Privacy Policy and KVKK Clarification Text

This Clarification Text has been prepared in accordance with the KVKK numbered 6698, for the platforms and field operations (interviews, surveys, etc.) operated by POLTEM AKADEMİ ARAŞTIRMA TEKNOLOJİ SAN. VE TİC. LTD. ŞTİ. ('Poltem Academy') located at Kılavuzlar Mah. 413. Sok. Karabük University Social Facility Block No: 8/33 Central/KARABÜK. Poltem Academy is registered with the VERBIS system and carries out its data processing processes within its legal responsibilities.

• Service Performance: Your data is processed in order to manage the technical infrastructure of research and field operations.
• Data Retention Period: Data is not 'indefinite'; it is kept for the period required by the purpose of processing or the legal retention periods stipulated in the relevant legislation. At the end of the period, the data is destroyed or anonymized in accordance with Article 7 of the KVKK.
• Artificial Intelligence and R&D: The use of data in the development of artificial intelligence models is subject to the separate explicit consent of the participant, independent of this clarification text.
• Commercial Communication: IYS (Message Management System) approval and commercial electronic message permission are separately obtained for personalized marketing activities.

• Audio, video and biometric data collected during interviews cannot be hidden within the clarification text in accordance with Article 6 of the KVKK.
• For the processing of this data, it is mandatory to obtain a separate, concrete explicit consent from the participant in written or electronic media, either in the field or in the digital environment.
• The participant merely 'starting the survey' does not constitute automatic approval for sensitive data.

Poltem Academy has the title of 'Joint Data Controller' together with the researcher in cases where it manages the field organization, participant matching and incentive distribution. In this context, Poltem Academy continues its legal responsibilities, limited to its own fault, even after the data is removed from the platform.

In case the data is kept in overseas-based infrastructures (Google, SurveyMonkey, etc.), in accordance with the 2024 amendment of the KVKK; one of the mechanisms of adequacy decision, standard contract or specific explicit consent for overseas transfer of the relevant data subject is operated.

• Data subjects can exercise their rights under KVKK Article 11 (deletion, correction, etc.) via info@poltemakademi.com.
• Reason for Rejection: Data deletion requests can only be rejected within the exceptions in KVKK Article 28. 'Trade secret' or 'research integrity' alone do not eliminate the legal right to delete.
• Anonymity Annotation: If the data has been anonymized, the deletion request technically cannot be met since it will fall outside the scope of the law in accordance with KVKK Article 28/1-a. This situation is reported to the participant at the very beginning.
• Right to Complain: Data subjects reserve the right to complain to the Personal Data Protection Board.

Poltem Academy takes the necessary technical and administrative measures in accordance with KVKK Article 12. The responsibility arising from personal data breaches cannot be limited to the service fee by contract in accordance with the mandatory rules of law (TCO 115 and KVKK 12); the principles of legal liability apply.

Data Controller Contact Person: Poltem Academy — info@poltemakademi.com | 0505 770 30 81. Kılavuzlar Mah. 413. Sok. Karabük University Social Facility Block No: 8/33 Center / KARABÜK