Terms of Use

CLARIFICATION DOCUMENT WITHIN THE SCOPE OF THE LAW ON PROTECTION OF PERSONAL DATA

Multico Group Eğitim Danışmanlık Turizm Sanayi ve Ticaret Ltd. Şti. respect your privacy and care about your data security. Within this scope, this clarification document was prepared to inform you as per the Article 10 of the Law on Protection of Personal Data No. 6698 (hereinafter referred to as “Law”) and other related legislations. 

Our aim is to explain the principles that we adopted regarding processing of personal data and protection of personal data which are realized in accordance with the Law on Protection of Personal Data within the direction of our company’s activities, and within this scope to inform the persons whose personal data are processed by our company particularly student candidates, agencies, schools, universities and educational institutions, insurance and flight ticket companies, institutions and employees that we are in cooperation, clients and eligible third parties and to ensure transparency. 

Your personal data are electronically collected based on legal reasons which are stated in the Article 5 and 6 of the Law that are; drawing up or execution of an agreement, fulfillment of a legal obligation, it is proposed in the laws, the data is revealed by the related person, institution, usage and protection of a right, if it is necessary for the legitimate interest of the data controller provided that the fundamental rights and freedoms of the related person are not harmed, or the express consent of the data owner. Your personal data are processed in accordance with the principles stated in the Article 4 of the Law on Protection of Personal Data and conditions stated in the Article 5 and 6 of the Law.

1. IDENTITY OF THE DATA CONTROLLER

Your personal data can be processed by the Multico Group Eğitim Danışmanlık Turizm Sanayi ve Ticaret Ltd. Şti. (hereinafter referred to as “Company”, “Multico” or ”Data Controller”) with the title of data controller within the below-mentioned scope as per the Law on Protection of Personal Data no. 6698 (“Law”). Company Address: Multico Group Eğitim Danışmanlık Turizm Sanayi ve Ticaret Ltd. Şti., Barbaros District Akzambak Street Varyap Meridian A Block No: 287 Floor: 34 Ataşehir/ İstanbul.

2. THE PURPOSE OF PROCESSING PERSONAL DATA

Your personal data can be processed by MULTICO with the below-mentioned purposes:

• Realization of the necessary work with the related work units or if required business associates to propose to you services according to your consumption and purchasing motivation,
• Execution of the necessary operational activities within the company to provide you with the products and services,
• Providing rights of the natural persons by managing human resources by our Company, to take necessary steps for making, execution and realization of commercial decisions by our Company, providing legal safety for natural and legal entities that we form a business relation and our Company stemming from these relations,
•  Planning and execution of the access authorization of the business associates and suppliers, 
• Tracking of finance and accounting works,
• Planning and execution of realization of the effectiveness, efficiency and suitability analysis of the work activities,  
• Planning and execution of the business continuity activities, 
• Building a profile which is helpful to provide you with a more personalized service to fulfill your preferences, 
• To provide the content on our website in the most effective way for you and your computer, 
• To send you our newsletters or provide you with the information, products or services that are requested by you or that we think be of your interest and for which you accepted to be contacted for these purposes, and to allow you to join our service’s interactive features if selected,
• To inform you about the changes in our service,
• Planning, inspection and execution of information security procedures, 
• Building and management of information technologies infrastructure,
• To form subscription registries and accounts and keep the related records, 
• Realization of commercial activities done by Multico,
• Planning and execution of corporate communication activities,
• Planning and execution of logistic activities,
• Planning and execution of supply chain management procedures,
• To contact customer candidates or customers,
• Planning and execution of activity management,
• Planning and execution of corporate management activities,
• Planning and execution institutional sustainability activities,
• Tracking of agreement procedures and/or legal demands,
• Planning and execution of product and/or service sale procedures,
• Planning and execution of customer relationship management procedures,
• Planning and/or execution of after sales support services,
• Management of purchase and sale of goods and services and after sale procedures
• Execution of after sale support services for goods and services,Tracking and execution of legal procedures,
• Execution of customer satisfaction activities,
• Execution of marketing analysis,
• Execution of product and service development activities,
• Execution of advertisement/campaign/promotion procedures,
• Execution of communication activities,
• To fulfill legal obligations,
• Collecting and evaluation of customer complaints, demands and suggestions,
• Planning and execution of pro-sale additional services,
• Planning of loyalty and campaign management, and planning and/or execution of customer satisfaction activities.

3. SITUATIONS WHERE PERSONAL DATA MAY BE PROCESSED WITHOUT OBTAINING CONSENT

Your personal data can be processed without obtaining additional express consent under the below-mentioned situations by Multico Group Eğitim Danışmanlık Turizm Sanayi ve Ticaret Ltd. Şti. under the title of data controller: 

• It is necessary to protect the life or physical integrity of the person or others where the person physically incapable of giving consent or his consent has no legal validity,
• It is necessary to process the personal data of the parties of an agreement provided that the processing is directly related to the execution of the agreement, 
• It is necessary to comply with our legal obligations as the data controller,
• The data is revealed to the public by the related person himself.
• It is necessary to process the data for the institution, usage or protection of a right,
• It is necessary to process the data for the legitimate interest of the data controller provided that the fundamental rights and freedoms of the related person are not harmed. The personal data may be used for the below-listed purposes based on any of these conditions.

4. WHICH PERSONAL DATA WILL BE PROCESSED

Internet activities within the website of the people who visit MULTICO website are recorded (via technical means such as cookies) in order to show them personalized content and realize online advertisement activities. Detailed information regarding our company’s related activities are stated in Privacy Policy document on our website.  

Additionally, your personal data can be processed and collected;

• As contact information such as name surname, TR identity number, passport information, address, telephone, work or personal e-mail address that are shared by the user through our company’s website and mobile application forms for communication; activity information, IP records of the activities, cookies collected by the browser, data about the surfing time and details, location data in accordance with the preferences selected on the websites that are accessed by signing in with user name and password;  
• From verbal, written or electronic media through our channels such as sale and marketing employees, suppliers, other sale channels, on-paper forms, business cards, digital marketing and call center; 
• From business cards, CVs, sharing their personal data to submit an offer etc. for forming business relations with our firm, applying for a job, submitting an offer on physical or virtual media, in person or remotely, verbal or written or electronic media; 
• Additionally, from data taken indirectly from different channels, web sites, blogs, competition, survey, game, campaign and web sites (micro) that are used for similar purposes and social media, e-bulletin reading or clicking activities, data presented by the public data bases, public social media profiles and data; 
• From IP address and logs which are mandatory to be kept by the Law no. 5651

5. METHOD AND LEGAL BASIS FOR PROCESSING PERSONAL DATA

Processing of personal data means any operation which is performed upon personal data such as collection, recording, storage, preservation, alteration, adaptation, disclosure, transfer, retrieval, making available for collection, categorization or blocking its use by wholly or partly automatic means or non-automatic means which form part of a filing system.

Your personal data are collected through different channels and based on different legal basis by Multico Group Eğitim Danışmanlık Turizm Sanayi ve Ticaret Ltd. Şti. as the data collector in order to execute our commercial activities. Data are processed based on the legal reasons that are stated in the Article 5 of the Law no. 6698 and those reasons are drawing up and execution of an agreement, legal obligation of the data collector, express consent, data being made public by the related person, necessity to process personal data of the parties of an agreement.

• Your shared personal data will be processed in accordance with the Law no.6698 and related secondary regulation in order to
• Perform the requirements of the services that we offer to our customers in accordance with the requirements of the contract and technology, to develop our offered products and services; 
• Record the identity, address and other required information to determine the information about the person realizing the activities within the scope of Law no 6563 on Regulation of Electronic Commerce, Law no 6502 on Consumer Protection and the Regulation on E-Commerce Service Provider and Intermediary Service Providers issued in the Official Gazette dated 26.08.2015 and no. 29457 which was prepared as basis for these regulations, Regulation on Distant Contracts issued in the Official Gazette dated 27.11.2014 and no. 29188 and other related legislations;
• Prepare all records and documents which are the basis of payment systems required in the field of Banking and E-payment , electronic agreements or on-paper transactions, to abide by the information storage, reporting and informing obligations which are set forth by the legislations and other authorities;
• Provide information to the Prosecution Offices, Courts and related public officials about the issues regarding public safety and legal disputes on demand and as per the legislation.

6. TO WHOM AND HOW WILL YOUR PROCESSED DATA BE TRANSFERRED?

Your gathered personal data can be transferred to our business associates (legal entities that we have business relationship under a legal title), our suppliers, our shareholders, public institutions and legal entities authorized by the Law, the institution that you choose (either your choice of language schools or universities) after the first interview within the framework of the personal data processing conditions and purposes stated in the Article 8 and 9 of the Law on Protection of Personal Data in order to provide legal and commercial security to our Company and the people who are in a business relationship with our Company, to enable our work units to realize necessary works to offer you products and services presented by our Company, to offer you products and services presented by our company by personalizing them according to your likes, habit of use and needs, to determine and execute our company’s commercial and business strategies, and to execute our company’s human resources policies. For the above-mentioned purposes, persons and institutions to which your shared personal data may be transferred are business associates and other third parties including but not limited to particularly language school, university and other educational institutions that our company has a business relationship, foreign visa departments, airlines, accommodation firms.

7. RIGHTS OF THE DATA SUBJECT

Our Company will conclude your request without a fee as soon as possible and within the latest thirty days depending on your request’s eligibility if you submit your request regarding your rights as Personal Data Subject to our Company within the scope of the rights stated in the Article 11 of the Law on Protection of Personal Data using the methods drafted below in this Clarification Document. However, if the Board of Protection of Personal Data sets a fee, the fee on the tariff that is determined of our Company will be collected. Within this scope, the Personal Data Subjects have the right to;

• Learn whether or not his personal data have been processed,
• Request information as to processing if the personal data have been processed,
• Learn the purpose of processing of the personal data and whether data are used in accordance with their purpose,
• Know the third parties in the country or abroad to whom personal data have been transferred
• Request rectification in case personal data are processed incompletely or inaccurately and request notification of the operations made within this scope to third parties to whom personal data have been transferred,
• Request deletion or destruction of personal data even if the data was processed in accordance with the Law on Protection of Personal Data or other related provisions in case the reasons necessitating their processing cease to exist and request notification of the operations made within this scope to third parties to whom personal data have been transferred,
• Object to occurrence of any result that is to her/his detriment by means of analysis of personal data exclusively through automated systems,
• Request compensation for the damages in case the person incurs damages due to unlawful processing of personal data.

You may submit your request to our Company in writing to use the above-mentioned rights as per the Item 1 of Article 13 of the Law on Protection of Personal Data. Within this scope, means and methods to submit your written application to our Company within the scope of the Article 11 of the Law on Protection of Personal Data are stated below. 

In order to use above-mentioned rights, you can submit in person or via notary your statements regarding which right you would like to use among the rights stated in the Article 11 of the Law on Protection of Personal Data together with the necessary identification information and a signed copy to the address Multico Group Eğitim Danışmanlık Turizm Sanayi ve Ticaret Ltd. Şti., Barbaros Distrcit Akzambak Street Varyap Meridian A Block No: 287 Floor: 34 Ataşehir/ İstanbul.