PRIVACY POLICY

CLARIFICATION TEXT AS PER THE LAW NR. 6698 ON PROTECTION OF PERSONAL DATA

This clarification text is prepared to fulfill the clarification obligation of PDI-ER ULUSLARARASI ÖZEL EĞİTİM HİZMETLERİ TİCARET ANONİM ŞİRKETİ (Hereinafter referred to as “Data Officer” or “Company) in accordance with the article 10 of the Law No. 6698 on Protection of Personal Data (Hereinafter referred to as “KVKK”)   with the title of data controller.

The current companies / organizations associated with PDI-ER ULUSLARARASI ÖZEL EĞİTİM HİZMETLERİ TİCARET ANONİM ŞİRKETİ are listed below:

-Özel Sarıyer British International School (Zekeriyaköy Mahallesi Kilyos Caddesi No: 227/1-2 Sarıyer )

-Özel Beş İklim Sevgi İlkokulu (Zekeriyaköy Mahallesi Göktürk caddesi No: 6 Sarıyer )

-Özel İstanbul British International School (Etiler Mahallesi Tuğcular Sokak No: 27, Etiler )

-Maslak Headquarters (Büyükdere Caddesi Maslak Meydan Sokak Spring Giz Plaza Kat: 5 No: 29/B Maslak Sarıyer )

-Department of Accountant (Büyükdere Mahallesi Karaorman Sokak No:5 Da:2 Sarıyer)

In accordance with the provisions of the Personal Data Protection Law No. 6698, the following personal datas which will be transferred by real persons, will be saved in the company’s database.

A-RECORD OF THE DATA CONTROLLER

TITLE: PDI-ER ULUSLARARASI ÖZEL EĞİTİM HİZMETLERİ TİCARET ANONİM ŞİRKETİ
MERSIS NO: 0760004783200018
ADDRESS: Maslak Mah. Büyükdere Cad. Spring Giz Plaza K:5 Sarıyer, İstanbul
PHONE: 0212 286 69 50
FAX: 0212 286 69 80
E-MAIL:  [email protected]

B-PERSONAL DATAS

Personal data is defined as; “Any kind of data relating to an identified or identifiable natural person”.

All data are collected and/or processed within the scope of education and training services provided by PDI-ER ULUSLARARASI ÖZEL EĞİTİM HİZMETLERİ TİCARET ANONİM ŞİRKETİ are; names, surnames, signatures, photos, T.C ID number, other informations on T.C ID card of our students, teachers, board of trustees and board of directors, staff, student parents / guardians, subcontractors, suppliers and their workers; passport informations, address informations and phone numbers etc. for foreigns and student numbers, informations on primary education and diploma, bank and account information regarding payment of tuition fees, payment informations, payment receipts, notes given to student during the education, projects and assignments during the education, presentations, club works and social, artistic & sporting activities, photos on websites, all kind of tests, results and rankings required for further education, medical datas of the student that the Company is obliged to collect under the applicable legislation; information on the occupational and social-economic status of parents/guardians, contact information (address, phone, fax and e-mail address); voices and images recorded by the cameras, ID informations and/or the fingerprints for entrance.

C- GENERAL PRINCIPLES REGARDING THE PROCESSING OF PERSONAL DATA

Personal datas are processed by our company with the title of data controller, in accordance with the principles stated in article 4 of Law No. 6698 on the Protection of Personal Data listed below;

- Processing for actual, specific, clear and legitimate purposes, when necessary,

- Compliance with the law and the rules of honesty,

- Being engaged, limited and restrained for the purpose they are committed,

- Preservation for the period required by the relevant legislation or for the purpose for which they are processed

D-PURPOSES OF DATA PROCESSING

Personal datas collected to date or to be collected in accordance with the articles 5 and 6 of the Law No. 6698 on the Protection of Personal Data are to be processed for the purposes both stated in the legislation and for the following or similar purposes;

a. Personal Datas of Students and Legal Representatives:

Necessary informations on name-surname, Turkish ID No., Passport No. for foreigners, contact informations, photos of the students are being collected in order for the registration. Informations on name-surname, Turkish ID No., Passport No. for foreigners, contact informations, bank account informations, and informations on the other children of the legal representatives of students are also being collected.

b. Fingerprints and Images of Cameras

Images and sounds are being recorded by cameras as well as fingerprints are collected in order for maintaining the security of the institutions and students, checking the entrances and the exits of buildings and facilities, increasing the staff productivity and detecting the working conditions, proving the work relationship and reducing the human traffic during entrance and exits. Our institution provides the option to enter with the card for whom does not want tos hare his/her fingerprint. It is sufficient and necessary for you to apply to our company with the documents which detecting your identity and a written and signed petition.

c.Personal Datas of Visitors:

For security purposes, name and surnames, ID/passport/driving license numbers, entrance and exit times and information on visited person are being collected and saved.

d. Personal Datas of Employees:

Personal datas of the employees are being collected fort he purposes of evaluation of the candidates, invitation for job interview, creation of the personal file, fulfilling the obligations arising from Turkish Labour Law, Social Security Law, Turkish Code of Obligations, Turkish Commercial Law and other legislation, proving of the work relationship, using the claiming and defending rights effectively during a possible trial process.

e. Datas Received within the Scope of Service and / or Commercial Business Relationship:

For the purposes of proving the contracts and providing security of services; name and surnames, Tr. ID numbers, passport numbers, circulars of signature, contact informations, title/division, qualification certificate, information on the membership to chamber of commerce, financial informations of the parties, representatives and other relevant persons who has a business relationship with our school such as puchase of goods and services.

E. OTHER DATAS

The company processes your personal data, including, but not limited to:

- In order to fulfill the requirements of the Ministry of National Education legislation,

-In order to provide information in emergency situations,

-In order to carry out student transactions,

- Giving information about the meetings, interview days and events organized in our schools,

- Carrying out discounts, activities, advertising and promotional activities related to the services of the Company and providing information on these issues,

- Fulfill its commercial, financial, legal and administrative obligations and activities with public and private institutions and organizations,

- Giving information to the staff and health institutions for students with allergies or diseases that need to be followed, taking and photographing the students so that they can be easily detected in an emergency,

- Informing the data owner about the issues requested by her/him and responding to his complaints and notifications,

F- COLLECTION, PROCESSING AND TRANSFER OF YOUR PERSONAL DATAS

Your personal data may vary depending on the service, product or business activity provided by our

Company and it may be also collected automatic or non-automatic methods, written, verbal or electronically by means of campuses and all affiliated business units of our institution, our website, social media accounts, integration systems, complementary or extension of the activities of our school, the parties receive services, contracted organizations, business partners, suppliers and others.

Your personal data shall be transferred to business associates, teachers, instructors, suppliers, shareholders of our Company; legally authorized public bodies and natural person for the purposes of; customizing and recommending products and services provided by our Company according to your likes, usage habits and needs; ensuring legal and commercial security of our Company and persons in business relationship with our Company; enabling necessary operations carried out by our business units in order to make you benefit from products and services offered by our Company; ensuring to continuity of our Company policy. Your personal data will be transferred anonymously and transferred abroad. Confidentiality agreements are made with real and legal persons for all data transferred

Your personal data, which is covered by the legislation and must be kept indefinitely, will be kept by the company indefinitely. All your personal data, except those that need to be kept indefinitely, will be deleted within 1 (one) year of your communication with our institution.

According to Article 5 of the KVKK, your personal data shall be processed by our Company acting its capacity as the Data Controller without further seeking your express consent in the event that:

•It is expressly permitted by any law;

•It is necessary for the protection of life or bodily integrity of a person himself/herself, or of

someone else, who is unable to express his/her consent due to actual impossibility or whose

consent is not legally recognized.

•It is necessary to process the personal data of parties of a contract, provided that the processing is directly related to the execution or performance of the contract;

•It is necessary for compliance with a legal obligation which Company is subject to;

•The relevant information is revealed to the public by the data subject herself/himself;

•It is necessary for the institution, usage, or protection of a right;

•It is necessary for the legitimate interests of the data controller, provided that the fundamental

rights and freedoms of the data subject are not harmed.

G- YOUR RIGHTS

Pursuant to Article 11 of the Law (KVKK), every personal data owner is entitled to:

a)To learn whether your personal data has been processed or not,

b)If personal data is processed, requesting information about it,

c)To learn the purpose of processing the personal data and whether they are used in accordance with their purpose,

ç)To know the third parties in which personal data is transmitted at home or abroad;

d)Requesting correction of personal data in case of incomplete or incorrect processing,

e) Ask for the deletion or destruction of your personal data as per the terms and conditions

f) Request that such third parties, to whom your personal data are transferred, are notified of the procedures carried out as per the paragraphs (d) and (e) above,

g)To challenge the emergence of a result against the individual by analyzing the processed data exclusively through automated systems,

ğ)Requesting to remedy the damages resulting from unlawful processing of personal data,

In case you make a written application to British International School İstanbul regarding your rights, your request will be answered free of charge maximum in 30 (thirty) days based on the nature of your request.

If you wish to exercise your rights as set forth in Article 11 of the Personal Data Protection Act, you must deliver your application, written clearly and comprehensibly, with wet-ink signature and along with documents of your identification and address, to Maslak, Büyükdere Cad. Meydan Sok. Spring Giz Plaza 30/A, 34398 Şişli/İstanbul by hand, by mail or through a notary.