Privacy Policy

Last Updated: 15 November 2025

This Privacy Policy explains how Sculin Online (“we”, “us”, “our”) collects, uses, shares and protects personal data of users (“you”) of the Sculin.com website and related digital platforms (together, the “Platform”), through which we provide online education services.

By using the Platform, you acknowledge that you have read and understood this Privacy Policy.

1. Data Controller

Your personal data is processed by:

Sculin Online
Address:
Beştepe Mah. Nergiz Sok. No:9
Gama Holding Binası Kat:13
06560, Yenimahalle
Ankara, Türkiye

E-mail: info@sculin.com
Telephone: +90 312 870 10 10

as the data controller, in accordance with the Turkish Personal Data Protection Law No. 6698 (“KVKK”) and applicable legislation.

2. What Personal Data Do We Collect?

Depending on how you use the Platform, we may process the following categories of personal data:

2.1. Membership and Account Information

Name and surname
E-mail address
Telephone number (where provided)
Username and profile picture (where provided)
Password (stored in an irreversibly hashed form)

2.2. Education and Usage Data

Courses, programmes and education packages you enrol in
Your participation data (attendance dates, times, duration, attendance records)
Exam, quiz, assignment, project and assessment results
Certificate information (where applicable)
Your interaction with educational content (viewing times, progress, completion status, etc.)

2.3. Transactional and Technical Data

IP address
Browser type, device type, operating system information
Session data and log records
In-Platform activity data (pages visited, clicks, navigation behaviour, etc.)

2.4. Communication and Support Records

Information you provide via contact forms, e-mail, calls or other channels
Complaints, suggestions and feedback
Records of written/electronic communication with trainers or our support team

2.5. Payment and Billing Information (where applicable)

Identification and contact details required for invoicing
Payment amount, date and method
Masked card information processed by the payment service provider (we do not store your full card number; it is held by the payment provider)

2.6. Cookies and Similar Technologies

Visit and usage information collected via cookies
Visit duration, frequency, referring pages, and similar analytics data

Further details on our use of cookies will be provided in a separate Cookie Policy.

3. For What Purposes Do We Use Your Personal Data?

We process your personal data for the following purposes:

Provision of Services and Operation of the Platform
- Creating and managing your user account
- Providing access to online courses and educational content
- Managing live sessions, recorded content and assessments
- Issuing certificates, where applicable
Management and Improvement of Educational Processes
- Monitoring your learning progress
- Evaluating your performance
- Improving and personalising educational content
- Measuring and enhancing user experience
Communication and Support
- Responding to your requests, complaints and enquiries
- Sending important information relating to the Platform and your courses
- Enabling necessary communication between learners, trainers and our support team
Performance of Contractual and Legal Obligations
- Performing our obligations under the terms of use and any applicable distance sales/subscription agreements
- Managing invoicing and accounting processes
- Complying with legal obligations and responding to official requests
Security and Prevention of Misuse
- Ensuring the security of your account
- Detecting and preventing unauthorised or malicious use
- Maintaining system security logs and records
Marketing and Information (Where You Give Consent)
- Informing you about campaigns, discounts, new courses and programmes
- Sending newsletters
- Providing you with personalised recommendations

4. Legal Bases for Processing Personal Data

We process your personal data on the legal bases set out in Articles 5 and 6 of KVKK, including but not limited to:

Necessity for the establishment or performance of a contract (e.g. providing online education services)
Compliance with legal obligations
Legitimate interests (e.g. ensuring security, improving services, internal reporting), provided that your fundamental rights and freedoms are not harmed
Your explicit consent (e.g. for certain marketing activities or non-essential cookies)

5. Sharing and Transfer of Personal Data

Your personal data may be shared, to the extent necessary and proportionate, with:

IT, hosting, maintenance, security and backup service providers
Payment institutions and banks (for processing payments)
Independent auditors, legal advisers and consultants where required
Competent public authorities and judicial bodies, where required by law

Where international data transfers are involved (for example, when using cloud, e-mail or analytics services based outside Türkiye), such transfers are carried out in accordance with Article 9 of KVKK and decisions of the Personal Data Protection Board, with appropriate safeguards in place.

6. Cookies and Similar Technologies

On our Platform we may use:

Strictly necessary (essential) cookies
Performance and analytics cookies
Marketing and targeting cookies (subject to your consent)

You can manage your cookie preferences through your browser settings and, where provided, through our cookie management tools. However, disabling certain cookies may affect the proper functioning of some features of the Platform.

More detailed information will be provided in our Cookie Policy.

7. Retention Periods

We retain your personal data for as long as necessary for:

The purposes for which it was collected
The periods required by relevant legislation
The applicable contractual and statutory limitation periods

After these periods expire, your personal data is deleted, destroyed or anonymised in accordance with KVKK and applicable legislation.

8. Data Security

Sculin Online takes appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, misuse or disclosure. These measures include, where appropriate:

Access controls and authorisation management
Firewalls, logging and monitoring systems
Encryption and masking techniques, where necessary
Confidentiality obligations and awareness-raising for staff

However, please note that no method of transmission over the internet or method of electronic storage is completely risk-free, and we cannot guarantee absolute security.

9. Your Rights Under KVKK

Under Article 11 of KVKK, you have the following rights in relation to your personal data:

To learn whether your personal data is being processed
To request information if your personal data has been processed
To learn the purpose of processing and whether it is used in line with that purpose
To know the third parties in Türkiye or abroad to whom personal data is transferred
To request the correction of incomplete or inaccurate data
To request the deletion or destruction of personal data under the conditions set out in KVKK
To request that correction, deletion or destruction is notified to third parties to whom personal data has been transferred
To object to the occurrence of a result against you by means of the analysis of personal data solely through automated systems
To request compensation for any damage arising from the unlawful processing of your personal data

You may submit your requests regarding these rights by contacting us via info@sculin.com or in writing to our postal address. Your applications will be assessed and responded to as soon as possible and in any event within 30 days, in accordance with KVKK and applicable legislation.

10. Third-Party Websites and Services

The Platform may contain links to third-party websites or services. Sculin Online is not responsible for the privacy practices of these third parties. We recommend that you review the privacy policies of any third-party websites you visit.

11. Changes to This Privacy Policy

Sculin Online may update this Privacy Policy from time to time. Significant changes will be announced via the Platform or by other suitable means.

The updated Privacy Policy will take effect from the date it is published on the Platform. Your continued use of the Platform following such changes will be deemed acceptance of the updated terms.

12. Contact

If you have any questions, requests or complaints regarding this Privacy Policy or our data protection practices, you can contact us at:

Sculin Online
Address:
8A Romsey
Terrace
Cambridge
CB1 3NH
United Kingdom

E-mail: info@sculin.com
Telephone: +90 312 870 10 10