1. General terms
The current Policy of personal data processing is made in accordance with the requirements of Turkish law and defines an order of processing of personal data and measures on the safety of personal data of Agora International Agency IT Services Limited Company (Legal address: Osmanağa mah. General Asım Gündüz caddesi, Bahariye apt. No:15, iç kapı No:2 Kadıköy, Istanbul, Turkey. Tax/Company Number: 0091660681), which is the right holder of the Application (further - the Operator).
1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of human and citizen's rights and freedoms in the processing of their personal data, including the protection of rights to privacy, personal and family secrets.
1.2. This Operator's Policy on personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors of the Website: https://mentorhd.com/ .
2. The basic concepts used in this Policy
2.1. Automated processing of personal data means the processing of personal data using a computer;
2.2. Blocking of personal data means temporary termination of processing of personal data (except in cases when processing is necessary to clarify personal data);
2.3. The Website means a set of graphic and information materials, as well as computer programs and databases that make them available on the Internet at the address https://mentorhd.com/ ;
2.4. The Application means a mobile application "Mental Mentor" aimed for smartphones working under iOS or Android operating systems. The Application is developed and administered by the Operator. With the help of this Application, the User can listen to affirmations. The Application is used by the User in interactive (online) mode by connecting the User to the World Wide Web. The Operator is the copyright holder of the Application and all its elements, both separately and in aggregate.
2.5 The Information system of personal data means a set of personal data stored in databases and ensuring their processing by information technologies and technical means;
2.6. Depersonalization of personal data means actions that lead to the inability to determine the identification of a particular user or other personal data entity without the use of additional information.
2.7. Processing of personal data means any action (operation) or set of actions (operations) made with or without the use of automation techniques with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
2.8. The Operator means a state authority, municipal authority, legal or physical person, independently or together with other persons organizing and (or) carrying out the processing of personal data, and also defining purposes of personal data processing, the structure of personal data that is a subject to processing, actions (operations) made with personal data;
2.9. Personal data means any information related directly or indirectly to the determined or determinable users of the Website https://mentorhd.com/ and the "Mental mentor" mobile application;
2.10. The User means any visitor of https://mentorhd.com/ or a person who has installed "Mental Mentor" mobile application on their device;
2.11. Provision of personal data means actions aimed at disclosure of personal data to a particular person or a particular circle of persons;
2.12. Dissemination of personal data means any actions directed on disclosing of personal data to an indefinite circle of persons (transfer of personal data) or on familiarisation with personal data of an unlimited circle of persons, including disclosing of personal data in mass media, making it available in information-telecommunication networks or making it available in any other way;
2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign authority, foreign physical or foreign legal entity;
2.14. Destruction of personal data means any actions that results in irretrievable destruction of personal data with the impossibility of further restoration of the personal data content in the information system and/or that results in the destruction of storage with personal data.
3. The Operator can process the following personal data of the User:
3.1. Last name, first name, patronymic name;
3.3. City of residence;
3.4. Date of birth;
3.6. The Application and the Website use third-party services that may collect information about users in accordance with their data processing policies:
3.7. All the data mentioned above is consolidated below in the text of the Policy by a common concept of Personal Data.
4. Purposes of personal data processing
4.1. The purpose of processing the User's personal data (such as full name, e-mail, phone number) is to inform the User by e-mail; conclude, execute and terminate civil law contracts; grant the User access to the services, provide information and/or materials from the Website or the Application.
4.2. The Operator is also entitled to send the User notifications about new products and services, special offers, and various events using personal data: full name and e-mail. The User can always refuse to receive information messages by sending an e-mail to the Operator's address [email protected], marked "I refuse all notifications about new products, services, and special offers".
4.3. Depersonalized users' data, collected with the help of Internet-statistics services, is used to gather information about Users' actions on the Website and in the Application, as well as to improve the quality of the Website and the Application and their content.
4.4. The processing of the User's personal data (such as phone number and e-mail) is performed to create a user account, which is necessary to identificate the User's information uploaded in the Application and the possibility of the User accessing his/her account when changing the mobile device.
4.5.Processing of such personal data of the User as full name, date of birth, city, and answers to test questions is necessary to recommend the content within the Application for the User.
4.6.The application requests access to the microphone and speech recognition function to expose the full functionality of the Application. Speech recognition takes place on the User's device. The Application neither process nor sends this data to developers.
4.7.The Application may request access to notifications to inform the User about new products, services, special offers, and various events.
4.8.The application requests permission to access IDFA to improve the Application and optimize advertising materials.
5. Legal grounds for personal data processing
5.1. The Operator processes personal data of the User only in case it is filled in and/or sent by the User through special forms located at https://mentorhd.com/ and in the mobile application "Mental Mentor". By filling in the corresponding forms and/or sending the personal data to the Operator, the User expresses their consent to this Policy.
6. Procedure for collection, storage, transfer and other types of personal data processing
6.1. The safety of personal data, which is processed by the Operator, is provided by the realization of the legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
6.2. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
6.3. The User's personal data will never, under any circumstances, be passed on to third parties, with the exception of cases related to compliance with existing legislation.
6.4. In case of inaccuracies in personal data, the User can update it independently by sending a notice to the Operator's e-mail address [email protected] with the note "Updating of personal data".
6.5. The period of personal data processing is unlimited. The User can, at any time, withdraw their consent to the processing of personal data by sending a notice to the Operator by e-mail at [email protected] with the note "Withdrawal of consent to the processing of my personal data".
7. Deletion of personal data
7.1.The period of personal data processing is unlimited. The User may withdraw his/her consent to the processing of personal data at any time by sending an e-mail to the Operator's e-mail address [email protected] marked "Withdrawal of consent for the processing of personal data". The User can also delete his/her account and all related personal data by clicking the "Delete account" button in the application settings. Once this button is clicked, all personal data of the User specified in chapter 3 of this agreement will be deleted from the database completely and permanently.
8. Cross-border transfer of personal data
8.1. Before the beginning of the transboundary transfer of personal data, the Operator is obliged to make sure that the foreign state, on which territory it is supposed to carry out a transfer of the personal data, provides reliable protection of the rights of personal data subjects.
8.2. Cross-border transfer of personal data on the territory of foreign countries that do not meet the above requirements may be carried out only if the subject of personal data has agreed in writing to the cross-border transfer of their personal data and/or execution of the contract, to which the subject of personal data is a party.
9. Final provisions
9.1. The User can get any explanations on the questions concerning the processing of their personal data by contacting the Operator by e-mail [email protected] .
9.2. This document will reflect any changes in the Operator's personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.
9.3. The current version of the current Policy is available on the Internet at https://mentorhd.com/ .