BEAUTYLOGY OÜ COMPANY (referred to as "NAILACADEMY", "we", "us", "us" or "our" or "Company") is committed to protecting your privacy to the maximum extent possible in accordance with applicable laws.
As NAILACADEMY, we attach utmost importance to the processing, storage, destruction and confidentiality of personal data in accordance with the Law No. 6698 on the Protection of Personal Data ("KVKK" or "KVK Law" or "Law") and the relevant secondary legislation and we consider these issues among our priorities in our business and transactions. In the capacity of "Data Controller", we prioritize the processing of personal data of real persons associated with our Company, including our employees, trainers, customers, suppliers, users and members of our websites and mobile applications, in accordance with the Law and related legislation and ensuring the effective use of the rights of the relevant persons whose data are processed. In this context, we present this Privacy and Personal Data Protection Policy to you in order to fulfill our obligation of disclosure within the scope of Article 10 of the KVKK and to inform you of all administrative and technical measures we take within the scope of processing, protection, destruction and confidentiality of personal data.

Another purpose of this Privacy and Personal Data Protection Policy is to explain our practices regarding the information we collect from users through https://nailacademy.org ("Website") and the ancillary services offered through the Website (collectively, the "Services"). Our Services predominantly include the operation of the NAILACADEMY educational platform, but we may expand the scope of our services as we see fit.
This Privacy and Personal Data Protection Policy sets out the legally binding conditions for your use of our Services, whether you are a "Visitor" (this means that you have just accessed and browsed the Website) or a "Member". Visitors and Members, our customers, employees, prospective employees and third parties who share their information with us are referred to as "User" or "you" in this Policy.

This Privacy and Personal Data Protection Policy forms an integral part of the Terms of Use ("Terms of Use") available at https://nailacademy.org and must be read and accepted by you or, if you have not reached the age of majority in your jurisdiction, by a parent or legal guardian. The Terms of Use describe your rights and responsibilities when using the NAILACADEMY Services. Capitalized terms not otherwise defined in this Privacy and Personal Data Protection Policy have the meanings given in our Terms of Use.

BY USING OUR SERVICES, YOU CONSENT TO THE COLLECTION, TRANSFER, USE, STORAGE AND DISCLOSURE OF YOUR INFORMATION IN THE MANNER AND FOR THE PURPOSES SET FORTH HEREIN. IF YOU OR YOUR PARENT/GUARDIAN DO NOT WISH TO BE BOUND BY THE TERMS OF USE, INCLUDING THIS PRIVACY AND PERSONAL DATA PROTECTION POLICY, PLEASE EXIT THE SERVICES NOW AND DO NOT ACCESS OR USE NAILACADEMY'S SERVICES.

If you are in any doubt about any of your rights and obligations under this Privacy and Personal Data Protection Policy, you are advised not to proceed without consulting a legal advisor. You may also contact us at support@nailacademy.org for additional questions.

By accepting, accessing or using our Services electronically, you agree that this Privacy and Personal Data Protection Policy will apply to your use of our Services and you agree to be bound by the Privacy and Personal Data Protection Policy, which constitutes a contract between you and NAILACADEMY.

This Privacy and Personal Data Protection Policy shall apply to all personal information transmitted by you to NAILACADEMY while visiting our Website and/or using any of our Services. This includes information we collect via email, text, voice, photos and other electronic messaging, as well as interactions between you and third party web pages or applications that contain a link to this Privacy and Personal Data Protection Policy.

NAILACADEMY is not responsible and will not be responsible in the future for the privacy rules and regulations of any third party application, website and/or service, whether linked by us or through us or not, such third party application, website and/or service. The foregoing sentence shall also extend to any person employed or otherwise placed on the payroll by such third party.

NAILACADEMY fully supports your right to privacy and personal data protection and if you decide to opt-out of being tracked by NAILACADEMY, we will also fully support your decision.

You may request deletion of your account with NAILACADEMY and/or all or any of your Personal Information stored by us or our service providers by contacting us at support@nailacademy.org and we will inform you how to proceed with your request. Please note that opt-out requests will take approximately 10 (ten) business days to process. Please note that the account and/or Personal Information you request to be deleted will be lost forever.

If you do not wish to receive any marketing communications through our Services, you may contact us at support@nailacademy.org and we will inform you of ways to stop receiving marketing communications. If you "opt-out" of these messages, you will still receive emails from us about your account, our services and other relevant information about our services. These communications are considered part of the service and your account, which you cannot opt out of receiving.

Let's define the concept of "information". Before we begin, it may help to define some terms. There are two types of information that can be collected. The first is called "Personal Information", which is personally identifiable information that allows someone to identify or contact you, including, for example, your name, address, phone number, email address, as well as any other non-public information.

Anonymous Information" means information that is not related to or linked to your Personal Information and does not in itself allow for the identification of individual persons. Anonymous Information is the type of information that does not directly identify a person or contain personally identifiable information, although it may be personal information. We may collect Anonymous Information about the use of our services to help us improve our services.

The Website is intended only for persons who have reached the age of 18. We share your concerns about the privacy of minors and do not knowingly collect personally identifiable information about children through the Services. We may, however, use third-party analytics services that collect anonymous information about the use of our Services.

Only "natural persons" are included in the scope of KVKK No. 6698 and the data belonging to legal entities, which do not contain the information of natural persons, are outside the scope of this Policy and the protection of personal data.

This Personal Information may include:
a. Your e-mail address;
b. Your name;
c. IP address, device type, operating system and browse
r type;
d. any other information you decide to provide to us.
We also collect various Personal Information as well as (where relevant) Anonymous Information about Users who visit our Website and use our Services. Such information includes:

a. Traffic Data
b. Location
c. Logs and communication data;
d. The resources you access and use on our Website;
e. IP address, operating system and browser type;
f. information collected through cookies, web beacons and other tracking technologies

Our Company has created a Personal Data Inventory in accordance with the Regulation on the Data Controllers Registry issued by the Personal Data Protection Authority in accordance with the Regulation on the Data Controllers Registry issued by the Personal Data Protection Authority in accordance with the legitimate and lawful personal data processing purposes of NAILACADEMY, by informing the relevant persons in accordance with Article 10 of the Law, based on and limited to one or more of the personal data processing conditions specified in Article 5 of the KVK Law in line with the legitimate and lawful personal data processing purposes of NAILACADEMY, by complying with the general principles specified in the KVKK, especially the principles specified in Article 4 regarding the processing of personal data, and all obligations regulated in the KVK Law. This data inventory includes data categories, the source of the data, data processing purposes, data processing process, recipient groups to whom the data is transferred and retention periods. In this context, there are the following types of data categories (but not limited to these types) in our Company's personal data inventory.

The categories specified below are for your information and other categories may be added by us in order for the Company to carry out its future commercial and operational activities. In such cases, our Company will continue to update the specified categories for you in the relevant texts in order to continue to inform you as quickly as possible.

PERSONAL DATA CATEGORIZATION - PERSONAL DATA CATEGORIZATION DESCRIPTION
IDENTIFICATION INFORMATION

Documents such as driver's license, identity card and passport containing information such as name-surname, Turkish ID number, nationality, mother's name-father's name, place of birth, date of birth, gender, and information such as tax number, SSI number, signature information, vehicle license plate, etc.

CONTACT INFORMATION
Information such as telephone number, address, e-mail address, fax number, IP address, device type, operating system and browser type, other information you decide to provide to us.

SIGNATURE DATA
Person's signature information (wet signature, e-signature, signature photocopy/scan).

HEALTH DATA
It is the data group containing the health information of the person (blood type, medical history, check-up result, consultation report, diet form).

TRANSACTION SECURITY INFORMATION / DATA BELONGING TO IN-TRANSIT USERS
Personal data processed regarding the technical, administrative, legal and commercial security of both the Personal Data Owner and the Company while conducting the Company's activities. IP Address Information of online users, Website Login and Logout Information, Password and Password Information Computer Screen Records, Device IMEI Number, Device MAC Address

FAMILY MEMBERS AND RELATIVES
Information about the Personal Data Owner's family members (e.g. spouse, mother, father, child), relatives and other persons who can be reached in case of emergency within the framework of the operations carried out by the Company's business units, regarding the products and services offered by the group companies or in order to protect the legal and other interests of the Company and the Personal Data Owner.

CUSTOMER INFORMATION
Information obtained and produced about the relevant person as a result of commercial activities and operations carried out by business units within this framework.

PHYSICAL SPACE SECURITY INFORMATION
Personal data related to records and documents taken at the entrance to the physical space, during the stay in the physical space; camera recordings, records taken at the security point, etc.

FINANCIAL INFORMATION/ASSET DATA
Personal data processed regarding information, documents and records showing all kinds of financial results created according to the type of relationship established by the Company with the Personal Data Owner, and data such as bank account number, IBAN number, credit card information, financial profile, data on the assets owned by the person (copy/scan of title deed, copy/scan of vehicle license), income information.

VISUAL/AUDIO DATA
Data contained in documents that clearly belong to an identified or identifiable natural person, such as photographs and camera recordings (except for recordings within the scope of Physical Space Security Information), voice recordings, photocopy/scan of driver's license, photocopy/scan of ID card, photocopy/scan of passport, etc., which are copies of documents containing personal data.

MARKETING INFORMATION
Personal data processed for the marketing of our products and services by customizing them in line with the usage habits, tastes and needs of the personal data owner, and the reports and evaluations created as a result of these processing results.

PERSONAL-TRAINING/PERFORMANCE INFORMATION/BENEFITS
All kinds of personal data processed for obtaining information that will be the basis for the formation of the personal rights of real persons who have a working relationship with the Company and the education data of the person (Diploma grade, diploma photocopy/scan).

Performance information; personal data processed for the purpose of measuring the performance of employees or real persons in a working relationship with the Company and planning and executing their career development within the scope of our company's Human Resources Policy.
Fringe benefits; personal data processed for the purpose of planning the fringe benefits and benefits offered and to be offered to employees or other real persons in a working relationship with the Company, determining the objective criteria for entitlement to them and monitoring the entitlement to them.

LEGAL TRANSACTION INFORMATION
Data processed within the scope of the determination and follow-up of the Company's legal receivables and rights and the performance of its debts and legal obligations.

SANCTION DATA
Data on sanctions taken in the past (Criminal Prosecutions, Criminal Record, Disciplinary Record).
PERSONAL DATA OF SPECIAL NATURE
Data specified in Article 6 of the Law (e.g. health data including blood type, biometric data, religion and membership of associations).

REQUEST/COMPLAINT MANAGEMENT INFORMATION
Personal data regarding the receipt and evaluation of any request or complaint addressed to the Company.

TRAVEL DATA
Data group containing information about the person's travels (flight information, flight card, tour route, mile card number, accommodation data).

AUDIT AND INSPECTION INFORMATION
Personal data processed within the scope of our company's legal obligations and compliance with company policies.

RISK MANAGEMENT INFORMATION
Personal data that clearly belongs to an identified or identifiable natural person and is included in the data recording system; personal data processed through methods used in accordance with generally accepted legal, commercial customs and good faith in these areas in order to manage our commercial, technical and administrative risks

EMPLOYEE INFORMATION
Personal data that clearly belongs to an identified or identifiable natural person, processed partially or completely automatically or non-automatically as part of the data recording system; Personal data processed about individuals who have applied to become an employee of NAILACADEMY or who have been evaluated as an employee candidate in line with the human resources needs of NAILACADEMY in accordance with the commercial custom and honesty rules or who are in a working relationship with NAILACADEMY.

We collect Personal Information that you submit directly to us if:

a. Signing up for online courses;
b. Signing up for a newsletter on Our Website;
c. request technical support through our Website, through our proprietary Learning Management System, through Google Classroom, through our Facebook page or by sending us a message via email
We use your Personal Data that you have provided to us for the following purposes:

- to deliver the newsletter you have subscribed to;
- provide you with the assistance you have requested;
- deliver localized content in your language;
- understand what type of content is more relevant in certain areas;
- to promptly identify and resolve technical problems encountered by our Website and our Users;
- inform you about new content and special offers;
- estimate the size and user pattern of our target group;
- estimate the efficiency of our marketing campaigns;
- improve our customer service;
- ensure the stability and security of our Services;
- analyze NAILACADEMY's trends, administer our Website, track users' movements and collect broad demographic information for statistical purposes,
- improve existing Services by analyzing aggregated data about how Users interact with our Services;
- develop new Services and tools;
- analyze trends, manage our Website, track users' movements and collect broad demographic information for statistical purposes.

In addition to the above-mentioned processing purposes, your personal data may also be processed for the purposes described below within the scope of the website named https://www.nailacademy.org, which is also within our Company, and the mobile applications of these sites:

i. Performing the purchase transaction, preparing the order, shipping, updating the delivery information, delivering your order to you, distinguishing the records of you that we have created in our system from the records of other customers, fulfilling after-sales operational transactions, and issuing an expense voucher when necessary, your identity (name, surname), contact (e-mail address, telephone number, address) and customer transaction (shopping date, time, amount, shopping content, shopping content, installment information, payment method and payment details, campaign / discount / benefit information) information for the purpose of sending you the e-invoice regarding your shopping,

ii. Your identity and billing information in order to issue an invoice, as well as some additional billing information if you are a taxpayer (Turkish ID number, tax number, sole proprietorship information),

iii. If you want to make your payment by credit card, your credit card information in order to receive the payment (credit card information is transferred to the payment institution without being recorded by us), the first 6 and last 4 digits of your credit card information or your bank account information where the refund will be made in order to make a refund in case of possible error / failure / return,

iv. Your information about your use of the websites and Mobile Application in order to detect and correct technical/software errors and deficiencies encountered during your visit and use of the websites and Mobile Application,

v. Your identity (name, surname), contact (e-mail address, telephone number) and password information in order to ensure that membership transactions are carried out, to fulfill the requirements of the Distance Sales Agreement we will conclude with you, to log in as a member, to inform the membership,

vi. Your identity (name, surname) and contact (phone number, e-mail address, delivery and billing address information) information in order to set up your account on our Services, to enable you to shop using your member information without the need to re-enter information for each purchase when you want to make a purchase on the Site / Mobile Application as a member,

vii. To be able to benefit from membership programs, to create general or personalized campaigns, advantages, promotions, advertisements, to organize campaigns, competitions, sweepstakes and other events, to carry out segmentation, reporting, profiling, marketing and analysis studies, to make advertisements and marketing / communication activities (notifications on the Mobile Application and Site, pop-up display, personalized offers, customization of user screens, advertising, search, survey, etc.) of Nailacademy and its website https://www.nailacademy. org website (notifications on the Mobile Application and Site, pop-up display, personalized offers, customization of user screens, advertising, search, survey, etc.), to improve the user experience on the Site and Mobile Application, to send you catalogs, brochures, printed marketing materials.

The purposes of processing personal data may be updated in line with our Company policies and our obligations arising from the legislation. In the event that the data processing activity carried out for the aforementioned purposes does not meet any of the conditions stipulated under the Law, your explicit consent is obtained by the Company regarding the relevant data processing process.

We do not store the information you provide to us via our Website, Facebook Page or email on our infrastructure. However, this information may be stored by the following:

a. by your email provider (if you decide to communicate with us via email).
b. by our email provider. We use HubSpot's email, CRM and help desk service to process and respond to all incoming support requests.
c. on your Facebook account (if you decide to contact us on the Facebook page). Click here to learn more about Facebook's Privacy Policy.
d. Users may disclose information about themselves by posting it on the Website or on our Page on Facebook. NAILACADEMY is not responsible for what Users say and write in these sections. In addition, such information is made publicly available for others to see. The User is responsible for the disclosure of such data here.

We also use a service provider called HubSpot to send the Newsletter, so your email address will be stored on their servers. HubSpot is a GDPR compliant marketing automation service. To learn more about HubSpot, please visit their website or contact us at support@nailacademy.org. You can unsubscribe from the newsletter at any time by clicking the unsubscribe button in such newsletters. You can also request that your email be permanently deleted from the newsletter mailing list by sending us a request at support@nailacademy.org.

Google Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. ("Google"), to optimize our Website. Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how you use this Website. The information generated by the cookie about your use of this Website (including your IP address) will be transmitted to Google and stored by Google on servers in the United States. If IP anonymization is activated on this Website, your IP address will be shortened by Google beforehand within EU member states or EEA member states. Only in exceptional cases will the IP address be transferred to Google on a server in the United States of America and then truncated. On behalf of the website operator, Google will use this information for the purpose of evaluating your use of the Website, compiling reports on website activity for website operators and providing other services related to website activity and internet usage. The IP address transmitted by your browser will not be merged with other data by Google. You can refuse the use of cookies by selecting the appropriate settings in your browser, but please note that if you do so, you may not be able to use the full functionality of this Website.

You can also prevent the data generated by the cookie and related to the use of the Website (including your IP address) from being collected and processed by Google. Link: https://tools.google.com/dlpage/gaoptout. Additional information on this is available at https://support.google.com/analytics/answer/600424.... (general information on Google Analytics and privacy). Our Website uses Google Analytics with the extension code "gat._anonymizeIp()", so IP addresses will only be processed in an abbreviated form to prevent the identification of individuals.

Google AdWords: is another Google service we use. This is a web analytics service that places a cookie ("Conversion Cookie") on your browser when you access our Website through a Google advertisement. These Conversion Cookies are valid for 30 days. If you access some websites and Conversion Cookies are still valid, we and Google may recognize that you clicked on the ad and were then transferred to Our Website. Note that each AdWords customer uses a different cookie and it is therefore not possible to track cookies across AdWords customers' websites. The information obtained through the Conversion Cookie is used to generate conversion reports for AdWords customers. AdWords clients receive the number of users who clicked on their ads and were transferred to a site containing the Conversion Tracking tag, but they do not receive any information that would allow them to identify the user.

You can decline the use of cookies by selecting the appropriate settings in your browser, but please note that if you do so, you may not be able to use the full functionality of our Website.

Facebook Pixel: We use Facebook Inc.'s "visitor action pixels" on this Website. This enables the tracking of user behavior after they have been redirected to our Website by clicking on a Facebook ad. This allows us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual Users.

However, this data is stored and processed by Facebook, which is why we inform you based on our knowledge of the situation. Facebook may link this information to your Facebook account and may also use it for its own promotional purposes in accordance with Facebook's Data Use Policy.

Facebook has been certified under the US-EU Privacy Shield Agreement and therefore guarantees compliance with European data protection legislation. You may allow Facebook and its partners to place advertisements on Facebook and a cookie may also be stored on your computer for these purposes. You can object to the collection of your data by the Facebook pixel or the use of your data for the purpose of displaying Facebook advertisements in your account settings.

Axltech: We use AXL as our email, CRM and helpdesk software provider and use the user tracking code snippet. Please familiarize yourself with their cookie policy here: https://admin.accelonline.io/docs/privacy/en
Tilda: We use Tilda to build and host parts of our website. Tilda's cookie policy is available at
https://tilda.cc/privacy/

Without your consent, we will not communicate or share the personal information we collect from you with third parties outside NAILACADEMY (or the group of companies of which NAILACADEMY is or may become a part), except as described below:

a. when we believe in good faith that we are legally authorized or required to do so, or that it is reasonably necessary or appropriate to comply with the law or legal process, or to respond to lawful requests or legal authorities, including responding to legal subpoenas,

b. To protect the rights and property of NAILACADEMY, our agents, customers and others (including enforcing our agreements, policies and terms of use) or to investigate fraud, intellectual property infringement and any other conduct that may be unlawful or expose NAILACADEMY;
c. If disclosure is necessary for a third party to assist NAILACADEMY in the operation and/or improvement of our Website and/or other Services;

d. where Personal Information is aggregated or de-identified for analytics, analysis, trends and similar purposes and no User of our Services will be individually identifiable from such aggregated and/or anonymized information and statistics;

e. In connection with or during negotiations of a change or proposed change in ownership of NAILACADEMY,

i.e. when we enter into a business agreement or negotiate a business agreement involving the sale or transfer of all or part of our business or assets. These agreements may include any sale, merger, financing, acquisition or bankruptcy transaction or proceeding or any other situation in which personal information may be disclosed or transferred as one of our business assets. The buyer or transferee will have to honor the commitments we have made in this Privacy and Personal Data Protection Policy;

f. In the event of an emergency involving protecting the safety of our employees and agents, customers or any other person.

We have implemented measures designed to protect your Personal Information from accidental loss and unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. We are constantly taking steps to further improve the way we store and process Personal Data.

Unfortunately, the transmission of information over the internet is not completely secure. While we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of Personal Information is at your own risk.
We are not responsible for bypassing any privacy settings or security measures contained on the Website.
You are responsible for the following:

a. making sure that no one uses our Services while you are "logged in" to your account;
b. logging out of your account when you are not using it;
c. and keeping your password or other access information confidential.

The information we collect through our Services is stored and processed on servers located in the US and EU hosted by Digital Ocean, Amazon Web Services & Fastly.

Our Service Providers' servers are located in the United States and the EU. By registering for and using the Services, you consent to the transfer of information to the United States and the EU.

NAILACADEMY shall retain the data collected pursuant to this Privacy and Personal Data Protection Policy for the period necessary to fulfill the purposes set out in this Privacy and Personal Data Protection Policy,
unless a longer retention period is required or permitted by law. Thereafter, in the event that the collected data is no longer needed for the purposes set out in this Privacy and Personal Data Protection Policy,

NAILACADEMY shall delete all aforementioned data at its disposal within a reasonable period of time.
NAILACADEMY does not verify the accuracy of Personal Data and is not responsible for it.

A User's access to and use of the Services may be subject to other third party terms and conditions and privacy and personal data protection policies, including but not limited to app stores, mobile software platforms, social networking services and payment providers. NAILACADEMY is not responsible for such third party terms and conditions and their use of users' personal data.

NAILACADEMY may, at its sole discretion, make links available through advertisements or otherwise enable Users to access third party products or services. NAILACADEMY is not responsible for the actions of such third parties, the content of their products or services, the use of information a User provides to them, or any products or services they may offer.

NAILACADEMY's linking to such products or services does not constitute sponsorship or affiliation with such third parties.

Any information you provide on third party websites or applications is provided directly to the owner of that website or application and is subject to that party's privacy policy. Our Privacy and Personal Data Protection Policy does not apply to such websites and applications, and we are not responsible for the content or privacy and security practices and policies of such websites and applications.

In accordance with Article 13 of the KVK Law, the evaluation of the rights of personal data owners and the necessary information to personal data owners are carried out through the Data Owner Application Form as well as this Policy. Personal data owners may submit their complaints or requests regarding the processing of their personal data to us within the framework of the principles specified in the relevant form.

i. Application Right
Pursuant to Article 11 of the KVK Law, anyone whose personal data is processed may apply to our Company and make requests regarding the following issues related to him/her:

a. To learn whether their personal data is being processed or not,

b. Request information if personal data has been processed,

c. To learn the purpose of processing personal data and whether they are used in accordance with their purpose,

d. To learn the third parties to whom their personal data are transferred domestically or abroad,

e. To request correction of personal data in case of incomplete or incorrect processing and to request
notification of the transaction made within this scope to third parties to whom personal data is transferred,

f. To request the deletion, destruction or anonymization of personal data in the event that the reasons requiring the processing of personal data disappear and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,

g. To object to the occurrence of a result to the detriment of the data subject by analyzing the processed data exclusively through automated systems,

h. In case of damage due to the processing of personal data in violation of the KVK Law, to demand the compensation of the damage.

ii. Situations Excluded from the Scope of the Right to Apply
Pursuant to Article 28 of the KVK Law, it will not be possible for personal data owners to assert their rights in the following cases:

a. Processing of personal data by natural persons within the scope of activities related to themselves or their family members living in the same residence, provided that their personal data is not disclosed to third parties and obligations regarding data security are complied with

b. Processing of personal data for purposes such as research, planning and statistics by anonymizing them with official statistics.

c. Processing of personal data for artistic, historical, literary or scientific purposes or within the scope of freedom of expression, provided that such processing does not violate national defense, national security, public security, public safety, public order, economic security, privacy of private life or personal rights or constitute a crime.

d. Processing of personal data within the scope of preventive, protective and intelligence activities carried out by public institutions and organizations authorized by law to ensure national defense, national security, public security, public order or economic security.

e. Processing of personal data by judicial authorities or execution authorities in relation to investigation, prosecution, trial or execution procedures.

Pursuant to paragraph 2 of Article 28 of the KVK Law, data owners will not be able to assert the rights of personal data owners, except for the right to claim compensation for the damage:

a. Processing of personal data is necessary for the prevention of crime or criminal investigation.

b. Processing of personal data made public by the data subject himself/herself.

c. Processing of personal data is necessary for the execution of supervisory or regulatory duties and disciplinary investigation or prosecution by authorized public institutions and organizations and professional organizations in the nature of public institutions based on the authority granted by law.

d. Personal data processing is necessary for the protection of the economic and financial interests of the State in relation to budget, tax and financial matters.
The relevant persons may submit their requests for the exercise of their rights by filling out the Application Form, which can be accessed from the website https://nailacademy.org;

a. after being signed with wet signature, send it to Barbaros Mah. Begonya Sk. Nidakule Ataşehir West Block No: 1 Interior Door No: 2 Ataşehir / Istanbul in person or through a Notary Public ("Information Request within the Scope of the Law on the Protection of Personal Data" will be written on the envelope/notification), or
b. By an e-mail to be sent to support@nailacademy.org by using your e-mail address registered in our Company's system (The subject of the e-mail will be written "Personal Data Protection Law Information Request").

In the application, information and documents related to the subject matter shall be attached to the application.

The requests in the application will be finalized free of charge within 30 days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost, the applicant may be charged a fee in accordance with the tariff determined by the Board. In order for third parties to make an application request on behalf of personal data owners, there must be a special power of attorney issued by the data owner through a notary public on behalf of the applicant.

In the event of the death of a Nailacademy user, please send us an email to the following email address: support@nailacademy.org

We may change or update the Privacy and Personal Data Protection Policy at any time as we add new or different features or as required by law. Unless another date is given, changes will take effect upon posting. You should therefore review the Privacy and Personal Data Protection Policy frequently.

The Privacy and Personal Data Protection Policy detailed herein applies to all information a User obtains from NAILACADEMY or provides to NAILACADEMY. We reserve the right, in our sole and absolute discretion and without prior notice, to change, modify, amend, correct, add, remove or otherwise omit portions of the Privacy and Personal Data Protection Policy at any time and for any reason or no reason. If we make any changes, we will change the last update date below. Please continue to check this Privacy & Personal Data Protection

Policy periodically at https://nailacademy.org/privacy-policy/ for any changes, although NAILACADEMY will endeavor to email a copy of the revised Privacy & Personal Data Protection Policy, if available, to the email address on file. In accordance with the Terms, we may provide you with additional change or update notification forms. Such changes will apply to disputes arising under the Privacy and Personal Data Protection Policy from the date of onward posting. A User's use of the Services after the posting of any modification, deletion or other change to the Privacy and Personal Data Protection Policy shall constitute acceptance, acknowledgment and agreement to such changes. If such change requires NAILACADEMY to notify a parent or obtain parental consent, NAILACADEMY will take steps to comply with such requirements at that time.

The effective date of this Privacy and Personal Data Protection Policy is 01.07.2023.