Company Privacy Policy
Location: IstanbulEffective Date: October 17, 2024
1. General Provisions
This Privacy Policy governs the processing of personal data in compliance with Turkish legal standards and establishesthe protocol for handling and safeguarding personal information by Agora International Agency IT Services Limited Company (Address: Osmanağa Mah. General Asım Gündüz Cad., Bahariye Apt. No:15, İç Kapı No:2, Kadıköy, Istanbul, Turkey. Tax/Company Number: 0091660681), which owns and manages the Application (hereafter referred to as "the Company").
1.1. The Company prioritizes protecting the rights and freedoms of individuals and citizens during personal data processing, focusing on securing privacy and maintaining personal and familial confidentiality.
1.2. This Privacy Policy (hereinafter "the Policy") applies to all data that may be collected by the Company from users who access the Website at https://mentormental.com.
2. Key Definitions in This Policy
2.1. Automated Processing: Handling personal data using digital means and technologies.
2.2. Data Blocking: Temporary suspension of personal data processing, except when processing is necessary for clarification purposes.
2.3. Website: A collection of visual and informational content, including software and databases, accessible via the Internet at https://mentormental.com.
2.4. Application: The "Mental Mentor" software, designed for Windows-based devices, developed and managed by the Company. It enables Users to listen to affirmations in an online, interactive environment. The Company holds all proprietary rights to the Application and its individual and collective components.
2.5. Personal Data Information System: A system comprising databases of personal data processed through information technologies and technical means.
2.6. Depersonalization: Actions that render personal data unidentifiable without additional information.
2.7. Data Processing: Any action or combination of actions performed on personal data, either manually or through automated systems, such as collection, storage, modification, retrieval, usage, transfer, depersonalization, and deletion.
2.8. Company: A public or private entity or individual responsible for organizing and performing data processing, including determining the purpose, scope, and methods of processing personal data.
2.9. Personal Data: Any information related to a specific or identifiable User of the Website ( https://mentormental.com) or the "Mental Mentor" Application.
2.10. User: Any individual visiting https://mentormental.com https://mentormental.com or installing the "Mental Mentor" Application.
2.11. Data Provision: Actions that make personal data available to a specific individual or group.
2.12. Data Dissemination: Any act of making personal data accessible to an unspecified number of individuals, including sharing data over the internet or through public networks.
2.13. Cross-border Data Transfer: Moving personal data to foreign countries or organizations.
2.14. Data Destruction: Any action that results in the irrecoverable elimination of personal data, rendering its restoration impossible.
3. Personal Data Processed by the Company
3.1. The Company processes the following personal data:
Full name (first, last, and patronymic, if applicable)
Email address
City of residence
Date of birth
Phone number
3.2. The Application and Website may use external services, which may collect data in accordance with their respective privacy policies:
- Google Analytics for Firebase
- Google Services
3.3. All data mentioned above is hereafter collectively referred to as "Personal Data."
4. Purpose of Personal Data Processing
4.1. The User's personal data, such as name, email, and phone number, is processed to enable communication with the User, execute and manage agreements, and provide access to materials and services available through the Website and Application.
4.2. The Company may also use personal data (full name and email) to inform Users about new products, services, offers, and events. Users can opt out of receiving such notifications by sending an email to [email protected] with the subject "Unsubscribe from all notifications."
4.3. Anonymous, depersonalized data is collected through web analytics tools to analyze User behavior and enhance the quality and content of the Website and Application.
4.4. Processing of personal data, such as phone number and email, is essential for creating and maintaining User accounts, ensuring accessibility across devices.
4.5. Personal data like full name, birth date, city, and test responses are processed to personalize and recommend Application content to the User.
4.6. The Application requires access to microphone functionality for speech recognition, which occurs locally on the User's device. No voice data is transmitted to the Company.
4.7. The Application may request access to notifications to inform Users about new services, offers, and events.
4.8. Permission to access IDFA may be requested to optimize the Application and related advertising content.
5. Legal Grounds for Processing Personal Data
5.1. Personal data is processed only when voluntarily provided by the User through forms available on the Website (https://mentormental.com) or within the "Mental Mentor" Application. By submitting their data, Users consent to this Policy.
5.2. Impersonal data is also processed if the User's browser settings allow it (e.g., cookies, JavaScript).
6. Data Handling and Security
6.1. The Company employs legal, organizational, and technical measures to ensure the security of personal data in full compliance with applicable laws on data protection.
6.2. All necessary precautions are taken by the Company to prevent unauthorized access to personal data.
6.3. Personal data will not be disclosed to third parties except as required by law.
6.4. If personal data needs to be corrected, the User can request changes by emailing [email protected] with the subject "Update Personal Data."
6.5. The duration of personal data processing is indefinite. However, Users may withdraw their consent at any time by sending an email to [email protected] with the subject "Revoke Personal Data Consent."
7. Deletion of Personal Data
7.1. Users may revoke their consent to personal data processing or delete their account and associated data at any time by emailing [email protected] or by selecting the "Delete account" option within the Application. This action will result in the permanent and irreversible removal of all personal data specified in Section 3.
8. Cross-border Data Transfer
8.1. Before transferring personal data internationally, the Company ensures that the recipient country provides adequate protection for personal data rights.
8.2. Transfers to countries lacking sufficient protections are only permitted with the explicit, written consent of the User or under specific contractual obligations.
9. Final Provisions
9.1. Users may request further clarification on the processing of their personal data by contacting the Company at [email protected].
9.2. Any updates to this Policy will be reflected in this document, which remains in force until replaced by a new version.
9.3. The most current version of the Policy can always be found at https://mentormental.com.