KVKK Information Notice
This notice is prepared for the EduDiamond AI mobile app under Article 10 of Turkish Personal Data Protection Law No. 6698 (the “Law”) and the Communiqué on the Procedures and Principles of the Obligation to Inform. The Turkish version prevails in case of conflict.
If you sign in with your EduDiamond account, the EduDiamond KVKK Information Notice also applies.
1. Data controller
Codesseum Yapay Zeka Hiz. San. Tic. Ltd. Şti., Fevzi Çakmak Mah. İstanbul Cad. No 68/4, Yalova, Türkiye, help@edudiamond.com.
For students signing in with an EduDiamond institution account, the student’s institution is the data controller; Codesseum acts as data processor on the institution’s instructions. In the direct relationship with individual users, Codesseum is the data controller.
2. Categories of personal data
- Identity and contact: name, email; for individual users under 13, parent name and email.
- Customer transaction: Firebase user ID, sign-in method, grade, goal, birth year, institution and branch, subscription records, consent and parental consent records.
- Learning content: question photos and text, follow-up and topic questions, generated solutions, notebook entries and notes.
- Usage: daily solution and question counters, error counts.
- Transaction security: IP address, request time, app version, error logs.
Processing special categories of personal data is neither intended nor required.
3. Purposes
Running membership and account operations, authentication, solving school questions and explaining topics with AI, providing the notebook, applying the daily limit and subscriptions, obtaining parental consent for users under 13, handling requests and complaints, information security, abuse prevention, service improvement and compliance with legal obligations.
4. Legal bases (Law Art. 5 and 6)
- Necessary for the conclusion or performance of a contract (Art. 5/2-c): account, profile, solving, notebook, subscription.
- Compliance with a legal obligation (Art. 5/2-ç): parental consent, records under Law No. 5651, financial records.
- Establishment, exercise or protection of a right (Art. 5/2-e).
- Legitimate interest, provided it does not harm fundamental rights (Art. 5/2-f): usage counters, security, abuse prevention.
- Explicit consent: transfer of question content to the AI provider abroad (Art. 9). Asked separately and explicitly in the app; can be withdrawn at any time.
5. Transfers (Law Art. 8 and 9)
- AI provider: Anthropic PBC (USA). Only content the task needs (question photo/text, follow-up and topic questions, grade and goal) is sent; name, email and account ID are not. The provider does not use the content for model training. Basis: explicit consent (Art. 9).
- Authentication and hosting: Google LLC – Firebase (USA), under the conditions of Art. 9.
- Payments and distribution: Apple Inc. and Google LLC (subscriptions, as independent controllers).
- Institution: for institution users, to the institution as data controller.
- Competent public authorities: when legally required.
Data is not sold or shared for advertising or marketing.
6. Method of collection
Data is collected by automated and partly automated means through the mobile app (sign-in, setup, camera and gallery, typed questions, notebook), Firebase authentication, EduDiamond institution sign-in, App Store and Google Play subscription notifications, and server logs.
7. Retention
Account and profile while the account is open; notebook solutions until the user deletes them; unsaved solutions, photos and daily counters 90 days; technical logs up to 2 years; records the law requires for the statutory period. Afterwards data is deleted, destroyed or anonymised.
8. Your rights (Law Art. 11)
You may learn whether your data is processed; request information; learn the purpose and whether it is used accordingly; know the third parties in Türkiye or abroad to whom it is transferred; request correction; request deletion or destruction under Art. 7; request that corrections, deletions and destructions be notified to those third parties; object to an adverse result arising solely from automated analysis; and claim compensation for damage caused by unlawful processing.
9. Requests
Send your request to help@edudiamond.com, stating your identity and request clearly (writing from your account’s email speeds up verification). Requests are concluded free of charge within 30 days; if the action incurs an extra cost, the Board’s tariff may apply.
Institution users should first direct requests about student data to their institution; we forward such requests we receive and follow up. You may also complain to the Turkish Personal Data Protection Board.