This privacy statement has been compiled to help you understand why we ask for your personal information, how we store and use it when you use one of our websites.

The core of our job is to help you and other users find the most suitable courses and training providers. This is defined as our Legitimate Business Interest. We process your personal data to help you make decisions when choosing a course or training provider. We do this through:

• By providing comprehensive educational information
• Recommending things you might like, such as a course or training provider
• By informing you of what you say you like, such as a new course in your area.
• By personalizing the sections of our websites according to your preferences
• By dealing with any request or content you submit
• By contacting you when there is something we need to convey, such as a change in our policies or a problem with our services.
• By controlling the usage and performance of the services we offer

This privacy statement applies to all website and app users, whether registered or not, including people who participate in surveys and contests and comment on institutions.

Keeping your information safe and private is very important to us. All our services are designed with privacy and security in mind.

Collection and use of your personal information

You can browse our websites without giving any personal information. However, we may request additional information when processing your request to use some of our advanced functions. For example:

• Providing your name, email and contact information when you request a brochure or ask a training provider
• Providing your name, email address and preferences when creating an account to receive email newsletters and save your preferences
• Providing your name, contact information and training history to benefit from offline education consultancy services

The details we request for each advanced functionality depend on the action desired. For example:

• If we need to contact you by email, we will ask you for your email address.
• If we are going to show you the available courses, we will ask for your preferred start date.
• If you are going to pay in Pavaedu or one of our partner providers, you will be asked for your card and billing information.

The details of why we collect this information are clearly shown beside the fields where you enter the data.

The full list of data collected by each website can be found in the site-specific data collection notice.

We also collect some technical information from you while using our websites. For example; the type of browser you use or your IP address. This information is used to protect and control the performance of our website.

Cookies

We use cookies on our websites to provide login and preferences functions and to collect anonymized data about user interactions. For example, we use cookies for the following reasons:

• Keeping you signed in on the website
• By understanding and saving your user preferences, providing you with the most interesting content and products and creating a personalized experience
• Compiling anonymized site traffic and interaction data to provide better site experience and tools in the future. We use Google Analytics for this.
• Providing targeted content and ads based on your preferences and previous interactions. We work with third party companies for targeted advertisements. Personal data is not shared with these companies. You can find the details of the companies we work with in our Cookie Policy section.

Anonymous analysis and insights

From time to time, we will ask for additional information to help us control the access and effectiveness of our services. For example, when creating an account, we may ask for the country of residence or your postal code. This data is used only in an anonymous form to demonstrate our effectiveness and help us improve the products and services we offer.

We use Google Analytics to review aggregate usage data on all our websites. No personal data is shared with Google Analytics.

Geographic data and geographic targeting

As with all websites, your IP address is sent to us every time you view the web page. For some functionality, we use this in conjunction with your geographic location information provided by your browser to deliver content specific to your location via our sites or apps. Your IP address and location information are stored anonymously and are not associated with any personal details. You can stop sharing information by changing your browser settings.

Special settings for mobile applications

We offer instant notifications, location-based services and targeted advertisements through our apps. When you use one of our applications for the first time, you are asked if you want to turn on these services. You can disable these services at any time by changing the permissions in your device settings.

Storage of your data

You provide personal data are stored in a secure environment in Turkey. We use a range of technologies and procedures to secure this data, including encryption, antivirus and anti-malware, intrusion detection, company-wide data usage policies, and mandatory security and privacy personnel training.

Your data is not stored outside the EU, but if one of our offices in Italy on our behalf needs to provide you with a service, your data is accessible to them. In order to keep your data safe and comply with our privacy obligation, we have data sharing agreements and operational security and technical measures with these companies.

How long will you keep my information?

We will keep your data for as long as we need to keep it:

• Either legally, for example, to meet financial regulations regarding payments
• Or as long as we need your data to provide you with a service.

Personal data will be deleted in accordance with our internal retention policy. All identifiable personal data of users who register in Turkey, 3 years after the last interaction they do this websiteyl deleted, this period is 2 years after the last interaction for registered users of the international market.

your rights

Review and update your data

You can update the information we store on your behalf by logging into your account and changing your profile information. If you did not use a password when creating an account, you can request a new password by selecting the ‘Forgot your password’ option on the site. If you do not have access to this account, you can contact the Pavaedu Privacy Manager to request a data update.

In line with the regulations of the General Data Protection Regulation, you have the following rights:

Right to be informed

You have the right to inform you about why and how we collect your personal data, how we use this information, with whom we share it, what security measures we take to protect it, and what your individual rights are. We provide all this information in this Privacy Statement.

Access right

You have the right to access the information we hold for you by logging in or requesting your online profile, if a permanent registration is required, you can download it in PDF format. Alternatively, you can make an offline Topic Access Request by contacting your Pavaedu link or by contacting the Pavaedu Privacy Manager.

Right to rectification

You have the right to update the erroneous or missing data we hold. You can request that your data be updated through your Hotcourses link or through the Hotcourses Privacy Manager.

Right to erasure

 You have the right to be forgotten at any point by contacting the Privacy Manager or  sending an e-mail to info@pavaedu.com . Upon your request, we will remove all your legally required information.

Right to restrict processing

When you use one of the above rights, you have the right to restrict processing and it may take some time to process this request. For example, when you contact us to update your information, you have the right to request restrictions until your details are updated.

Right to withdraw consent

For the processing activities we request from you, you have the right to withdraw this permission at any time by clicking the unsubscribe link in any email we send to you or by contacting the Privacy Manager.

The right to appeal

You may object to the processing of your personal data at any time by contacting the Privacy Manager. There may be occasions when we are unable to fulfill these requests, but we will explain it in detail when responding to you.

Not subject to automated decisions and profiling

None of our processing activities are fully automated. There are cases when we process the data to analyze or predict the behavior, but we will ask for your final confirmation when this process includes your personal data.

Right to data portability

If you have provided your personal data to us with your consent or communication obligations, you have the right to request machine-readable data from us when you decide to switch to another data controller.

Sharing your data with partners

We work with many training providers promoting courses on our platforms, and we have agreements and procedures to ensure that your personal data is protected through the service you receive from us.

Your personal data will only be shared with the education providers you interact with on our website. For example, when you send a question to an institution or request a brochure, your details related to your inquiry will be provided to the institution so that your question can be answered directly.

We also provide anonymized site usage data to providers in order to monitor enrollment of users who use our website.

We have data sharing agreements with these training providers to ensure they take operational security and technical measures when processing your personal information.

In the future, all or part of the Hotcourses Group may be sold, acquired, or combined. Under these circumstances, we may share personal data we hold with us.

Link to other websites

There are many links to course provider websites on our website. This privacy statement does not cover these links. We recommend that you read the privacy statements on other websites you visit.

Changes to the Pavaedu Privacy Statement details

The date of the newest version will appear at the top of the page. We may update this Privacy Statement from time to time, please review your personal information each time you submit. If we make significant changes to this notification, we will send you an e-mail notifying you of these changes. If you disagree with these changes, please do not use our websites to provide personal information. You can also delete your account at any time – please see the rights section.

For Your Questions

If you have any questions regarding your personal data, please contact the Privacy Manager at: Privacy Manager
Pava Education 

info@pavaedu.com

If you think we have interfered with your privacy or misused your data, you have the right to file a complaint with ICO.

Site-Specific Privacy Statement

The following section provides information about the collection and processing of personal data specific to the Pavaedu website.

You can access the site from Pava Education .

The site is designed for use by users 16 and older. Users under this age are not allowed to create an account on the website.

What personal data do we collect from you?

The following personal data items are collected as part of the registration process:

• Name
• Surname
• E mail address
• Nationality
• Entry year and month
• episode
• education level
• Preferred educational destination
• Date of birth
• Phone number

If you use Facebook to register or log in to the pavaedu.com website, the following personal data items are collected:

• Name
• Surname
• Gender
• E mail address

How do we process your data?

When using the pavaedu.com website, you can perform the following interactions where we process your personal data:

• Create a user profile
• Posting questions to universities
• Requesting university brochures
• Download ebooks
• Taking advantage of Pava consultancy services
• Reserving for university days
• Adding comments about institutions
• Search filters

Approval options

As part of the registration process, you have the option to participate in:

• Newsletters from Pava
• Newsletters of our universities or partners
• Surveys
• Sharing information with institutions when consultancy service is requested 
• If you log in to the pavaedu.com website using Facebook, you have the option to share your activity on the Pava Education site with your Facebook friends.

Data sharing

When you send a question to an educational institution or request a brochure from the educational institution, your contact information will be shared with that educational institution.

If you have requested consultancy service through the Pava Education site, your data will be shared with Pava Consulting, the parent company of Pavaedu and also physically performing the consultancy service.