EXPLANATION AND PRIVACY POLICY ON
‘PROTECTION OF PERSONAL DATA’



Basic information on the protection of personal data transferred to ‘Online Egitim, Video ve Oyun Teknolojileri Ticaret Limited Sirketi’ (‘Hi e-learning & Online Portal’) is given below. Hi e-learning & Online Portal presents the following explanations to the attention of our customers and third parties who use our website and / or mobile applications in order to fulfil the disclosure obligation arising from Article 10 of the Personal Data Protection Law No. 6698 (‘KVKK’). Hi e-learning & Online Portal reserves the right to update this Statement on the Protection of Personal Data at any time within the framework of changes that may be made in the legislation in force.

If you have created a membership to the Hi e-learning APP or portal with the Sign up method. You can cancel your membership at any time and the information you have entered for membership to Hi e-learning application will be permanently deleted by Online Education, Video and Game Technologies Trade Limited Company (‘Hi e-learning & Online Portal’). In order to cancel your membership, if you send an e-mail to the e-mail address ‘info@hielearning.com’ with the subject ‘Membership cancellation’ and send your username you want to delete, your membership will be deleted within 24 hours.

1) What is the legal basis for Hi e-learning & Online Portal to collect personal data?
There are regulations in various laws on the use of personal data of our customers. First and foremost, the principles of protection of personal data are determined by the KVKK. In addition, the Law No. 6563 on the Regulation of Electronic Commerce also contains provisions on the protection of personal data. The Turkish Penal Code No. 5237 also stipulates criminal sanctions in some cases for the protection of personal data. On the other hand, data must be collected and used in order to fulfil our obligations arising from the Law No. 6502 on Consumer Protection and the Regulation on Distance Contracts.

2) Which methods does Hi e-learning & Online Portal use to collect personal data? The data provided by our customers who make transactions from the www.onlineportali.com website or mobile applications are processed by Hi e-learning & Online Portal in accordance with the consent of our customers and the provisions of the legislation. The website www.onlineportali.com belonging to Hi e-learning & Online Portal is a website that uses cookies. Cookie; It is a file consisting mostly of letters and numbers, which is stored in the internet browser or hard disc of the device being used, allowing the device in question to be detected. In order to provide better service to its visitors and within the framework of its legal obligation, www.onlineportali.com will collect, process, share with third parties and securely store your browsing information, provided that it is not used outside the purposes and scope specified in this Statement on the Protection of Personal Data. www.onlineportali.com stores information collected through cookies; log files, empty gif files and/or third party sources in order to create a summary of your preferences. www.onlineportali.com may monitor your browsing information on the site and/or your usage history on the site in order to provide you with special promotions, promotions and marketing offers, to improve the content of the website or mobile application according to you and/or to determine your preferences. www.onlineportali.com may match information collected from you on the site by different methods or at different times, such as information collected online and offline, and may use this information together with information from other sources such as third parties. www.onlineportali.com uses session cookies and persistent cookies in its mobile application. The session ID cookie expires when you close your browser. The persistent cookie, on the other hand, remains on your hard disc for a long time. You can remove persistent cookies and reject both session cookies and persistent cookies by following the instructions provided in the ‘help’ file of your internet browser or by visiting ‘www.allaboutcookies.org’ or ‘www.youronlinechoices.eu’. If you reject persistent cookies or session cookies, you may continue to use the website, mobile application, but you may not be able to access all functions of the website, mobile application or your access may be limited.

3) How are Website Cookies Used? The website www.onlineportali.com belonging to Hi e-learning & Online Portal is a website that uses cookies. Cookie; It is a file consisting mostly of letters and numbers, which is stored in the internet browser or hard disc of the device being used, allowing the device in question to be detected. www.onlineportali.com stores the information it collects through cookies; log files, empty gif files and/or third party sources in order to create a summary of your preferences. We use two types of cookies across our sites: session cookies and persistent cookies. Session cookies are temporary cookies and are only valid until you close your browser. Persistent cookies remain on your hard drive until you delete them or until they expire (how long cookies remain on your device will depend on their ‘lifetime’). www.onlineportali.com uses cookies to remember your preferences and to personalise your use of the website/mobile application. This use includes cookies that save your password and keep your website/mobile application session open continuously, thus saving you the trouble of entering your password more than once on each visit, and cookies that remember and recognise you on subsequent visits to the website/mobile application. www.onlineportali.com uses cookies to determine how you use the website/mobile application, including measuring how you use the website/mobile application, such as where you connect to the website, what content you view on the website/mobile application and the duration of your visit. www.onlineportali.com website may also use cookies to activate ‘advertising technology’ in order to provide you with advertisements that it thinks may be of interest to you when you visit search engines, website, mobile application and/or websites where the website advertises. The advertising technology uses information about your previous visits to the website/mobile application and the websites/mobile applications advertised by the website in order to provide you with customised advertisements. When serving these adverts, a unique third party cookie may be placed on your browser so that the website can recognise you. Hi e-learning & Online Portal also uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies to analyse how users use the website, mobile application and/or mobile site with statistical information/reports. For more information about the use of Google Analytics (including opt-out options), you can visit: http://www.google.com/intl/tr/policies/privacy/#infocollect In the mobile application, the SDK (Software Development Kit) of the relevant application is used instead of cookies. You can use the following methods to allow and reject cookies:
Google Chrome : You can allow or block cookies from the ‘Cookies’ tab by clicking the ‘lock sign’ in the address section of your browser.
Internet Explorer : You can manage cookies as ‘allow’ or ‘disallow’ by clicking the security tab from the ‘Tools’ section in the upper right corner of your browser.
Mozilla Firefox : Click the ‘open menu’ tab in the upper right corner of your browser. You can manage cookies using the ‘Privacy and Security’ button by clicking the ‘Options’ image.
Opera : You can manage cookies from the ‘Cookies’ section by selecting ‘Advanced’ in the ‘Preferences’ section of your browser.
Safari : You can select the ‘safari’ tab from the ‘Settings’ section of your phone and make all your cookie management from the ‘Privacy and Security’ section.
In addition to the above options; to have information about all cookies and for cookie management: https://www.allaboutcookies.org, https://www.youronlinechoices.eu/, or you can use the ‘Privacy Badger’ application (https://www.eff.org/tr/privacybadger). If you refuse persistent cookies or session cookies, you can continue to use the website, mobile application and mobile site, but you may not be able to access all functions of the website, mobile application and mobile site or your access may be limited. Information about the cookies on Hi e-learning & Online Portal is given in the tables below:
Cookie Service Provider Cookie Name Cookie Purpose Cookie Type Cookie Duration
Google _ga Analytics device information - for use by applications in the Google Tag Manager system Persistent Cookie 2 Years
Google _gaexp Cookie that holds information about EU tests - for use by applications in the Google Tag Manager system Persistent Cookie 85 Days
Google _gid For user identification Persistent 1 Day
Yandex _ym_isad For ad blocking detection Persistent Cookie 2 Days
Yandex _ym_uid For identifying users Persistent Cookie 1 Year
Hi e-learning & Online Portalı AbTesting The value used for A/B Test management is stored in this cookie. Persistent Cookie 2 Years
Hi e-learning & Online Portalı AbTestingCookies The values used for Multiple A/B Test management are stored in this cookie. Persistent Cookie 2 Years
Hi e-learning & Online Portalı COOKIE_CookieLawInformationPermission The permissions of our personal data policies are stored in this cookie. Non Persistent Cookie During the browser session duration
Hi e-learning & Online Portalı COOKIE_Popup Technical data about the popups shown to the user are stored in this cookie. Persistent Cookie 1 Hour
Hi e-learning & Online Portalı COOKIE_TY.Entrance It is the cookie where the information of the logged in user is stored. Persistent Cookie 1 Month
Hi e-learning & Online Portalı COOKIE_TY.FirstVisit It is the cookie where the user's first visit information is stored. Persistent Cookie 1 Month
Hi e-learning & Online Portalı COOKIE_TY.UserAlreadyLogged It is the cookie that stores the information whether the user is already logged in or not. Non Persistent Cookie During the browser session duration
Hi e-learning & Online Portalı COOKIE_uic It is the cookie where the demographic information of the logged in user without access token is stored. Persistent Cookie 30 Minutes
Hi e-learning & Online Portalı COOKIE_UserAlreadyLogged It is the cookie that stores the information whether the user is already logged in or not. Non Persistent Cookie During the browser session duration
Hi e-learning & Online Portalı COOKIE_UserTypeStatus It is the cookie where the status of the users is stored. Persistent Cookie 12 Hours
Hi e-learning & Online Portalı hvtb It provides information on whether a user has visited the Hi e-learning & Online Portal before. Persistent Cookie 2 Years
Hi e-learning & Online Portalı pid It is the cookie where the ID given to the user is stored permanently. Persistent Cookie 1 Year 354 Days
Hi e-learning & Online Portalı sid It is the cookie where the session ID value of the user is stored. Persistent Cookie 30 Minutes
Hi e-learning & Online Portalı SiteHash It is the cookie where the hash information of the cookies is stored. Persistent Cookie 7 Days
Hi e-learning & Online Portalı VisitorTypeStatus It is the cookie where the status of visitors is stored. Persistent Cookie During the browser session duration
Qualaroo ki_r The referrer cookie that the person landed on the site comes from document.referrer. Persistent Cookie 5 Years
Qualaroo ki_t It is the cookie that contains survey timestamps and view counts. Persistent Cookie 5 Years
Hi e-learning & Online Portalı NSC_QDJUFTU-IUUQT-XXX.USFOEZPM.DPN It is the cookied where sticky session information is stored in order to proceed through the same session in all groups in Netscaler. Session Cookie During the browser session duration
Marketing utmCampaign30dtemp2 Keep user visit channel log information for 30 days Persistent Cookie 1 Month
Marketing utmCampaignGO5d Keep user visit channel registration information for 5 days for affiliate campaigns Persistent Cookie 5 Days
Marketing utmCampaignLT30d To keep user visit channel record information for 3 months Persistent Cookie 1 Month
Marketing utmMedium30dtemp2 Keep user visit channel log information for 30 days Persistent Cookie 1 Month
Marketing utmMediumGO5d Keep user visit channel registration information for 5 days for affiliate campaigns Persistent Cookie 5 Days
Marketing utmSource30dtemp2 Keep user visit channel log information for 30 days Persistent Cookie 1 Month
Marketing utmSourceGO5d Keep user visit channel registration information for 5 days for affiliate campaigns Persistent Cookie 5 Days


4) For what purposes does Hi e-learning & Online Portal use personal data? Hi e-learning & Online Portal may record, store, update, disclose to third parties, transfer, classify and process your personal data where and to the extent permitted by the legislation. Your personal data is used for the following purposes: • To verify the identity information of the shopper / shopper via the website / mobile applications, • to record the address and other necessary information for contact, • To communicate with our customers regarding the conditions, current status and updates of the contracts we have concluded under the distance sales contract and the relevant articles of the Law on the Protection of Consumers and to provide the necessary information, • To organise all records and documents that will be the basis of the transaction in electronic (internet/mobile etc.) or paper environment, • To fulfil the obligations undertaken in accordance with the distance sales contract and the contracts we have concluded under the relevant articles of the Law on Consumer Protection, • To be able to provide information to public officials on matters related to public security upon request and in accordance with the legislation, • To provide our customers with a better shopping experience, to be able to inform our customers about our products that our customers may be interested in ‘taking into account the interests of our customers’, to convey campaigns, • To increase customer satisfaction, to be able to recognise our customers who shop from the website and/or mobile applications and to use them in customer environment analysis, to use them in various marketing and advertising activities and to organise surveys in electronic environment and/or physical environment through contracted organisations in this context, • To be able to offer suggestions to our customers by our contracted institutions and solution partners and to inform our customers about our services, • To be able to evaluate customer complaints and suggestions about our services, • To fulfil our legal obligations and to exercise our rights arising from the legislation in force.

5) How does Hi e-learning & Online Portal protect your personal data? Personal data shared with Hi e-learning & Online Portal are under the supervision and control of Hi e-learning & Online Portal. Hi e-learning & Online Portal has assumed the responsibility as data controller to establish the necessary organisation and to take and adapt technical measures in order to protect the confidentiality and integrity of information in accordance with the provisions of the relevant legislation in force. Being aware of our obligation in this regard, we periodically carry out penetration tests in accordance with international and national technical standards on data confidentiality and we would like to inform you that we always update our data processing policies in this context.

6) Does Hi e-learning & Online Portal share your personal data? The sharing of personal data of our customers with third parties is carried out within the framework of the consent of the customers and as a rule, personal data are not transferred to third parties without the consent of our customers. However, personal data are shared with courts and other public institutions due to and limited to our legal obligations. In addition, personal data is transferred to contracted third parties in order to provide the services we undertake and to control the quality of the services provided. Necessary technical and legal measures are taken to prevent violations of rights during data transfer to third parties. However, Hi e-learning & Online Portal is not responsible for violations that occur due to the data protection policies of the third party receiving personal data and in the risk area under the responsibility of the third party. Your personal data may be shared with the shareholders of Hi e-learning & Online Portal, our direct/indirect domestic/foreign affiliates, program partner institutions and organisations with which we cooperate in order to carry out our activities, domestic/foreign persons and institutions from which we receive data storage services in cloud environment, domestic/foreign institutions and organisations with which we have an agreement to send commercial electronic messages to our customers, It may be shared with the Interbank Card Centre, the banks with which we have an agreement and with various agencies, advertising companies and survey companies in Turkey and abroad and other third parties in Turkey and abroad and our related business partners within the scope of various marketing activities in order to provide you with better service and customer satisfaction.

7) What are your rights arising from the Law on the Protection of Personal Data? Pursuant to KVKK, your personal data; a. a) To learn whether your personal data are processed or not, b. b) request information if processed, c. c) to learn the purpose of processing and whether it is used in accordance with its purpose, d. d) Knowing the third parties to whom it is transferred domestically / abroad, e. e) request correction if incomplete / incorrectly processed, f. f) To request deletion / destruction within the framework of the conditions stipulated in Article 7 of the KVKK, g. g) to request notification of the transactions made in accordance with subparagraphs (d) and (e) above to the third parties to whom it is transferred, h. h) object to the occurrence of a result to your detriment due to analysis exclusively by automated systems, i. i) We would like to remind you that you have the right to demand the compensation of the damage in case you suffer damage due to processing in violation of KVKK. j. j) Click here for the application form.

8) How can I be informed about legislative changes related to personal data? The rights you have in accordance with KVKK are the obligations of Hi e-learning & Online Portal. We would like to inform you that we process your personal data with this awareness and to the extent required by the legislation, that in case of legal changes, we will update this information on our page in accordance with the new legislation, and that you can always easily follow the updates made on this page.

9) How can I ensure that the data is kept up to date and accurate? Pursuant to Article 4 of the KVKK, Hi e-learning & Online Portal has the obligation to keep your personal data accurate and up-to-date. In this context, in order for Hi e-learning & Online Portal to fulfil its obligations arising from the legislation in force, our customers are required to share their accurate and up-to-date data on Hi e-learning & Online Portal. In case your data changes in any way, we kindly ask you to update your data by contacting us via the following communication channels.

10) Would you like to ask Hi e-learning & Online Portal questions about your personal data? You can contact us at any time at info@hielearning.com for any questions and comments regarding your personal data.