Cleverness Academy
Legal

Privacy Policy

This policy explains what the marketing site clevernessacademy.com collects, why, and on what legal basis. The practice platform dsatcleverness.com is a separate service with its own privacy policy.

Last updated: September 13, 2026

1. Who we are and what this policy covers

Cleverness Academy ("we", "us", "our") is an educational project providing online tutoring. We act as the data controller for the personal data described below.

This policy covers the website clevernessacademy.com: its subject pages, the request form, and correspondence sent to the addresses published on the site. This website has no registration, no user account and no payment processing.

The practice platform dsatcleverness.com is a separate product with its own account, authentication cookies and subscription. Its data processing is described in that platform's own privacy policy, not here.

For any question about your data, or to request access or deletion, contact support@clevernessacademy.com.

Our audience is multi-jurisdictional. We aim to honor the Turkish Personal Data Protection Law (KVKK, Law No. 6698) as our primary regime, and the EU/EEA and UK GDPR for users in those territories. Where a regime grants you stronger rights, those stronger rights apply.

2. What data we collect

We collect only what we need to answer your request and to run the site.

  • Request form data — your name and a contact (phone number or messenger handle), plus an optional comment you write yourself. The form has no other required fields.
  • Correspondence — the content of the emails and WhatsApp, Telegram or LinkedIn messages you send to the contacts published on this site.
  • Hosting technical data — IP address and request logs recorded by our hosting provider, Vercel, when it serves a page.
  • Visit analytics — aggregated, cookieless statistics from Vercel Web Analytics, and Yandex Metrica data: page views, referrer, device and browser type, approximate region, plus on-page session recording (Webvisor: cursor movement, clicks, scrolling, and typing into form fields).
  • Analytics cookies — the _ym_* files set by the Yandex Metrica counter. See the Cookie Policy for details.

We do not collect payment details, passwords, or identity documents on this site. Please do not send health data, documents, or other sensitive information through the request form — none of it is needed to answer you.

3. Why we process it (legal bases)

  • To answer your request and arrange lessons — processing at your request and to prepare or perform our agreement (GDPR Art. 6(1)(b)).
  • To keep the site running and secure — our legitimate interest in a stable, protected service (GDPR Art. 6(1)(f)).
  • To understand how the site is used and improve it — web analytics, based on consent where consent is required, otherwise on legitimate interest (GDPR Art. 6(1)(a) or (f)).
  • To comply with legal obligations — accounting and tax duties arising from agreements we conclude (GDPR Art. 6(1)(c)).

Under the KVKK we rely on the lawful grounds in Art. 5, including explicit consent where it is required.

4. Who we share data with (processors)

We name each provider and its role rather than using generic "third-party service provider" language.

  • Vercel Inc. — hosting, serverless functions and CDN for the site. Processes IP addresses and request logs, and provides cookieless aggregated web analytics.
  • Yandex (Yandex Metrica) — web analytics and Webvisor. Receives visit, device and referrer data plus on-page session recordings.
  • Resend — delivery of website requests to our mailbox. The email contains the name, contact and comment you entered in the form.
  • Messengers and email you choose to use — WhatsApp, Telegram, LinkedIn and your email provider. Those conversations follow their own rules; we do not control their processing.

We do not sell personal data and we do not share it with advertising networks.

5. Storage and international transfers

Our providers operate globally, so your data may be processed outside your own country. Where required, transfers rely on the safeguards provided under the applicable data-protection regime. We do not assert a specific data residency that we have not confirmed.

6. Retention

  • Requests and correspondence — for as long as the conversation is live and a reasonable period afterwards; if lessons start, for the duration of the arrangement and any subsequent legal requirement.
  • Hosting logs — for the retention periods set by Vercel as our infrastructure provider.
  • Analytics data — for the retention period of the relevant service; the _ym_* cookies have their own lifetimes, listed in the Cookie Policy.

After those periods, data is deleted or anonymized. You can ask us to delete your request sooner — write to support@clevernessacademy.com.

7. Your rights

  • Under the GDPR (EU/EEA, UK) — access, rectification, erasure, restriction, portability, objection, and the right to lodge a complaint with your supervisory authority.
  • Under the KVKK (Turkey, Art. 11) — to learn whether your data is processed, request information about the processing, request correction or deletion, and object to results produced solely by automated analysis.
  • Withdrawing consent — where processing is based on consent, you can withdraw it at any time; this does not affect the lawfulness of processing before withdrawal.

To exercise any of these rights, email support@clevernessacademy.com. We will respond within the timeframe required by the law applicable to you.

8. Children and minors

We teach school students in grades 1–12, so a significant share of our learners are minors. A request on this site should be submitted by a parent or legal guardian, and the tutoring arrangement for a child is made with them.

We do not knowingly collect a child's personal data without a parent or guardian involved. There is no automated age check and no formal parental-consent mechanism on this site — this is a disclosure, not a claim that such a flow exists.

Parents and guardians can request access to, or deletion of, a child's data at support@clevernessacademy.com.

9. Security

We state only the controls we actually apply:

  • The site is served over HTTPS/TLS — traffic between your browser and our host is encrypted.
  • Form data is submitted to the server and forwarded by email to our working mailbox; this site keeps no separate database of requests.
  • No payment details and no passwords are collected or stored on this site.

We do not claim certifications (such as ISO 27001 or SOC 2) or signed data-processing agreements with every provider — we state only verified controls.

10. Changes and contact

We may update this policy as the service evolves; the "Last updated" date at the top reflects the current version. Questions: support@clevernessacademy.com.

See also our Terms of Service, Refund Policy and Cookie Policy.

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