Privacy Policy and Data Protection Notice
What personal data we process, why and for how long, who else sees it, and how to exercise your rights.
Last updated:
Contents
1. Who controls your data
Under Turkish Law No. 6698 on the Protection of Personal Data ("KVKK"), Legal English TR acts as data controller and processes your personal data as described below.
- Data controller: Legal English TR — EKC Yazılım ve Teknoloji A.Ş.
- Address: Üniversite Mah. Sarıgül Sk. Istanbul Teknokent No: 37/1 Door No: 28, 34320 Avcılar / Istanbul, Türkiye
- Tax office / number: Avcılar Vergi Dairesi / 3260715403
- MERSIS: 0326071540300001 · Trade registry: 1159414 (İstanbul Ticaret Sicil Müdürlüğü)
- Registered email (KEP): ekcteknoloji@hs01.kep.tr
- Email: info@legalenglishtr.com · Phone: +90 545 477 97 70
This notice serves both as the disclosure required by Article 10 of the KVKK and as an explanation of how privacy works on https://legalenglishtr.com and in the Legal English TR mobile app (iOS and Android).
2. What data we process
We process only what we need to run the service. What applies to you depends on how you use it.
| Category | Data |
|---|---|
| Identity | Name, surname |
| Contact | Email address; a phone number if you give us one when writing in |
| Account and authentication | An irreversible hash of your password, session data, email verification and password reset records, your language preference (saved to your account in the mobile app) |
| Transactions | Order records, product purchased, amount, coupon, order date, invoice details (name and surname, company name for business purchases, Turkish ID or tax number, tax office, address and province, mobile phone), subscription status, trial and renewal dates, refund and cancellation requests |
| Payment | Transaction reference, amount, payment status and the last four digits of the card. Card number, expiry date and CVC are never seen or stored by us — they go straight into the payment service provider's system |
| Store purchases (mobile app) | Subscription product, purchase, renewal and cancellation dates, trial status, store transaction ID, store (App Store or Google Play), price and currency. Apple or Google takes the payment; your card details never reach us |
| Usage and progress | Which video lessons you watched, how far through and percentage completed, downloads of the study document and dictionary, certificate eligibility. Your flashcard progress in the mobile app stays on your device only |
| Security | IP address, sign-in and sign-out records, device and browser information, the random session ID given to a browser tab or device for the one-screen rule and concurrent session records, browser and device signals from the form check (Cloudflare Turnstile), the date, time, IP address and browser information of the consents you give at checkout, account deletion attempts |
| Advertising and device data (free version of the mobile app only) | Advertising ID (on iOS only if you allow it; on Android the advertising ID and app set ID), approximate location estimated from your IP address, device and app information, ads shown and clicked, crash and performance information. This data is collected by the Google AdMob software; Premium subscribers are not shown ads |
| Error records and visit counts | Records of software errors on the website and in the mobile app (type of error, the page or screen where it occurred, browser, device and version information; the IP address is not recorded) and cookie-free, aggregate view counts for the website's public pages |
We do not collect special categories of personal data. We never ask about health, beliefs or political views — please do not include such details in support messages.
3. Why we process it, and on what legal basis
| Purpose | Legal basis (KVKK Art. 5) |
|---|---|
| Creating your account, authentication, session management | Necessary for entering into and performing the contract |
| Opening access to what you bought; tracking access periods and subscriptions; verifying store subscriptions in the mobile app and linking them to your account | Performance of the contract |
| Taking payment, handling refunds and cancellations | Performance of the contract; legal obligation |
| Saving your progress through the videos (resume where you left off, certificate) | Performance of the contract |
| Sending transactional email | Performance of the contract |
| Invoicing, accounting and tax records | Legal obligation |
| Answering support requests, resolving complaints | Legitimate interest; establishing and defending legal claims |
| Preventing account sharing and piracy; enforcing the single-screen limit | Legitimate interest |
| Retaining the checkout consent and access records as evidence | Legal obligation; establishing and defending legal claims |
| Platform security, bot checks on forms, error detection, abuse prevention | Legitimate interest |
| Cookie-free, aggregate visit counting on the website's public pages (improving the site) | Legitimate interest |
| In the free version of the mobile app: showing non-personalised ads, limiting how often they appear, ad measurement and fraud prevention | Legitimate interest |
| In the mobile app: ads personalised to your interests and, on iOS, tracking across other companies' apps | Your explicit consent — withdrawable at any time (see section 7) |
We do not send commercial electronic messages for marketing (newsletters, promotions). If we start doing so, we will first ask for your consent as Turkish Law No. 6563 requires.
We do not carry out profiling or automated decision-making that produces adverse effects for you solely on the basis of automated analysis.
4. How we collect it
- What you type in when creating an account or placing an order
- Records the system generates as you use the Platform (sign-in logs, viewing progress, IP address)
- Transaction results returned by our payment service provider
- In the mobile app, purchase information from the app store where you bought and from our subscription infrastructure provider (RevenueCat)
- In the free version of the mobile app, advertising and device data that the Google AdMob software sends directly from your device to Google
- The security check on forms (Cloudflare Turnstile)
- What you tell us when you email us or use the contact form
- Browser storage and similar technologies (see section 7)
5. How long we keep it
We keep data for as long as the purpose requires and for the limitation periods set by law. When the period ends, data is deleted, destroyed or anonymised.
| Data | Retention |
|---|---|
| Account details (name, surname, email) | While your account is open; deleted immediately when you delete your account |
| Invoice details in our systems | While your account is open; deleted immediately when you delete your account. Invoices already issued remain with our e-invoicing provider and in the Revenue Administration's records for the period in the next row |
| Order, invoice and payment records | 10 years, under the Tax Procedure Law and the Turkish Commercial Code; if you delete your account, without your name and email address, under a random account ID |
| Raw payment notifications received from the payment institution and the app stores | 18 months (because of chargeback periods); cleared immediately if you delete your account, leaving only a summary without content |
| Withdrawal-right and document consents (version of the text accepted, date and time, IP address, browser information) | For the limitation period applying to consumer disputes (10 years) |
| Video progress, reading and download records | While your access lasts, plus one year (for certificates and support requests); deleted immediately if you delete your account |
| Sign-in and IP logs | One year, for security |
| Password attempts during account deletion | 90 days; the IP address is deleted immediately if you delete your account |
| Support correspondence | Three years after the request is closed |
Deleting your account: you can delete your account yourself on the website under My Account → Account & security, or in the mobile app under Settings → Account → Delete my account. Your profile, session data, video progress, reading and download records and the invoice details in our systems are deleted at once; records we must keep by law are kept for the periods above. Deleting your account does not cancel a subscription bought through the App Store or Google Play; you need to cancel that separately in your store account settings.
6. Who we share it with
We do not sell your personal data. To run the service we share the minimum necessary with the recipients below. Each transfer relies on the legal basis shown for the relevant purpose in section 3 (KVKK Art. 8). Our service providers process the data on our behalf and on our instructions; the payment institution, the bank, the app stores and Google (AdMob) also process it on their own behalf under their own regulations and policies.
Infrastructure, security and communication
| Recipient | Purpose | Data shared | Location | Retention |
|---|---|---|---|---|
| Supabase | Database, authentication, file storage and server functions; hosts our data on our behalf | Account, order, invoice details, access and progress data, consent and security records | Abroad — data centre in Germany (Frankfurt, EU) | The periods in section 5 |
| Netlify | Hosting the website and serving it to visitors | IP address, browser information and the address of the page requested (technical access logs) | Abroad — USA; content delivery network in several countries | The provider's technical log period; we keep no separate copy |
| Cloudflare (Turnstile) | Bot checks on the sign-in, sign-up, password reset and email verification forms, on the website and in the mobile app | IP address, browser and device signals, the result of the check | Abroad — USA; global network | The provider's period; we do not store the result of the check |
| Sentry (Functional Software, Inc.) | Recording and fixing software errors and crashes on the website and in the mobile app; measuring page and screen load times on a sample basis | Error record (type and message of the error, the page or screen and line of code where it occurred, app version), browser, device and operating system information, language. The IP address is anonymised and not recorded; your name, email address and account ID are not sent, and personal details in addresses are removed before sending | Abroad — data region Germany (EU); provider based in the USA | The provider's error retention period; we keep no separate copy |
| Umami (Umami Software, Inc.) | Cookie-free, aggregate visit counting on the website's public pages (which pages are viewed and how often). It does not run on account, payment, sign-in or admin pages or while you watch a lesson, and it is not used in the mobile app | The address of the page viewed (with the query string and personal details removed), the referring site, browser, operating system, device type, screen size, language and the approximate location (country) derived from the IP address. No cookies are used; the IP address is processed only transiently during the request and is not stored in the visit records; if your browser sends a 'Do Not Track' signal, no count is made | Abroad | Aggregate counts only; the provider's period |
| Bunny.net (Bunny Stream) | Hosting the video lessons and streaming them through time-limited access links | IP address, browser information, time-limited access token and playback technical logs; your name and email address are not passed on | Abroad — Slovenia (EU); delivery network in several countries | The provider's technical log period |
| Resend | Transactional email: account verification, password resets, order, subscription and invoice notices | Name, email address, the content of the email and its delivery status | Abroad — USA; sending infrastructure in Ireland (EU) | The provider's sending log period |
| Google (Google Workspace) | Our business email service: messages you send to info@legalenglishtr.com | Your email address and the content of the correspondence | Abroad — Google data centres | The period for support correspondence in section 5 |
Payment and invoicing
| Recipient | Purpose | Data shared | Location | Retention |
|---|---|---|---|---|
| iyzico Ödeme Hizmetleri A.Ş. | Taking payment for the Premium App subscription, storing the card and charging it on each renewal, 3D Secure checks, fraud prevention, refunds and chargebacks | Name and surname, email, mobile phone, billing address and province, Turkish ID or tax number, order details, IP address and browser information. Card details are entered directly into the payment institution's secure form and never reach us; to collect the payment the payment institution passes them to the card-issuing bank and the card schemes (Visa, Mastercard, Troy, American Express) | Türkiye | The period set by the payment institution's own regulations; a stored card is kept until the subscription is cancelled or the card is removed |
| Our partner bank (virtual POS) | Taking payment for the Training Set in one go or in instalments, 3D Secure checks and refunds | Order number and amount, instalment details, IP address; card details are entered on the bank's secure payment page and never reach us | Türkiye | The period set by the bank's own regulations |
| Paraşüt | Issuing the e-Archive invoice and keeping the accounting record | Name and surname or company name, Turkish ID or tax number, tax office, address and province, email, phone, product purchased and amount | Türkiye | Invoices: 10 years, under the Tax Procedure Law and the Turkish Commercial Code |
Mobile app
| Recipient | Purpose | Data shared | Location | Retention |
|---|---|---|---|---|
| Apple (App Store) and Google (Google Play) | In-app purchase, payment, automatic renewal, cancellation and refunds. For these purchases the store is the seller and takes the payment; the store processes the data on its own behalf | Purchase and subscription records and store transaction IDs (the store shares these with us and with RevenueCat). Your card details stay with the store and never reach us | Abroad | The store's own policy |
| RevenueCat | Verifying store subscriptions and linking access to your account | Your random account ID (your name and email address are not passed on), store transaction IDs, product, purchase, renewal and cancellation dates, trial status, price and currency, device and app information (platform, language, version), IP address | Abroad — USA | The subscription history is kept by the provider; deleting your account does not delete it automatically, and you can ask for it to be deleted in the ways described in section 9 |
| Google (AdMob) | In the free version only: showing ads, limiting how often they appear, ad measurement and fraud prevention. Google also processes this data on its own behalf and under its own privacy policy | Advertising ID (on iOS only if you allow it), IP address and the approximate location estimated from it, device and app information, ads shown and clicked, crash and performance information | Abroad — USA and Ireland (EU) | Google's own policy |
Public authorities and advisers
| Recipient | Purpose | Data shared | Location | Retention |
|---|---|---|---|---|
| Public authorities | Where required by law, including reporting e-Archive invoices to the Revenue Administration | Only what is requested and legally required | Türkiye | The period set by the relevant law |
| Accountants, lawyers and auditors | Accounting, legal matters and audit | Order and invoice records; in a dispute, the relevant correspondence and records | Türkiye | As long as the engagement requires and the law provides |
Transfers abroad: transfers to the recipients shown as "abroad" in the table are made under Article 9 of the KVKK and the Regulation on the Procedures and Principles for the Transfer of Personal Data Abroad. For our service providers, the safeguard we rely on is the standard contract published by the Personal Data Protection Board; a standard contract is notified to the Board within five business days of signing. The app stores and Google (AdMob) are independent data controllers processing the data on their own behalf; that processing is also subject to their privacy policies.
7. Cookies, on-device storage and ads
Our website uses no advertising or tracking cookies and writes no cookies to your device. There is no ad network or script that tracks you across sites; the two measurement tools that do run (cookie-free visit counting and error recording) are described at the end of this section.
The information the site needs in order to work is kept in your browser's storage (local storage and session storage) rather than in cookies:
- Your session: the session key that keeps you signed in after you log in; without it you would have to sign in again on every page. At sign-in we also save a short account summary (your name, email address and account type) and the time you signed in. If there is no activity for 30 minutes you are signed out for security and this information is deleted.
- Your language preference: remembers whether you chose Turkish or English.
- Your email address awaiting verification, and where to return: kept so that you do not have to type your address again on the verification page when you need to verify your email address. If you signed up while buying something or from another page, the address of that page and the product you chose are also kept, for up to 24 hours, so that you can return there after verifying.
- Video viewing ID: a random ID given to each browser tab to enforce the rule that one account can watch on one screen at a time. It is deleted when the tab is closed.
- Update marker: a temporary marker that makes sure an open page is reloaded only once when the site is updated. It is deleted when the tab is closed.
This information is used only to provide the service, never for advertising or profiling. The session key and the video viewing ID are sent to our servers while you use the site; the rest stays on your device only. Because they are strictly necessary, they need no separate consent. You can clear site data in your browser settings; if you do, you will be signed out and your language preference will be reset.
Subscription payment form: when you buy a subscription, the payment form prepared by the payment institution (including your name, e-mail address and phone number) is kept temporarily in this tab's storage while you move from the checkout page to the payment page. It is deleted when the payment page opens; if it does not open, it becomes unusable after 30 minutes at the latest.
Offer announcement: when an offer announcement is shown, the time it was shown is saved in your browser's storage so that the same announcement does not open again within 7 days; whether the offer and sales are currently open is also kept until the tab is closed. These records contain no personal information and are not sent to our servers.
On the sign-in, sign-up, password reset and email verification forms, the Cloudflare Turnstile security check runs to tell automated (bot) submissions apart. For the check, your IP address and technical signals about your browser are sent to Cloudflare (see section 6). It is used only to prevent abuse of those forms, never for advertising or tracking.
Video lessons play in Bunny.net's player, in a separate frame embedded in the page; to deliver the video the player receives your IP address and browser information.
Visit counting (Umami): on public pages, the cookie-free Umami counter runs to count, in aggregate, which pages are viewed and how often. It writes nothing to your device; it sends the address of the page viewed (with the query string and personal details removed), the referring site, browser, device type and language. Your IP address is processed only transiently during the request to determine your approximate location (country) and is not stored in the visit records. The counter does not run on account, payment, sign-in or admin pages or while you watch a lesson, and no count is made if your browser sends a "Do Not Track" signal (see section 6).
Error recording (Sentry): when a software error occurs on the site, the type of error, the page where it occurred and browser and device information are sent to Sentry; load times of some pages are also measured on a sample basis. Sentry writes no cookies or other information to your device. Your IP address is not recorded, and your name, email address and account ID are not sent. These records are used only to find and fix errors (see section 6).
Mobile app
In the mobile app, your session and app settings are kept in the app's storage on your device. Your flashcard progress (reviews, streaks, bookmarks) is stored only on your device and is not sent to us; your language preference is saved to your account. The sign-in and sign-up screens run the same Cloudflare Turnstile check as the website. Crashes and errors in the app are recorded with Sentry in the same way as on the website (no IP address, name or email is sent); the visit counter is not used in the app.
The free version of the mobile app shows ads; Premium subscribers see no ads. Ads are served by Google AdMob. To show ads, limit how often they appear, measure them and prevent fraud, the AdMob software sends Google your advertising ID, your IP address and the approximate location estimated from it, device and app information, and your interactions with ads (see sections 2 and 6).
Personalised ads are shown only with your consent. In the European Economic Area, the United Kingdom and Switzerland, the app shows Google's consent form during your first study session. On iOS you are also asked whether to allow the app to track you; if you do not allow it, your advertising identifier (IDFA) is not shared. If you have not given consent, or no consent form is offered where you are (including Türkiye), ads are shown without personalisation; even then Google may use device identifiers and your IP address to limit how often ads appear, to measure ads and to prevent fraud.
You can change your choices as follows:
iPhone and iPad: turn off tracking for the app under Settings → Privacy & Security → Tracking.
Android: reset or delete your advertising ID under Settings → Google → All services → Ads (menu names vary by device).
European Economic Area, United Kingdom and Switzerland: change or withdraw your consent in the app under Settings → Ad preferences.
8. How we protect it
- All traffic is encrypted with TLS/SSL; the site is served over HTTPS only.
- Passwords are never stored in plain text — only as an irreversible hash.
- Row-level access rules in the database mean each user can reach only their own records.
- Payment data is handled by a PCI-DSS compliant payment institution or bank, and for purchases in the mobile app by Apple or Google; card details never enter our systems.
- Videos are served through time-limited, account-bound access tokens; no directly downloadable link is ever issued.
- Access to admin tools is restricted by role and logged.
- In the event of a data breach we notify the Turkish Personal Data Protection Board and the individuals affected as soon as possible, as the KVKK requires.
9. Your rights
Article 11 of the KVKK gives you the right to:
- Learn whether your personal data is being processed
- Request information about it if it is
- Learn why it is processed and whether it is used for that purpose
- Know the third parties, in Türkiye or abroad, to whom it has been transferred
- Have incomplete or inaccurate data corrected
- Request deletion or destruction of your data under the conditions in Article 7 of the KVKK
- Have any correction, deletion or destruction notified to the third parties who received the data
- Object to an adverse outcome produced solely by automated analysis of your data
- Claim compensation for damage caused by unlawful processing
How to apply
Under the Communiqué on the Procedures and Principles of Applying to the Data Controller, you may apply in any of these ways:
- Email info@legalenglishtr.com from the address registered to your account
- Send it from your registered electronic mail (KEP) address to ekcteknoloji@hs01.kep.tr
- Email an application signed with a secure electronic signature or mobile signature to info@legalenglishtr.com
- Send or hand-deliver a signed written request to Üniversite Mah. Sarıgül Sk. Istanbul Teknokent No: 37/1 Door No: 28, 34320 Avcılar / Istanbul, Türkiye
Your application must be in Turkish and include your name and surname, your signature if it is in writing, your Turkish ID number (or, if you are a foreign national, your nationality and passport or ID number), your residential or business address for notifications, your email address and phone number if you have them, and what you are asking for. We respond as soon as possible and within 30 days at the latest, free of charge. Where the request involves an actual cost, the fee set by the Board may apply.
If your request is refused, our answer is inadequate or we do not respond in time, you may complain to the Personal Data Protection Board within 30 days of learning our response and in any event within 60 days of your application.
Some choices need no application: you can delete your account yourself as described in section 5, and withdraw your consent to ads in the mobile app in the ways described in section 7.
10. Children's data
The website and the mobile app are not directed at children; they are designed for adults who want to learn legal English. Purchases are made by people aged 18 and over. Anyone under 18 may open an account only with the consent and supervision of a parent or guardian. If we learn that a child's data has been processed without such consent, we delete it without delay. Please tell us at info@legalenglishtr.com if you believe that has happened.
Ads in the mobile app are limited to content suitable for a general audience.
11. Changes to this notice
We may update this notice as the law or the service changes. The current version is always published here and the "Last updated" date changes with it. Where our processing changes materially we email registered users, and where consent is required we ask for it again.
12. Contact
- Legal English TR — EKC Yazılım ve Teknoloji A.Ş.
- Address: Üniversite Mah. Sarıgül Sk. Istanbul Teknokent No: 37/1 Door No: 28, 34320 Avcılar / Istanbul, Türkiye
- Email: info@legalenglishtr.com
- Phone: +90 545 477 97 70
For purchase and refund terms see the Distance Sales Agreement and the Refund and Cancellation Policy; for platform rules see the Terms of Use.
Data controller contact: info@legalenglishtr.com · +90 545 477 97 70 · Üniversite Mah. Sarıgül Sk. Istanbul Teknokent No: 37/1 Door No: 28, 34320 Avcılar / Istanbul, Türkiye.
