7. Asking the transactions, which will be made in accordance with the foregoing paragraphs e and f, to be informed to the third persons, whom the personal data has been transferred,
8. Objecting to the results, which will be arising against him/her for the reason of analysing of the personal data through automatic systems
9. Claiming his/her damages to be compensated in the event of misprocessing of the personal data or processing of it contrary to the law.

For the purpose of using your rights, you may forward your request to our institution in written or in other methods, which are specified in KVKK and/or determined by Personal Data Protection Council. You may deliver your petition with wet signature, in which your request is stated, by hand in person or send it to our institution’s address, mentioned below with a registered mail. In the same way, you may apply to our institution with an email, which has been signed in a competent manner. According to the characteristic of the request, your application will be finalised latest within 30 days.

7 - Security and Retention Period of Personal Data

In case the purpose, which requires your personal data to be processed, is eliminated and/or time-out/retention periods, we are obliged to process your data in accordance with the legislation, are expired, your personal data will be deleted or brought into the form anonymous.

Our institution, as Data Supervisor has taken all necessary technical and administrative measures in the scope of security in order to safeguard the personal data in the most convenient manner and to prevent any illegal access to them in accordance with article no 12 of KVKK and uses antivirus and firewall software and hardware for the security of the data.

Data Supervisor	:	RUSTEM EYUBOGLU EGITIM KURUMLARI A.S.
Mersis Number	:	0735089869100001
Web Site	:	www.eyuboglu.k12.tr
E-Mail Address	:	kvkk@eyuboglu.k12.tr
Communication Address	:	Esenevler Mah. Dr. Rustem Eyuboglu Sok. No: 8 Umraniye/ISTANBUL
Telephone	:	+90 216 522 12 12

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• Address Confirmation Certificate (It may be obtained from the address of www.turkiye.gov.tr with the E-State password),
• Certificate of Identity Register Copy (It may be obtained from the address of www.turkiye.gov.tr with the E-State password in the form where all family is displayed by clicking all family option),
• Certificate of Good Conduct (It may be obtained from the address of www.turkiye.gov.tr with the E-State password by clicking Official Institution Option),
• Our employees, who will go under the military service, are required to inform their status to our Human Resources department with Military Draft Card (SILUS),
• Private Health Insurance Form is sent to our employees by our Human Resources Department. In case the Private Insurance Form is not completed fully and correct or not delivered on the specified date, our employees are not covered with the health insurance.
• Minimum Living Allowance Form must be completed by the Employee and it must be renewed in the event of marriage, divorce or having children. The employees, who will not complete the form or don’t inform the changes, as described above, will not benefit from the right of Minimum Living Allowance.
• In case the employee is married; a copy of the marriage certificate, renewed identity card copy, address confirmation certificate, certificate of identity register copy are forwarded to Human Resources Department.
• In case the employee is divorced; renewed identity card copy, address confirmation certificate, certificate of identity register copy are forwarded to Human Resources Department.