Privacy Policy

Turkly.co is operated by Turkly.co LLC, a limited liability company registered in Wyoming, USA ("Turkly", "we", "us"). We decide how and why your personal data is used, which makes us the "data controller" under laws like the GDPR.

Address: 30 N Gould St, Sheridan, WY 82801, USA Email: info@turkly.co

Our lessons are taught by our founder from Turkey, so your data may be handled in both the US and Turkey (more on that in section 8).

We collect only what we need to run the school:

• Account details — your name, email address, password (stored only as a secure hash) and an optional profile photo.

• Sign-in with Google or Apple — if you choose it, we receive your name, email address and an account identifier from that provider.

• Learning data — programs you join, lesson progress, quiz and exercise answers, voice recordings and transcripts from speaking exercises, homework submissions (including files or audio you upload) and the feedback you receive.

• Messages — chats with your tutor, support tickets, contact form messages and newsletter or guide sign-ups.

• Purchases — what you bought, the price, currency and payment status. Card details go directly to our payment provider, Stripe; we never see or store your full card number.

• Live lessons — the schedule of your lessons and the email address we send calendar invitations to.

• Technical data — IP address, browser type and server logs, used to keep the service secure and working.

• To provide the service — run your account, give you access to programs, track progress and deliver lessons and feedback. Legal basis: performance of a contract (GDPR Art. 6(1)(b); KVKK Art. 5(2)(c)).

• To take payments — process purchases, refunds and keep accounting records. Legal basis: contract and legal obligation (GDPR Art. 6(1)(b) and (c); KVKK Art. 5(2)(c) and (ç)).

• To give exercise feedback — we send answers from listening exercises and short voice recordings from speaking exercises to AI services to give you instant feedback. Legal basis: contract.

• To communicate with you — service emails such as verification, receipts, lesson reminders and replies to your messages. Newsletters and guides only if you sign up; email us any time to stop them. Legal basis: contract; consent for newsletters (GDPR Art. 6(1)(a); KVKK Art. 5(1)).

• To keep the service secure — prevent abuse, fraud and unauthorised access, for example through rate limiting. Legal basis: legitimate interests (GDPR Art. 6(1)(f); KVKK Art. 5(2)(f)).

We do not sell your personal data and we do not use it for advertising.

Your tutors and our staff can see the learning data and messages they need to teach and support you. We also use these service providers, who process data on our behalf:

• Stripe — payment processing.

• Google — sign-in (if you use it) and Google Calendar and Meet for scheduling and running live lessons.

• Apple — sign-in, if you use it.

• AI feedback services — AI service providers process answers from listening exercises and voice recordings from speaking exercises with zero data retention to transcribe speech and generate instant feedback.

• Email delivery provider — sending service emails.

• Hetzner — hosting our servers and database in the European Union.

• Cloudflare — secure network delivery and protection against attacks.

We may also disclose data when the law requires it, or to protect our rights, our users or the public.

Our main servers are in the European Union. Some providers, such as Stripe, Google, Apple, Cloudflare and our AI providers, may process data in the United States or other countries. Where data leaves the EU/EEA, the UK or Türkiye, we rely on adequacy decisions or standard contractual clauses (including the safeguards required by KVKK Art. 9).

Connections to turkly.co are encrypted with TLS, passwords are stored only as hashes, staff access is limited by role and we keep regular backups. No system is perfectly secure, so please use a strong, unique password and tell us right away if you think your account has been compromised.

We keep your account and learning data while your account is active. Speaking exercise recordings are deleted after 90 days. If you ask us to delete your account, we delete or anonymise your personal data within 30 days, except records we must keep by law, such as purchase and tax records, which we keep for the legally required period. Backups are overwritten on a rolling basis.

Under GDPR (EU, EEA and UK residents)

You can download a copy of your account data in Settings. If you have a student account, you can also permanently delete it there. You can ask to access, correct, delete or receive a copy of your data, restrict or object to its use, and withdraw consent at any time. You may also complain to your local data protection authority.

Under KVKK (Türkiye)

Under Article 11 of KVKK you can learn whether your data is processed, request information about it, learn the purpose of processing and the third parties it is transferred to, ask for correction, deletion or destruction, object to results produced solely by automated processing, and claim compensation for unlawful processing. You may also apply to the Personal Data Protection Board (Kişisel Verileri Koruma Kurulu).

To use any of these rights, email us at info@turkly.co. We reply within 30 days.

Turkly.co is for adults and teenagers aged 16 and over. If you are under 18, a parent or guardian must agree to these terms on your behalf. If you believe a child has given us personal data without permission, contact us and we will delete it.

We use only cookies that are needed to sign you in, keep the site secure and take payments. See our Cookie Policy for the full list.

We may update this policy as the school changes. We will change the effective date above and, for significant changes, tell you by email or on the site before they take effect.