GDPR Privacy Notice

Pensión Research & Consulting (“Company”) places great importance on the protection and privacy of your personal data. In accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable data protection legislation, we take appropriate technical and organizational measures to ensure that your personal data is processed lawfully, fairly, transparently, securely, and only for specified purposes. This Privacy Notice explains what personal data we collect, how and why we process it, with whom it may be shared, how long it may be retained, and the rights you have regarding your personal data.

1. Data Controller

• Company: Pensión Research & Consulting
• Address: Sahrayı Cedit, Atatürk Cd. No: 69, 34734 Kadıköy/İstanbul, Türkiye
• Phone: +90 (539) 425 51 39
• Email: info@pensionrc.com
• Website: www.pensionrc.com

2. Personal Data We Process

Depending on your interaction with our website and services, we may process the following categories of personal data:

• Identity Information: First name, last name and, where legally required, identification information.
• Contact Information: Telephone number, email address and postal address.
• Payment and Billing Information: Billing details, transaction information and payment-related information. Credit or debit card details are processed by authorized payment service providers and are not stored by the Company.
• User Account Information: Username, password, registration date and account-related information.
• User Transaction Information: Purchased courses or services, login and logout records, IP address, access dates and usage history.
• Technical Information: IP address, browser type, device information, operating system, cookie identifiers and website usage logs.
• Request and Complaint Information: Customer support requests, correspondence, complaints and feedback.
• Marketing Information: Marketing preferences, newsletter subscriptions and records of consent provided for promotional communications.

3. Purposes of Processing Personal Data

Your personal data may be processed for the following purposes:

• Providing access to online courses, training materials and related services,
• Managing user registrations, memberships and accounts,
• Processing orders, payments, invoices and accounting transactions,
• Providing customer service and technical support,
• Responding to requests, inquiries and complaints,
• Managing contractual relationships with our users and customers,
• Sending newsletters, campaigns, announcements and promotional communications where you have provided the required consent,
• Fulfilling our legal and regulatory obligations,
• Improving the quality, security and functionality of our website and services,
• Conducting statistical analysis, reporting and service performance evaluations,
• Preventing fraud, misuse, unauthorized access and unlawful activities.

4. Legal Basis for Processing

We process your personal data only where a lawful basis exists under the GDPR. Depending on the nature of the processing activity, your personal data may be processed on one or more of the following legal bases:

• Consent: Where you have given your consent for a specific processing activity, such as receiving marketing communications.
• Performance of a Contract: Where processing is necessary to provide products or services you have requested or to perform our contractual obligations.
• Legal Obligation: Where processing is necessary for compliance with applicable laws, regulations, accounting requirements or other legal obligations.
• Legitimate Interests: Where processing is necessary for the legitimate interests pursued by the Company or a third party, provided that such interests do not override your fundamental rights and freedoms.

5. Collection of Personal Data

Your personal data may be collected directly from you or automatically through your use of our services. Personal data may be collected through:

• Our website, www.pensionrc.com,
• Registration and account creation forms,
• Contact and application forms,
• Email communications,
• Telephone communications,
• Customer support services,
• Social media platforms,
• Online payment service providers,
• Cookies and similar technologies used on our website.

6. Sharing and Transfer of Personal Data

Your personal data may be shared only where necessary and in accordance with applicable data protection legislation. Depending on the service provided, your personal data may be shared with:

• Authorized public authorities and regulatory bodies where legally required,
• Payment service providers and financial institutions,
• Accounting and financial service providers,
• Information technology and technical support providers,
• Hosting, cloud infrastructure and data storage providers,
• Email and communication service providers,
• Analytics and website performance service providers,
• Professional advisers such as accountants, lawyers or consultants where necessary,
• Business partners and third-party service providers where necessary for the provision of our services.

We do not sell, rent or commercially disclose your personal data to third parties without an appropriate legal basis.

7. International Data Transfers

Some of the service providers we use may process or store personal data outside the European Economic Area (“EEA”). Where personal data is transferred internationally, we take appropriate measures to ensure that the transfer complies with applicable data protection requirements.

Where required, such transfers may be based on an adequacy decision, appropriate safeguards such as Standard Contractual Clauses (“SCCs”), or another lawful transfer mechanism permitted under the GDPR.

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal, accounting or regulatory obligations, establish or defend legal claims, and manage our contractual relationships.

The applicable retention period may vary depending on the type of personal data, the purpose of processing and applicable legal requirements. Once the relevant retention period expires, personal data will be securely deleted, anonymized or otherwise disposed of in accordance with applicable legislation.

9. Your Rights Under the GDPR

Subject to the conditions and limitations provided under the GDPR, you may have the following rights regarding your personal data:

• Right to Access: You may request information about whether we process your personal data and obtain a copy of such data.
• Right to Rectification: You may request the correction of inaccurate or incomplete personal data.
• Right to Erasure: You may request the deletion of your personal data where the applicable legal conditions are satisfied.
• Right to Restriction of Processing: You may request that the processing of your personal data be restricted in certain circumstances.
• Right to Data Portability: Where applicable, you may request to receive personal data you have provided to us in a structured, commonly used and machine-readable format.
• Right to Object: You may object to certain processing activities based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before your consent was withdrawn.
• Rights Related to Automated Decision-Making: Where applicable, you may have rights regarding decisions based solely on automated processing, including profiling.

10. Exercising Your Rights

To exercise any of your data protection rights or to request further information regarding the processing of your personal data, you may contact us using the following details:

• Company: Pensión Research & Consulting
• Address: Sahrayı Cedit, Atatürk Cd. No: 69, 34734 Kadıköy/İstanbul, Türkiye
• Phone: +90 (539) 425 51 39
• Email: info@pensionrc.com

We will respond to valid requests without undue delay and, in principle, within one month of receiving the request, subject to the conditions permitted under applicable data protection legislation.

11. Right to Lodge a Complaint

If you believe that the processing of your personal data violates applicable data protection legislation, you have the right to lodge a complaint with the competent data protection supervisory authority.

12. Data Security

We implement appropriate technical and organizational security measures designed to protect personal data against unauthorized access, accidental loss, alteration, disclosure, destruction or unlawful processing.

These measures may include access controls, SSL/TLS encryption, secure server infrastructure, authentication mechanisms, monitoring, backups and other appropriate security practices.

13. Updates to This Privacy Notice

Pensión Research & Consulting may update this GDPR Privacy Notice from time to time to reflect changes in our services, legal requirements or data processing activities.

Any updated version will become effective when published on www.pensionrc.com.