LEEXT has adopted the principle of protecting the privacy of visitors to its website.

In this context, LEEXT takes all necessary measures and actions to ensure compliance with the provisions of the Law No. 6698, decisions of the Board, and, to the extent applicable, the GDPR provisions to ensure the lawful processing of personal data.

We aim to inform you about the types of information LEEXT processes about users and how this information is used. We will also inform you about your rights as data subjects and how you can exercise them.

Any changes to this Privacy Policy and the Cookie Policy, which is part of this agreement, will be published on this page, allowing you to stay updated on what information is stored and how it is used.

This Privacy Policy and the Cookie Policy, part of this agreement, do not apply to other websites linked from the Leext site.

How Your Personal Data Can Be Processed

Under Law No. 6698, your personal data shared with leext.com can be processed fully or partially automatically, or non-automatically as part of any data recording system, by being collected, stored, modified, reorganized, and subjected to various processing operations. All operations performed on data within the scope of KVKK are considered as "processing of personal data."

Purposes and Legal Reasons for Processing Your Personal Data

Your personal data is processed for:

• Fulfilling the requirements of the services provided to our customers in a manner compatible with the obligations of the contract and technology, and improving our products and services;

• Conducting and managing the tests you have engaged with, entered, or developed;

• Ensuring the appropriate use of our platform and other technological services and optimizing their functions;

• Enhancing the effectiveness of our platform, testing, monitoring, and diagnosing or fixing technology issues;

• Assisting in efficient access to your information after logging in and reminding your information so that you won't need to re-enter it during or on subsequent visits to the Platform;

• Providing information to prosecutors, courts, and relevant public officials on matters related to public safety and legal disputes upon request and as required by law;

• Offering a wide range of opportunities to our members or sharing them legally with persons or organizations that can provide these opportunities;

• Analyzing advertising preferences.

  
  

All processing will be in accordance with the KVKK and related secondary regulations.

Third Parties or Organizations to Which Your Personal Data May Be Transferred

Your personal data shared with leext.com for the above purposes may be transferred to our main shareholders, advertisers, direct or indirect domestic/international affiliates, member companies using leext.com infrastructure, and other individuals and organizations related to the service provided, as well as third parties and organizations, including those from whom we receive services and with whom we collaborate as Data Processors, both domestically and internationally.

Our regulations regarding cookies used for advertising purposes are detailed in the "leext.com Cookie Policy," which forms part of this "Privacy and Personal Data Protection Policy" you are currently reading. For information about our Cookie Policy, please click here. (A link to the cookie policy example can be found at the bottom of this document)

Collection Method of Your Personal Data

Your personal data can be collected through:

• Forms on the leext.com website and mobile applications, including information such as name, surname, address, telephone, business or private email address;

• Pages accessed using a username and password, preferences made, transaction IP records, cookie data collected by the browser, data including browsing time and details, and location data;

• Face-to-face or remotely in a physical or virtual environment, verbally or in writing, or through electronic means from individuals who share their personal data with leext.com for purposes such as establishing a commercial relationship, applying for a job, making an offer;

• Indirectly through different channels, data obtained from websites, blogs, competitions, surveys, games, campaigns, and similar activities (micro) websites and social media, including data from publicly available databases, social media platforms (Facebook, Twitter, Google, Instagram, Snapchat, etc.), shared profile and data from social sharing sites, e-newsletter reading or click movements.

  
  

Transfer of Your Personal Data

Personal data collected through any of the above-listed methods, processed in Turkey or processed and stored abroad, may be transferred to service intermediaries abroad (countries accredited by the Personal Data Protection Board as having adequate protection for personal data) within the scope of KVKK and in accordance with contract purposes.may

Your personal data may be transferred for the following purposes:

• To collaborate with our business partners who assist in providing and promoting our products and services;

• To share the information of Exam Participants with customers who administer the tests;

• To share feedback from Test Participants and customers regarding the tests with the subject matter experts who created these tests;

• To authorized bodies capable of determining your location in case of an emergency call;

• To regulatory and supervisory institutions, courts, and enforcement directorates, as well as other public institutions authorized to request personal data;

• To legal entities in commercial relations with leext.com and who have your phone number, when deemed necessary.

  
  

Storage and Protection of Personal Data

Leext.com is obligated to take necessary software measures such as hashing, encryption, transaction logging, access management, as well as physical security measures to prevent unlawful processing of and unauthorized access to the personal data stored in its systems and databases, in accordance with Article 12 of the KVKK. Should personal data be acquired by others through illegal means, the situation will be reported to the Personal Data Protection Board promptly and in compliance with legal regulations.

Duration of Personal Data Storage

Generally, leext.com stores your personal data only for as long as necessary to provide services on our Platform. The storage duration for exam participant data (e.g., name, email address, and exam scores) provided to customers is 1 year. Webcam images taken as anti-cheating measures are stored for 6 months. Video recordings of exam participants responding to specific questions are stored for 1 year.

Accuracy and Up-to-dateness of Personal Data

According to Article 4 of the KVKK, leext.com is responsible for keeping your personal data accurate and up-to-date. Therefore, members are required to share accurate and updated data or update their information via the website/mobile application to enable leext.com to fulfill its obligations under the current legislation.

Rights of Personal Data Subject Under KVKK

As of October 7, 2016, when Article 11 of the KVKK came into effect, Personal Data Subjects have the following rights:

• To inquire if personal data has been processed;

• To request information if personal data has been processed;

• To know the purpose of processing personal data and whether it is used accordingly;

• To know the third parties to whom personal data is transferred domestically or abroad;

• To request correction of personal data if processed incompletely or inaccurately;

• To request deletion or destruction of personal data under the conditions set forth in Article 7 of KVKK;

• To request notification of the operations made per the correction, deletion, or destruction of personal data to third parties to whom personal data has been transferred;

• To object to any adverse outcome resulting from the analysis of the processed data solely through automated systems;

• To claim compensation for damages resulting from the unlawful processing of personal data.

  
  

Rights of Personal Data Subject Under GDPR

Personal Data Subjects have rights to:

• Know if personal data is being processed;

• Request information if personal data has been processed;

• Obtain a copy of personal data and certain other information;

• Request correction of incorrect or incomplete personal data;

• Request deletion or destruction of personal data under certain conditions;

• Request restriction of processing of certain personal data;

• Obtain a copy of personal data provided to Leext in a structured, commonly used, and machine-readable format, or request the transfer of personal data to another party, under certain conditions;

• Object to processing based on legitimate interest or the interest of a third party;

• Withdraw consent where personal data is processed based on consent;

• Object to any adverse outcomes resulting from exclusively automated processing of data;

• Claim compensation for damages resulting from unlawful processing of personal data.

  
  

Personal Data Subjects also have the right to lodge a complaint with a data protection authority in the European Union member state of their habitual residence or where the alleged infringement of data protection laws has occurred.

Communication and Application Method

The Data Controller Representative appointed by leext.com will be announced on the Data Controllers Registry and the website address where this document is located once the legal infrastructure is provided.

Personal Data Subjects can direct their questions, opinions, or requests to the email address info@leext.com.

Leext.com may respond to the submitted requests in writing or digitally within 30 days, positively or negatively, with justification. While the processing of requests is primarily free of charge, leext.com reserves the right to charge a fee if the process incurs a cost. These fees will be determined based on the tariff set by the Personal Data Protection Board in accordance with Article 13 of the Personal Data Protection Law.

By sharing your personal data on our web pages, applications, and other channels, you acknowledge and consent to the processing, methods of processing, transfer, and sale of your data, and other related matters as outlined in our Personal Data Policy, to the benefit of our members and may be shared with third parties for commercial purposes. You declare your explicit consent, defined as informed consent based on specific subjects of significant importance under the KVKK, expressed freely, before exercising your legal rights and making an application to leext.com.