YanYana “PRIVACY POLICY”

1.Introduction

Welcome to the YanYana Privacy Policy ("Policy"). The Policy you will read below discloses how we collect, process and share information relating to the users of our Application. Protection of personal data is an unconditional priority of YanYana and we give utmost importance in complying with the applicable legislation and ensuring the safety of our users.


The conditions of use and protection of the information we obtain about you and the services you request while enjoying the YanYana Application (“Application” “App”) are operated by İnnova Bilişim Çözümleri A.Ş. ("Innova” “Company"), who is the joint data controller of the personal data processed by YanYana along with the educational institutions that use our application to bring YanYana educational tools to children globally. By collaborating with our Application and requesting to benefit from the services we offer, you agree to the terms set out in this Privacy Policy.

Children's Privacy


At YanYana, children are the heart of our app. Keeping their personal data safe is our top priority, which is why we follow strict global data protection rules to ensure their privacy and security.


We understand the importance of protecting children's privacy and take extra technical steps to safeguard any personal information we collect from children on our sites and applications. YanYana does not collect any personal data directly from children. All personal data inputted in the YanYana app shall be done so through the educational institution. Please consult our Terms of Use for more detail.


2. Categories of Personal Data We Collect


YanYana collaborates with educational institutions, and while doing so processes certain registration and profile information. Some of the information we collect from the Application which are of identified or identifiable nature classify as personal data and require a valid legal basis before any processing activities.


3. Legal Bases for Personal Data Processing

Below you can find each of the legal bases for the categories of personal data we collect:

Contractual Necessity: We need to receive certain categories of personal data in order to be able to offer our services. Such personal data includes: Registration information (name, surname, photograph, gender, mobile phone number, date of birth, username and password) Profile Information (activity on the app and engagement with the education tools, progress levels of students)

Legitimate Interest: We rely on our legitimate interests to facilitate networking opportunities in the YanYana app: Device Information

3.1. Registration Information

While creating a profile on the YanYana app; educational institutions shall collect the below information from children:

Name

Surname

Gender

Date of Birth

One photograph

Profiles of Assigned “Instructor 1” and “Instructor 2”

Names of “Relative 1” and “Relative 2”*


*All procedures regarding obtaining the consent of the relatives of children belong to educational institutions and YanYana does not hold any responsibility regarding the input of names of relatives. Please consult our Terms of Use for more detail.


While creating a profile on the YanYana app; educational institutions shall collect the below information from instructors:

Name

Surname

Gender

One photograph

Mobile Phone Number

Email Address

3.2. Profile Information

YanYana App shall process the below information after registration:


Activity on the App (such as engagement with the educational tools)

Progress Levels of Students

Camera and Voice Recordings During the Proceeding of the Services Given by the Application*


3.3. Disclaimer Regarding Camera and Voice Recordings


Momentary Capture of Camera and Voice Recordings


YanYana may utilize camera and voice recording functionalities for the purpose of providing enhanced user experiences and services. However, these recordings are strictly momentary and are not stored or retained by YanYana for any period of time.


No Retention of Recordings
YanYana guarantees that all camera and voice recordings are transient and will be used only for the immediate purpose for which they are captured. Once the intended purpose is achieved, the recordings will be immediately discarded and will not be stored, saved, or otherwise retained in any form.

3.4. Device Information

When you use the YanYana App, we may gather information about your device, including the unique device identifier, device model, and operating system, for various purposes outlined in this policy.

4. Use of Information

We may use your registration and other related information for various purposes, including:

Providing our services and features.

Keeping you informed about App updates and new features.

Personalising the content children and instructors receive on the App.

Conducting research and analytics to understand how children and instructors use and engage with the App.

Testing new technologies and processes to improve the App.

Resolving disputes, addressing issues, and enforcing our Terms & Conditions.

Investigating and pretending fraud and other illegal activities, protecting our legal rights, and enforcing our Terms & Conditions.

Ensuring legal compliance .

Safeguarding our users and third parties from potential harm.

 

6. Rights of Data Subjects


The data protection legislation of your country may provide you the following rights:


1. Right to Information: on whether processing activities take place regarding your personal data; on the purposes of the processing activity relating to your personal data and whether they are processed in compliance with the established purposes; on the third-parties to whom your personal data are transferred in Türkiye or abroad.

2. Right to rectification: Requesting the rectification of any incomplete or inaccurate personal data

3. Right to erasure: to request the erasure or destruction of your personal data

4. Right to request reporting of the operations specified in law to third parties to whom your personal data have been transferred

5. Right to object to the occurrence of a result against yourself by analysing the data processed solely through automated systems

6. Right to claim compensation for the damage arising from the unlawful processing of your personal data.

If you have a consideration or question about how YanYana processes your personal data, you can contact us in the first instance help@yanyana.io

If you contacted us and still think that we have not adequately addressed your concern, you have the right to make a complaint with Data Protection Authority of your Country.

7. Data Transfers and Storage

7.1. Restriction on Cross-Border Data Transfers
YanYana is committed to ensuring the privacy and protection of our users' personal data. To this end, YanYana strictly prohibits the transfer of any personal data of our users outside the jurisdiction of Türkiye. All data processing activities are confined within the boundaries of Türkiye, in compliance with local data protection laws.

7.2. Disclosures to Third Parties

Innova does not disclose personal data of users to any shareholders and collaborating organisations involved in our activities.


In situations involving law enforcement or when mandated by law, we may reveal your information if reasonably deemed necessary: (i) to adhere to a legal process, such as a court order, subpoena, or search warrant, government/law enforcement investigation, or other legal obligations; (ii) to aid in the prevention or detection of crime, always in accordance with applicable law; or (iii) to ensure the safety of any individual.


YanYana explicitly assures that it does not rent, sell, or share the personal information of users with others.


7.3. Data Storage in Türkiye
All personal data collected and processed by YanYana is securely stored on servers operated by Innova. These servers are physically located within Türkiye.

7.4. Data Security Measures
YanYana employs comprehensive security measures to safeguard personal data stored on secured İnnova servers. These measures include, but are not limited to, encryption, access controls, regular security audits, and monitoring to protect against unauthorized access, disclosure, or loss of data.

8. Data Retention and Deletion


We retain your personal information only for the duration necessary based on the legal basis we rely upon and in accordance with applicable law:

1. Necessity to retain data to comply with applicable laws (e.g., retention of personal data related to in-app purchases for tax and accounting purposes).

2. Requirement to maintain information as evidence of adherence to applicable laws (e.g., retaining account details and a record of the behaviour leading to an account block for evidential purposes in the event of queries or legal claims related to the block).

3. Existence of an ongoing issue, claim, or dispute that mandates the retention of relevant information until resolution.

4. Essential retention of information for our legitimate business interests, such as fraud prevention and the enhancement of user safety and security (e.g., retaining information to prevent a user banned for unsafe behaviour or security incidents from creating a new account).

 

9. Changes to this Policy

We may change this Privacy Policy at any time, in which case we will notify you by posting the changes on the website. We may, in certain material circumstances, notify you of such changes by e-mail or other conspicuous method reasonably designed to notify you, with additional notices as appropriate. If, upon being notified of such changes, you do not cancel your membership and continue to use our services after the notice period, you will be deemed to have expressly consented to the changes to our privacy policy. You reserve the right to close your account (if any) at any time if you do not agree to the terms of this privacy policy or any updated privacy policy.