PRIVACY POLICY

This Privacy Policy document covers the types of information collected, recorded, stored, and disclosed through the Talker English application provided by Talker Eğitim Yazılım ve Bilgi Teknolojileri Pazarlama Tic. Ltd. Şti. ("Talker," "we," "our"). If you have any additional questions or need further information about our Privacy Policy, please contact us at [email protected].

Types of Personal Information Collected

Talker collects the minimum necessary personal information required for service provision, contract enforcement, user authentication, service improvement, new service development, membership registration, and consulting.

The user acknowledges that Talker is allowed to collect essential data required to perform the core functions of the service and optional personal information needed to provide more customized services.

If the user does not wish to consent to the collection of personal information, they may continue to use the service but may not be able to benefit from customized services.

Information from Social Media Platforms

When users log in with their social media accounts, Talker may obtain pseudonyms, social media IDs, email addresses, and profile pictures from the selected social media platforms.

Talker may collect the user's personal information as long as it complies with the policies and terms of each social media platform.

User-Generated Content

Talker stores content generated by users, voice recordings recorded during the use of sections involving speaking practice, and other relevant data. Users can access and request the deletion of this data in the application for the purpose of reviewing and tracking their learning progress.

Technical Specifications

While using mobile services, information such as device model, mobile network operator details, hardware ID, advertising ID, and usage statistics is automatically collected. However, these pieces of information cannot be used to identify or specify individual persons.

In case of issues related to the service or violations of user rights, Talker may collect the user's email address and phone number to resolve the issues or verify the user's account.

Purposes of Collection and Use of Personal Information

Talker uses the collected information for the following purposes:

• Ensuring users can fully benefit from the features of the service.
• Identifying users and preventing fraudulent usage.
• Compiling statistical data about service usage.
• Detecting and analyzing necessary service improvements.
• Notifying users of campaigns and events via email.
• Verifying the user's identity when a report is submitted to Talker or a question is asked.
• Providing important notifications when necessary.
• Monitoring and analyzing user behavior related to application usage.

Method of Collecting Personal Information

Talker collects personal information for the purpose of providing the service through the following methods:

• Directly from users during Talker membership registration and usage.
• Through the "information collection tools" created.
• Through written forms, faxes, phones, message boards, and emails.

The application uses third-party services that can collect user information:

• Firebase için Google Analytics
• Facebook Analytics

We may display ads using third-party technologies, and these technologies may collect usage information for advertising purposes. You can find the policies of these companies below:

• AdMob

Legal Bases for Data Processing

Talker processes personal data based on the following legal bases:

• For the performance of a contract (e.g., providing our service and responding to user requests).
• For legitimate and functional needs (e.g., analyzing user behavior related to application usage).
• With consent (e.g., providing updates or informing you about contests).

Sharing and Personal Information

In accordance with principles, Talker does not share personal information with external organizations without the user's prior consent. Exceptions will be made in the following cases:

• When the user has given consent for such sharing.
• When required by legal compliance.

Talker hosts the system operations necessary to provide the service on VULTR (The Constant Company, LLC.). You can review VULTR's Privacy Policy by clicking here.

Processing and Management of Personal Information

The collection and processing of personal information are carried out using computers and/or IT-enabled tools following organizational procedures and modes strictly related to the purposes indicated. In addition to Talker, in some cases, the data may be accessible to certain types of persons in charge, such as personnel involved with the operation of the application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as data processors by Talker.

Data is processed at Talker's operating offices and in any other places where the parties involved in the processing are located.

Data Transfer Outside the EU

Talker stores user data on servers located within the EU boundaries and, if necessary, transfers data to third countries (i.e., any country outside the EU) only in compliance with legal data transfer mechanisms. Users can contact Talker to learn which specific data transfer mechanism applies to which specific service.

User Rights and Application Practices

Users have the following rights regarding data processed by Talker:

• Withdrawal of consent: Users have the right to withdraw their consent to the processing of personal data if they have previously given their consent.
• Lodge a complaint: Users have the right to file a complaint with competent data protection authorities.
• Object to the processing of data: Users have the right to object to the processing of their data if it is processed based on a legal basis other than consent. If Talker processes personal information for public interest, the exercise of official authority granted to Talker, or for the purposes of legitimate interests pursued by Talker, users may object to such processing by providing a reason related to their particular situation.
• Access data: Users have the right to know whether Talker is processing their data, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the data being processed.
• Verification and correction request: Users have the right to verify the accuracy of their data and request it to be updated or corrected. When a user requests correction of an error in their personal information, the incorrect information will not be used until the correction is complete.
• Restriction of data processing: Users have the right, under certain circumstances, to restrict the processing of their data. In this case, Talker will not process the data for any purpose other than storage.

• Request for erasure or removal in other ways: Users have the right to request the erasure of their data under certain circumstances. Users can request the deletion of their account and data by clicking the link below.
  
  Click here to request account deletion.

• Right to receive data and data portability: Users have the right to receive their data in a structured, commonly used, and machine-readable format and, if technically feasible, have it transmitted to another controller. This provision is applicable provided that the data is processed by automated means and is based on the user's consent. Users can submit requests to download shared information through Talker's services by clicking the link below.
  
  Click here to request data portability.
  
  You can access the list of European supervisory authorities by clicking here.

Exercise of Rights

Requests to exercise these rights should be directed to the Data Protection Officer using the contact details provided in this document.

Retention and Use Period of Personal Information

Talker may retain personal information as long as the user has given consent for such processing and until such consent is withdrawn. Additionally, Talker may be required to retain personal information for a longer period due to legal obligations or upon the order of an authority.

In accordance with principles, Talker will erase the user's personal information securely, taking necessary security measures, once the purpose of collecting and using personal information is achieved. However, if it is necessary to retain personal information, it may be retained for the following periods:

• Records of contracts or subscription cancellations, etc.: Retained for 5 years.
• Payment records and supply of goods: Retained for 5 years.
• Consumer complaints or dispute resolution records: Retained for 3 years.
• Nicknames and profile pictures used for customer service transactions of exiting members: Retained for 3 months.

During the initial launch of the application on a device, Talker may collect the user's IP address. This is done to determine the language of the application interface shown to the user based on the geographical location detected from the IP address.

Data Destruction Procedure

Information entered by the user during the use of the service is securely destroyed after being stored for a certain period in accordance with internal policies and relevant laws.

Personal information is not used for any other purpose unless required by law.

Personal information on paper is shredded using a shredder, while personal information stored electronically is deleted using a technical method that does not allow records to be restored.

Technical Management and Protection of Personal Information

Questions, comments, and requests regarding this policy should be directed to the Data Protection Officer using the contact details provided below.

Talker Eğitim Yazılım ve Bilgi Teknolojileri Pazarlama Tic. Ltd. Şti.
Adres: Bahçelievler Mah. 319. Cad. No: 35 / 6 İç Kapı No: 312 Gölbaşı, Ankara, Türkiye
E-posta adresi: [email protected]

When processing users' personal information, Talker takes the following technical and administrative measures to prevent its loss, theft, leakage, alteration, or damage:

• Users' personal information is stored and managed through encryption via Secure Sockets Layer (SSL) communication systems. Passwords are stored in a one-way irreversible manner.
• Measures are taken to restrict external access to protect users' personal information from malicious attacks.
• Data is backed up daily to prevent the loss or damage of personal information. Current anti-virus software is used to prevent data leaks or damage, and the transmission of personal information over the network is secured via SSL communication.
• An intrusion prevention system is used to control unauthorized access from outside, and all possible technical devices are used systematically to ensure security.
• Limiting the number of personnel who process personal information reduces the risk of leaks.
• Regular training and seminars are provided for personnel who process personal information. They are educated on privacy obligations and security.

Privacy Policy Revisions

This Privacy Policy may be updated by Talker from time to time. We recommend that you review the Privacy Policy whenever you visit the platform to stay informed about our privacy practices.

This English version of the Privacy Policy is a translation based on the original Turkish version of the Privacy Policy with an adjustment for EU General Data Protection Regulation compliance. Between these two versions, the original Turkish version of the Privacy Policy shall prevail in the event of conflicts addressed in the Republic of Türkiye.

Last updated on December 19, 2023.