REC EDU EĞİTİM HİZMETLERİ LTD. (“we”, “us”, “our” or “Rec-Tutors”) places great importance on safeguarding the privacy of every individual who visits our website at Rec-Tutors.com, as well as those who access our services through any mobile application (collectively referred to as the “Website”).

We encourage you to review the following privacy policy carefully, as it outlines how we handle and safeguard your personal data. The terms “you” and “your” refer to any user of our platform, whether you are a student or a tutor. Rec-Tutors acts as the data controller in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and Turkey’s Personal Data Protection Law No. 6698 (KVKK).

Please note that we may update this policy from time to time by publishing changes directly on our Website, without prior notification.

When you interact with the Rec-Tutors Platform or utilize the Payment Services, we collect certain personal data related to your usage patterns and the features you engage with.

Collecting this information is essential for us to fulfill our contractual obligations to you, to meet our legal responsibilities, and to serve our legitimate interest in operating, enhancing, and maintaining the quality and functionality of the Rec-Tutors Platform and its associated Payment Services.

1. Information That We Automatically Collect

Interaction Data: We gather details about how you engage with the Rec-Tutors Platform and mobile application. This includes the pages or materials you view, tutor searches, bookings made, exchanged messages, job postings, and other activities performed on the platform.

System Logs and Device Details: When you visit or interact with the Rec-Tutors Platform or App—regardless of whether you’ve registered or logged in—we automatically capture log and device data. This includes information such as how you’ve navigated the platform (e.g., clicking on third-party links), your IP address, the times and dates of access, your device and browser specifications, operating system details, crash reports, unique identifiers, cookie-related data, and the pages you accessed before and after using our services.

Cookies and Tracking Tools: Our platform and mobile app use cookies and similar tracking technologies when you browse, interact with ads, or open emails from us. These may include web beacons, tracking pixels, browser analytics, mobile identifiers, and server logs that automatically gather specific usage data.

Often, the data collected through these tools is aggregated or anonymized and does not directly identify you. For instance, we might analyze traffic flows and usage trends to enhance user experience. In some scenarios, the data collected may be linked to your personal profile. Additionally, our partners may use similar technologies on the Rec-Tutors Platform or on our behalf to monitor and analyze user behavior.

Location Data: If you use features that require location access, we may collect your exact or approximate location using sources like your IP address or your mobile device’s GPS. This helps us tailor your experience based on where you are. You can manage or disable location permissions through your device’s settings. In some cases, we may continue collecting location data in the background if your device or app permissions allow it.

Third-Party Pixels and SDKs: Third parties—such as Facebook—may deploy cookies, tracking pixels, and similar technologies to gather data from our website and other sources across the web. This information may be used to provide analytics or serve personalized advertisements. Mobile apps may also share data with such third parties for these purposes.

Ad Targeting Preferences: You can manage your preferences and opt out of targeted advertising by adjusting the ad settings within your Facebook account. You can also contact us at support@Rec-Tutors.com with a detailed request and verification information to further control data usage.

Do Not Track: While most browsers allow users to restrict cookie tracking, please note that the Rec-Tutors Platform currently does not respond to "Do Not Track" browser signals due to the lack of a consistent industry standard for interpreting such requests.

2. Information That We Collect

When you access our Website or book a lesson through it, we may request personal details such as your full name, residential address, and contact information.

If you’re using the Website as a Tutor, you may be required to upload identity verification documents. This could include a passport, driver’s license, or national identity card as well as your banking information for payment purposes.

Upon registering as a Tutor, we may request contact information for individuals who can act as references to verify your qualifications and appropriateness for tutoring through our platform.

As part of the Tutor registration process, we may also ask you to disclose any past criminal convictions.

If you’re acting as a reference for a Tutor, you may be asked to provide personal information including your name, address, contact details, and feedback regarding the Tutor’s suitability.

When a lesson is requested, we may collect your billing information, such as your credit or debit card number.

We may also gather information related to how you interact with the Website, including content from your messages—this can include messages to Tutors, uploaded files, and communications you’ve had with our team via email or SMS.

All online lessons conducted on our platform are recorded. We also store any files uploaded to the virtual classroom, as well as data related to your interactions during these sessions.

Technical information about how you use the Website is collected automatically. This may include details about your device and web browser, your IP address, time spent on the site, and the specific pages you’ve visited.

In certain situations, we may ask for your payment information such as a debit or credit card number. However, please note that all card processing is managed by a third-party provider. We do not store or handle payment card data directly and are not PCI compliant.

3. How we use your data

The information you provide helps us grant you access to the appropriate areas of the Website and deliver the services you’ve requested.

If you're a Student, we use your data to connect you with the Tutor you've reached out to, along with up to five additional Tutors who may be a good fit for your tuition needs. We also use your information to handle lesson payments and to get in touch with you when needed regarding our services.

If you're a Tutor, your identity verification documents allow us to comply with regulations such as Know Your Customer, Recruitment Agency laws, while your banking details enable us to process your earnings from completed lessons.

As a Tutor, we review your application to ensure your qualifications and background meet our tutoring standards and that you have the legal right to work.

If you've supplied contact details for references, we’ll reach out to those individuals to gather their feedback about your suitability to tutor on our platform.

If you’ve disclosed any criminal history during Tutor registration, we will verify those details through official government records.

Tutors using our platform may have their information—including name, address, date of birth, tax ID number, total earnings, and lesson counts—shared with the Revenue Administration Presidency (Gelir İdaresi Başkanlığı), in accordance with legal reporting requirements.

To optimize Student-Tutor matching, we may use automated systems to rank Tutors in search results. Ranking is based on several scoring criteria, which are visible in your Tutor dashboard. If your ranking falls below a certain level, your profile may be excluded from search results and access to new opportunities may be restricted. Additionally, inactive Tutor profiles may be automatically removed.

Your activity on the Website, including messages exchanged, helps us preserve your communication history and resolve any potential disputes that arise between Users.

If you send messages to other Users, we may monitor those messages to ensure personal contact details are not shared until a lesson has been booked.

If you've participated in an online lesson—whether as a Tutor or Student—the session is recorded and stored to ensure safety and maintain the quality of teaching. Students are typically able to access the recording after the lesson has ended.

All online lessons are recorded and may be made available for viewing by both Students and their parents.

If you've given consent, we may use your personal data to inform you about other services and products that might interest you. This outreach may take the form of postal mail, phone calls, text messages, emails, social media communication, or direct advertising.

We may also reach out to you to participate in internal research to help us improve our offerings and better serve our user community.

If you no longer wish to receive communications from us or want to change your marketing preferences, please get in touch by emailing support@Rec-Tutors.com.

Even after an account is closed, we may retain personal data when necessary to meet legal requirements, enforce our terms, prevent fraud, recover outstanding payments, resolve issues, support investigations, and take other lawful actions.

4. Purposes for which we will use your personal data

Below, we’ve provided a breakdown of the various ways we may use your personal information, along with the legal grounds we rely on for each purpose. Where applicable, we have also outlined our legitimate interests in doing so.

Please note that certain uses of your data may fall under more than one lawful basis, depending on the specific circumstances. If you would like further clarification on which legal basis applies to a particular use of your personal data, feel free to reach out to us.

1. Personal Information (e.g., Name and Contact Details)

We use your personal details to set up your account, manage your interactions with the platform, and facilitate your use of our services. Your contact details may also be used to send updates, notifications, and marketing materials related to our services.

Legal basis: (a) Contractual necessity, (b) Our legitimate interest in recovering owed payments, (c) Our legitimate interest in promoting and growing our business.

2. Identity Verification Documents

We collect identification documents from Tutors to confirm their identity and meet compliance requirements, including anti-money laundering regulations.

Legal basis: (a) Necessary for fulfilling our contract with you, (b) Required to meet legal obligations.

3. Profile Information

Details provided in Tutor profiles, as well as system-generated or third-party data such as reviews and performance scores, are used to assess Tutor applications and monitor ongoing eligibility. This process helps us maintain the quality and standards of tutoring on our platform.

Legal basis: (a) Contractual necessity, (b) Our legitimate interest in maintaining accurate records and understanding service usage.

4. Payment Information (e.g., Card Details)

We process financial data to handle payments—both billing Students and transferring earnings to Tutors.

Legal basis: (a) Necessary for executing our contract with you, (b) Our legitimate interest in processing payments for our services.

5. Location Data

We use location information to help connect Tutors and Students effectively and manage billing operations. We may also analyze anonymized location data to better understand our user demographics.

Legal basis: (a) Contractual necessity, (b) Our legitimate interest in delivering and billing for services.

6. Sensitive Personal Data (e.g., Criminal Convictions)

We may collect criminal background data to assign and display a “Background Checked” status on Tutor profiles, enhancing trust and transparency within the platform.

Legal basis: (a) Performance of a contract, (b) Our legitimate interest in verifying Tutor credentials.

7. Electronic Data (e.g., IP Address, Cookies)

Technical identifiers such as your IP address and cookies are used to analyze how users interact with the site, allowing us to improve performance and user experience.

Legal basis: (a) Our legitimate interest in understanding and serving our user base, refining our site, and shaping our marketing strategy.

8. User Activity and Preferences

We collect data on how users interact with each other and with the platform to support communication, enhance matchmaking between Tutors and Students, and ensure lesson quality. User preferences help us tailor the service experience and honor individual settings. Online lessons are recorded for safeguarding.

Legal basis: (a) Contractual necessity, (b) Our legitimate interest in improving our platform and services.

9. Transactional and Service Records

Information about the services provided and goods exchanged is used to properly manage transactions and ensure compliance with legal requirements for financial documentation.

Legal basis: (a) Contractual necessity, (b) Legal compliance.

10. Device and Browser Information

Details about the device and browser you use help us improve our website's usability, maintain technical compatibility, and enhance your overall experience.

Legal basis: (a) Our legitimate interest in ensuring the Website remains current, user-friendly, and technically efficient.

5. Disclosure of your information

The information you provide to us, as detailed in the previous section, may be transferred to and stored on our servers or those of third-party service providers. We ensure that all third-party providers comply with their obligations and responsibilities in processing your personal data by maintaining Data Processing Agreements with them.

In some cases, it may be necessary for us to transfer the data we collect from you to locations outside of the European Union for processing and storage. Any data transferred will be strictly limited to what is required for the specific processing purpose.

Some of our third-party data processors do not transfer your personal data outside of the European Economic Area (EEA). These include Amazon Web Services, ClockworkSMS, and Digital Ocean.

However, certain third-party data processors may transfer your personal data outside the EEA. These processors include Amplitude, Drip, Google, Sendgrid, Stripe, LessonSpace, Braze, Notion, and Freshdesk.

If you are a User of the Website, we may share your personal information with a Tutor you have contacted. This may include your first name, contact details, and address, to allow them to provide you with the requested tuition services.

If you are a Tutor on the Website, we may share your information to help match you with new Students. This may include your first name, approximate location, any references you have provided, and details listed on your public profile. If you agree to teach a Student, we may also disclose your address and contact details to the Student for lesson delivery.

If you are a Tutor and have shared details of any criminal convictions (including a criminal record), we will assign a "Background-Verified" status to your profile if your record is clear and within the time limits specified in our Terms and Conditions.

If you are a Tutor and have listed references, we will contact those individuals, inform them of your intention to tutor with us, and ask for their feedback on your suitability.

If you are a referee, we may disclose the reference you provided to the Tutor and other Users of the Website. This will include the reference, your first name, and the initial of your surname.

We use third-party services to process sensitive information, including credit card and bank account details. By providing us with your personal information, you consent to this transfer, storage, or processing by these third parties. We do not share your personal data with third parties for marketing purposes or for offering unrelated goods or services.

We may also use your information if we are legally required to disclose or share it to comply with any legal obligations, enforce our Terms of Service, or prevent fraud.

In the event that we sell or transfer all or part of our business, or enter into a joint venture with another business, your personal information may be disclosed or transferred to the potential buyer, new business partners, owners, or their advisors.

6. Security

We are committed to safeguarding your data and take all reasonable measures to prevent unauthorized access, accidental loss, destruction, or damage to your information.

While we strive to protect your data, it’s important to note that transmitting information over the internet is not completely secure, and there is a possibility that such data may be intercepted. Although we take steps to protect your information, we cannot guarantee the absolute security of data you send to us electronically, and doing so is entirely at your own risk.

In order to ensure that all new features and updates to our services comply with the GDPR and the Turkish Data Protection Law (KVKK 6698), we adopt a “data protection by design and by default” approach in the development of our Website and services. This includes conducting Privacy Impact Assessments (PIAs) and submitting them to the Information Commissioner’s Office (ICO) as required.

7. Data Retention

We will retain your personal information for a period of 7 years from the date of your last activity on our Website.

There are some exceptions to this retention period: online lesson recordings are kept for 90 days, and certain records are retained for only 6 months. However, details related to these records, such as certificates, will be preserved for the full 7 years to demonstrate the legitimate granting of the Background-Verified status.

Any records you have made publicly available or shared with other Users (such as reviews, messages, or bookings) may remain on the Website even after your personal information has been deleted. These records will, however, no longer contain any identifying information that links them to you.

We may keep records for a longer period if required to meet our regulatory or legal obligations.

7. Legal Rights

Under certain conditions, you have rights regarding your personal data under data protection laws. These rights include:

● The right to access your personal data.

● The right to correct any inaccuracies in your personal data.

● The right to request the deletion of your personal data.

● The right to object to the processing of your personal data.

● The right to request a restriction on the processing of your personal data.

● The right to request the transfer of your personal data.

● The right to withdraw consent where consent is the legal basis for processing your data.

● The right to challenge decisions made through automated processes, such as Tutor rankings in search results.

If you wish to exercise any of the rights mentioned above, please get in touch with us. To help us handle your request promptly, please make sure to clearly state your request.

You will not be charged a fee for accessing your personal data or exercising any of the other rights. However, if your request is deemed unfounded, repetitive, or excessive, we may charge a reasonable fee. In such cases, we may also refuse to process your request.

You have the right to request an electronic copy of the personal data we hold about you in a structured, commonly used, and machine-readable format. This is especially useful if you wish to share it with another service provider.

To ensure the security of your personal data, we may need to ask for additional information to verify your identity before granting access or processing your request. This is to prevent unauthorized access to your data. We may also contact you for further details to help expedite our response.

We aim to respond to all legitimate requests within one month. However, if your request is complex or if you’ve made several requests, it may take us longer.

8. Changes to our Privacy Policy

Any changes to our Privacy Policy will be posted to the Website and, where appropriate, via e-mail.

8. Queries and Complaints

Please do not hesitate to contact us regarding any matter relating to this Privacy Policy via email at support@Rec-Tutors.com.