KVKK & Privacy

Website Privacy Policy

Your visit to this website and your use of the information/services provided through this site are subject to the terms outlined in this "Privacy Policy" regarding how the information we obtain about you and the information/services you request will be used and protected. By visiting this website and requesting to use the services we offer through this website, you agree to the terms specified in this "Privacy Policy."

I. Purpose of the Personal Data Protection and Processing Policy

Due to the sensitivity of the information and services provided by Adler Coaching Education and Management Consulting Inc. to date, the data obtained from our customers or prospective customers has been kept confidential and has not been shared with third parties. The protection of personal data is a fundamental policy of our company. Even before any legal regulations were in place, our company and its affiliates prioritized the confidentiality of personal data and adopted this as a working principle. Furthermore, our employees have work instructions in line with this principle. As Adler Central Europe, we commit to complying with all responsibilities brought by the Personal Data Protection Law. The principles related to the protection of personal data by Adler Central Europe also encompass our affiliates.

II. Scope and Modification of the Personal Data Protection and Processing Policy

This policy, prepared by Adler Central Europe, is in accordance with the Personal Data Protection Law No. 6698 (“KVKK”). The data obtained from you with your consent or as per other lawful bases specified in the Law will be used to improve the quality of the services we offer and enhance our quality policy. Some of the data in our possession are also anonymized and de-identified. These data are used for statistical purposes and are not subject to the Law or our Policy.

The “Adler Central Europe Personal Data Protection and Processing Policy” aims to protect the automatically obtained data of our customers, prospective customers, employees, customers and employees of companies with whom we have a solution partnership, and other individuals, and includes relevant regulations.

Adler Central Europe reserves the right to amend our Policy and Regulations, provided that they comply with the Law and ensure better protection of personal data.

III. Fundamental Rules Regarding the Processing of Personal Data

a) Compliance with Law and Integrity Principles: "Adler Central Europe" questions the source of the data it collects or receives from other companies and emphasizes obtaining such data in compliance with the law and principles of integrity. In this context, Adler Central Europe provides necessary warnings and notifications to third parties who sell the services it offers to ensure data protection.

b) Accuracy and Up-to-Dateness When Necessary: Adler Central Europe" values the accuracy of all data it holds, ensuring it does not contain incorrect information. Additionally, it prioritizes updating personal data when changes are communicated to it.

c) Processing for Specific, Explicit, and Legitimate Purposes: Adler Central Europe processes data only for the purposes for which it has obtained consent from individuals during the service provision. It does not process, use, or allow the use of data for purposes beyond this.

d) Relevance, Limitation, and Proportionality: Adler Central Europe uses data only to the extent necessary and relevant to the purposes for which they are processed and as required by the service.

e) Retention for the Period Stipulated by Relevant Legislation or Required for the Purpose for Which They Are Processed: Adler Central Europe retains data stemming from contracts for the duration specified by the Law's dispute periods, commercial and tax law requirements. However, once these purposes no longer exist, it deletes or anonymizes the data.

Principle of Maximum Savings/Frugality Principle

According to this principle, known as the principle of maximum savings or the frugality principle, Adler Central Europe only processes the data it receives to the extent necessary. Therefore, the data we collect is determined based on the purpose. Unnecessary data is not collected. Other data that reaches Adler Central Europe is similarly transferred to Adler Central Europe's information systems only if necessary.

Deletion of Personal Data

When the legally required retention periods expire, judicial processes are completed, or other necessities no longer apply, these data are deleted, destroyed, or anonymized by our company either automatically or upon the request of the relevant individual.

Accuracy and Data Currency

As a rule, the data held by Adler Central Europe is processed based on the declarations of the individuals concerned. Adler Central Europe is not obligated to verify the accuracy of the data declared by customers or individuals in contact with Adler Central Europe and does not do so due to legal and operational principles. The declared data is assumed to be accurate. The principle of accuracy and currency of personal data is also adopted by Adler Central Europe Our company updates personal data processed from official documents it receives or upon the request of the individual concerned. Necessary measures are taken for this purpose.

Privacy and Data Security

Personal data is confidential, and Adler Central Europe adheres to this confidentiality. Within the company, personal data can only be accessed by authorized personnel. All necessary technical and administrative measures are taken to protect the personal data collected by Adler Central Europe from unauthorized access and to prevent our customers and prospective customers from being adversely affected. In this context, ensuring that software complies with standards, carefully selecting third parties, and adhering to the data protection policy within the company are enforced.

IV. Data Processing Purposes

The collection and processing of personal data by Adler Central Europe will be carried out in line with the purposes specified in the disclosure statement. Data is collected and processed to establish contracts and to provide better services to customers.

V. Customer, Prospective Customer, and Business and Solution Partner Data

As Adler Central Europe, we process your personal data in our capacity as the data controller in accordance with the Personal Data Protection Law No. 6698 and relevant legislation. The categories and descriptions of personal data to be processed in this context are as follows: Name, Address, Telephone Number, Email Address.

Customer feedback, feedback, and complaint data: Comments, opinions, and complaints.

Other: Participation in competitions, raffles, or marketing programs, website membership information.

Collection and Processing of Data for Contractual Relationship

If a contractual relationship has been established with our customers and prospective customers, the collected personal data can be used without the customer's consent. However, this usage is carried out in line with the purpose of the contract. Data is used for the better execution of the contract and as necessary for the service requirements, and is updated by contacting customers when needed. However, the data provided by our prospective customers (potential customers) is processed to provide them with easier and higher quality service subsequently. If these data have not been converted into a contractual relationship upon request, they are deleted.

Business and Solution Partners Data

Adler Central Europe data with both business and solution partners, adopts the principle of acting in accordance with the law. Data sharing with business and solution partners is carried out with a commitment to data privacy, and only the amount of data required for the service is shared. These parties are always required to take measures to ensure data security.

Data processing for advertising purposes In accordance with the Law on Regulation of E-Commerce and the Regulation on Commercial Communication and Commercial Electronic Messages, advertising electronic messages may only be sent to individuals who have previously consented, in compliance with the specified regulations. The explicit consent of the recipient to receive the advertisement is a prerequisite. Adler Central Europe adheres to the details of the "consent" as determined by the same legislation. The consent to be obtained should encompass all commercial electronic messages sent to the recipients' electronic communication addresses for the purpose of promoting your company's goods and services, marketing, promoting the business, or increasing visibility with content such as congratulations and wishes. This consent may be obtained in writing in physical form or through any electronic communication means. What matters is the affirmative declaration of intent by the recipient to accept the sending of commercial electronic messages, along with their full name and electronic communication address.

Data processing carried out by the company due to legal obligations or as expressly envisaged in the law may be processed without additional consent for the purpose of fulfilling the legal obligations explicitly specified in the relevant legislation or fulfilling a legal obligation prescribed by the legislation. The type and scope of data processing activities must be necessary for the data processing activity permitted by law and must comply with the relevant legal provisions.

Company Data Processing

The company may process personal data within the scope of the information/services provided by Adler Central Europe and for legitimate purposes. However, the data must not be used in any way for unlawful services.

Processing of sensitive data

According to the Law, individuals' race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance, association, foundation or union membership, health, sexual life, criminal record, and data related to security measures as well as biometric and genetic data are considered sensitive personal data. Adler Central Europe also takes additional measures determined by the Board for the processing of sensitive personal data.

Adler Central Europe may process sensitive personal data with the individuals' consent only for the purpose for which they were collected, in order to provide better services.

Data processed by automatic systems

Adler Central Europe complies with the Law regarding data processed through automatic systems. Information obtained from these data cannot be used against the individual without their explicit consent. However, Adler Central Europe may make decisions regarding individuals with whom it will transact based on the data in its own system.

User information and internet

Adler Central Europe websites and other systems or applications collect, process, and use personal data. Relevant individuals are informed through a privacy notice and, if necessary, about cookies. Users are informed about our applications on our web pages. Personal data will be processed in accordance with the law. When you visit our website, we provide the following information about the cookies we use/will use on our page.

Data processed through automatic systems regarding employees can be used in internal promotions and performance evaluations. Our employees have the right to object to the outcome against them and do so in accordance with internal procedures. Employee objections are also evaluated internally within the company.

Google (Analytics, DoubleClick)

Purpose of Cookie Usage: Keeping site statistics, measurement, advertising, site improvement

Cookie Type: Functional and analytical cookies, commercial cookies.


Purpose of Cookie Usage: Feedback, customer reviews, customer conversation tracking. Cookie Type: Functional and analytical cookies, commercial cookies.


Purpose of Cookie Usage: Feedback, contact forms, customer conversation tracking. Cookie Type: Functional and analytical cookies.

Functional and Analytical Cookies

Functional and analytical cookies include remembering your preferences, ensuring the effective use of the website, optimizing the website to respond to user requests, and collecting data about how visitors use the site. By their nature, these types of cookies may contain personal information such as usernames.

Third-Party Cookies

Adler Central Europe websites/mobile applications/mobile websites work with third-party trusted, well-known advertising providers. Third-party service providers place their own cookies to serve you personalized advertisements. Cookies placed by third parties collect, process, and analyze visitors' navigation information on websites.

Commercial Cookies

Commercial cookies serve to enhance your user experience by presenting products/content similar to your interests and choices, and by offering a more advanced, personalized advertising portfolio. The retention period for the aforementioned session, persistent, functional, analytical, and commercial cookies is approximately 2 (two) months, and necessary adjustments can be made through individual internet browser settings. Removal from these settings may vary depending on the internet browser.

How to Delete Cookies?

Many web browsers are set to automatically accept and use cookies from the first installation on your computer. You can prevent cookies from being accepted or receive a notification when cookies are sent to your device by using the help or settings menus of your web browser. To learn different ways to manage cookies and obtain detailed information on how to adjust the settings of your browser, you can utilize the instruction or help options screen of your browser.

VII. Transfer of Personal Data Domestically and Abroad

Personal data may be shared with business and solution partners by Adler Central Europe for the purpose of providing the service.

Adler Central Europe may transfer personal data to the individuals and institutions listed below for specific purposes; » Limited to ensuring the fulfillment of the purposes of the business partnership, to the business partners of Adler Central Europe, » Limited to ensuring the provision of services necessary for the commercial activities of Adler Central Europe from external sources, to the suppliers of Adler Central Europe, » Limited to ensuring the execution of commercial activities that require the participation of our company's subsidiaries, to the solution partners of Adler Central Europe, Adler Central Europe has the authority to transfer personal data domestically and abroad in accordance with the conditions determined by the Board in the law, in compliance with the other conditions in the Law and with the consent of the individual.

VIII. Rights of the Data Subject

Adler Central Europe acknowledges that the data subject has the right to give consent before processing data and to determine the fate of their data after processing, in accordance with the Law.

By applying to us through the contact form announced on our website, the data subjects have the right to; a) Learn whether personal data is being processed, b) Request information if personal data has been processed, c) Learn the purpose of processing personal data and whether they are used for their intended purpose, d) Know the third parties to whom personal data is transferred domestically or abroad, e) Request the correction of personal data if it is incomplete or incorrect, f) Request the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7, g) Object to the occurrence of a result against oneself as a result of personal data being analyzed exclusively through automated systems, h) Demand compensation for damages in case of suffering damages due to the unlawful processing of personal data. However, there is no right for individuals regarding anonymized data within the Company. Adler Central Europe may share personal data with relevant institutions and organizations for the purpose of using a judicial authority or state authority's legal powers, in the context of a business or contractual relationship.

Data subjects can submit their requests regarding the aforementioned rights to Adler Central Europe by filling out the contact form on the official website completely and signing it with a wet signature, and sending it to the communication address specified below, by registered mail with return receipt requested, along with photocopies of their identity documents (only the front side photocopy for ID cards). Your applications will be responded to within the shortest possible time or within 30 days at the latest after reaching our company. Your applications must be made by registered mail. Additionally, only the part of your application related to yourself will be answered, and an application made about your spouse, relative, or friend will not be accepted. Adler Central Europe may request additional information and documents from the applicants.

IX. Privacy Policy

Whether employees or other individuals, the data within Adler Central Europe is confidential. No one can use, copy, reproduce, transfer to others, or use for purposes other than business without a contract or legal compliance.

X. Transaction Security

Adler Central Europe takes all necessary technical and administrative measures to protect the personal data collected and ensure that unauthorized individuals do not have access to it, in order to prevent our customers and prospective customers from being harmed. In this context, software is ensured to comply with standards, third parties are carefully selected, and compliance with data protection policies is ensured within the company. Security measures are continuously updated and improved.

XI. Audit

Adler Central Europe conducts necessary internal and external audits regarding the protection of personal data.

XII. Reporting of Violations

Adler Central Europe takes immediate action to remedy any breach of personal data when notified of such breach. It minimizes the damage to the individual and compensates for any harm caused. In the event that personal data is compromised by unauthorized individuals from outside, it immediately reports the situation to the Personal Data Protection Board.

Concerning the reporting of violations, applications can be made through the communication section on the Adler Central Europe website, according to the specified procedures.

According to the Personal Data Protection Law

All requests are processed when sent to the address specified on the contact page by registered mail with return receipt requested, along with a photocopy of identification, as announced on the Privacy and KVKK pages.

Rights regarding personal data can only be exercised for data belonging to the individuals themselves. Complaints regarding data of individuals other than the person making the complaint, and requests without a photocopy of identification attached, will not be considered. Even when data deletion requests are fulfilled, we would like to inform you that we are obligated to share the data with official authorities if requested by them.

Changes to the Personal Data Protection and Privacy Policy:

Adler Central Europe reserves the right to make changes to the statements here. In the event of a significant change, a link to the updated statement will be added to the homepage of the website to ensure access to the current statement. Guests who have registered for any of our products or services may be informed through the communication channels they provided to the facilities. The date of the last update to the statement and the update number are indicated at the end of this text.

Every change made to the statement becomes effective upon publication of the revised statement on the website. Following such changes, using the site or any of our products and services indicates your acceptance of the revised statement valid during that period.

Policy Update: 01.01.2020. KVKK Statement-1

For any questions regarding the privacy policy, you can reach us using the information provided on the contact page.

Best regards
Adler Central Europe