Ensuring the security of the personal data you share while using the Educator Companion platform and processing such data in a lawful manner is one of the primary priorities of ORC Yayıncılık Reklamcılık ve Danış. Tic. Ltd. Şti. Through this Clarification Text, within the scope of the Turkish Personal Data Protection Law No. 6698 ("KVKK"), we aim to explain to you in a clear, understandable, and transparent manner:
which of your personal data are processed,
for what purposes these data are processed,
to whom and for what purposes your personal data may be transferred,
by which methods your personal data are collected and on which legal grounds they are processed, and
what your rights are in relation to your personal data.
Before moving on to the clarification text, we would like to briefly share with you some basic concepts set out below:
1. What is personal data?
Personal data means any information relating to you that identifies you or makes you identifiable. For example, your name, email address, user account information, information relating to your teacher profile, and certain records concerning your use of the platform may constitute personal data.
2. What does processing of personal data mean?
Processing of personal data refers to any operation performed on data, whether wholly or partly by automated means or by non-automated means provided that they form part of any data recording system, such as collection, recording, storage, retention, use, transfer, classification, updating, or deletion of personal data. For example, collecting your account information when you register on the platform, creating your teacher profile, entering class information, or keeping technical records relating to your use of the platform are all considered personal data processing activities.
3. Who is the data controller?
Under the KVKK, the data controller is the natural or legal person who determines the purposes and means of processing personal data. Within the scope of the Educator Companion platform, your personal data are processed by ORC Yayıncılık Reklamcılık ve Danış. Tic. Ltd. Şti., acting as the data controller.
Data Controller Information:
Data Controller
ORC Yayıncılık Reklamcılık ve Danış. Tic. Ltd. Şti.
Data Controller MERSIS Number
0645034893200015
Data Controller Address
Yakuplu Mah. Hürriyet Blv. Skyport Residence No:1 İç Kapı No:197, Beylikdüzü / Istanbul
Teacher Profile Data: Course information, class levels, curriculum frameworks, teaching approach/philosophy, and communication preferences.
Class Profile Data: Information relating to class name, number of students, academic level, language context, and teaching approach.
Basic Educational Data Relating to Students: Student name or nickname, gender, language proficiency, learning needs, and behavioral notes entered by you on the platform. Information directly identifying the student is not collected.
Special Categories of Personal Data Relating to Students: If entered by you on the platform, limited information with instructional impact relating to learning difficulties (for example, dyslexia), behavioral support notes, and special educational needs may be processed.
Uploaded Documents: Curriculum documents, rubrics, teaching guides, school policies, and other educational materials uploaded by you to PowerBase or similar sections.
Generated Content: Lesson plans, educational materials, assessments, teacher guidance materials, and other outputs created by the platform.
Usage Data: Login timestamps, feature usage patterns, platform usage records, technical logs, and conversation history.
Communication Data: Email address used for account notifications, password reset messages, and platform updates, as well as related service records.
3. Method of Collection of Your Personal Data
Your personal data are collected:
directly from you during your registration on the platform and creation of an account,
through your entry of information into profile, class, and setup screens,
through your entry of data into student support plans, class profiles, or PowerBase-like sections,
through your uploading of documents,
automatically by systems during your use of the platform,
within the scope of account notifications and platform communication processes.
4. Purposes and Legal Grounds for Processing Your Personal Data
Your personal data are processed for the following purposes and based on the legal grounds specified below:
4.1. Creation of an account, authentication, and management of the user account
Your account data are processed for the purposes of providing you access to the platform, carrying out login processes, and creating and managing your user account.
Legal ground: Processing of personal data of the parties to a contract is necessary, provided that it is directly related to the establishment or performance of a contract.
4.2. Creation of personalized educational materials suitable for your teacher profile
Your teacher profile data are processed in order to individualize and optimize AI-supported outputs in accordance with your teaching area, class level, and curriculum.
Legal ground: Processing of personal data of the parties to a contract is necessary, provided that it is directly related to the establishment or performance of a contract.
4.3. Creation of differentiated content at class level
Your class profile data are processed for the purpose of adapting AI outputs according to the class context, number of students, academic level, and teaching approach.
Legal ground: Processing of personal data of the parties to a contract is necessary, provided that it is directly related to the establishment or performance of a contract.
4.4. Production of inclusive and individualized educational materials
Basic educational data relating to students are processed for the purpose of creating differentiated and inclusive materials appropriate to the individual student or the class.
Legal ground: Processing of personal data of the parties to a contract is necessary, provided that it is directly related to the establishment or performance of a contract.
4.5. Processing of special category student support information
Special category data relating to students, such as learning difficulties, behavioral support notes, or information concerning special educational needs with instructional impact, may be processed for the purpose of creating educational outputs suitable for the student, such as visual organizers, scaffolding supports, and differentiated materials.
Legal ground: Explicit consent.
If such data are entered into the platform, explicit consent will be obtained from the relevant parties in a manner based on free will, with the relevant legal ground specified and all legal grounds explained. Otherwise, special categories of personal data will not be processed by us.
4.6. Processing of uploaded documents
Uploaded documents are processed in order to align AI outputs with the school curriculum, assessment criteria, and school policies.
Legal ground: Processing of personal data of the parties to a contract is necessary, provided that it is directly related to the establishment or performance of a contract.
4.7. Generation of content by the platform and saving it to your account
Generated content is processed in order to provide you with usable lesson plans, assessments, teacher guidance materials, and other educational materials.
Legal ground: Processing of personal data of the parties to a contract is necessary, provided that it is directly related to the establishment or performance of a contract.
4.8. Monitoring technical performance and improving user experience
Usage data are processed for the purposes of ensuring the reliability of the platform, monitoring technical performance, detecting errors, providing user support, and improving user experience.
Legal ground: Processing of data is necessary for the legitimate interests of the data controller.
4.9. Sending account notifications and platform updates
Your communication data are processed for the purposes of sending account notifications, password reset messages, and important service updates.
Legal ground: Processing of personal data of the parties to a contract is necessary, provided that it is directly related to the establishment or performance of a contract.
5. To Whom and for What Purposes Your Personal Data May Be Transferred
Your personal data may be transferred, on a limited basis, to the following recipients in order to fulfill the purposes set out above:
Anthropic (USA): for carrying out AI processing activities through the Claude API and for creating educational materials,
Supabase (USA / EU infrastructure): for carrying out database, storage, and authentication services,
Vercel (USA): for hosting and deployment of the platform,
Resend (USA): for sending account notifications and emails regarding platform updates.
Where necessary, your data may also be transferred to authorized public institutions and organizations for the purpose of fulfilling legal obligations or exercising/defending legal claims.
6. Transfer of Your Personal Data Abroad
Your personal data may be transferred to our domestic and international suppliers, service providers, and business partners within the framework of the conditions set forth in Articles 8 and 9 of the Law, for the purpose of fulfilling the purposes stated above and providing our services. In this context, your personal data may be transferred, on a limited basis, to the relevant service providers for purposes such as AI-supported content generation, provision of database and authentication services, hosting of the platform, operation of the technical infrastructure, maintenance and support processes, and sending account notifications and service-related emails. Since some of the service providers used within the scope of Educator Companion are located abroad, your personal data may be transferred, depending on the nature of the service used, particularly to the United States and, depending on the service infrastructure, to the European Union. International data transfers are carried out, where applicable, on the basis of an adequacy decision, appropriate safeguard mechanisms, or your explicit consent within the scope of Article 9 of the KVKK.
7. Retention Period
Your personal data are retained for as long as your platform account remains active and for as long as necessary for the relevant processing purpose. If you request deletion of your account, your personal data are, as a rule, deleted or anonymized within 30 days. Data transferred to Anthropic for AI processing are deleted within 7 days following the processing.
However, uploaded documents, generated content, technical logs, and communication records may be retained for different periods depending on operational requirements, security, legal obligations, and account management needs.
8. Teacher's Responsibility
The platform may generate teacher guidance materials. These guidance materials may contain student support information entered by you into the system. In contrast, it is essential that materials prepared to be shared with students do not contain personal data that would identify the student.
Before entering student data into the platform, the user is responsible for ensuring that the necessary school authorization, permissions, and, where applicable, explicit consent or other legal basis have been obtained. The user is also responsible for reviewing content to be shared with students and checking that it does not contain unnecessary personal data.
9. Your Rights as a Data Subject
Under Article 11 of the KVKK, you have the right to learn whether your personal data are processed, to request information if they have been processed, to learn the purpose of processing and whether they are used in accordance with that purpose, to know the third parties to whom they are transferred domestically or abroad, to request correction if they have been processed incompletely or inaccurately, to request deletion or destruction where the relevant conditions are met, and to exercise the other rights granted under the Law.
10. Application Method
If you have a request for information under the Personal Data Protection Law, you may contact us through the channels specified below, provided that your request contains the minimum elements required by law.
Application Method
Address for Application
In-person Application (application made in person by the data subject or his/her authorized representative, guardian/attorney)
Yakuplu Mah. Hürriyet Blv. Skyport Residence No:1 İç Kapı No:197, Beylikdüzü / Istanbul
Application via Notary Public
Yakuplu Mah. Hürriyet Blv. Skyport Residence No:1 İç Kapı No:197, Beylikdüzü / Istanbul
Application via Mobile Signature or E-mail by using the secure electronic mail address previously notified to the data controller by the data subject and registered in the data controller's system