PERSONAL DATA PROCESSING AND PROTECTION DISCLOSURE NOTICE

A. INTRODUCTION

Data privacy is of utmost importance to Sufle Teknoloji A.Ş. (“SUFLE” and/or “COMPANY”), and we particularly care that the processing of your personal data is carried out through a clear and transparent process.

The data controller responsible for processing the data is Sufle Teknoloji Anonim Şirketi, whose information is provided in Section D.

As SUFLE, within the scope of our activities arising from the legislation and legal regulations regarding the Law No. 6698 on the Protection of Personal Data (“KVKK”), we have prepared this Personal Data Processing and Protection Disclosure Notice (hereinafter referred to as the “Disclosure Notice”) in order to inform the relevant data subjects regarding the purposes for which your personal data will be processed, to whom and for what purposes the processed personal data may be transferred, and the method and legal basis for the collection of personal data. Through this Disclosure Notice, SUFLE provides this information to the participants (each referred to as a “Participant”); who fill out the Training Participation Registration Form in order to attend the trainings offered through the website https://www.sufle.io/ or whose information contained in this Disclosure Notice is provided to SUFLE by its business partners for the purpose of participating in the training and to participants who have been contacted regarding the need to pay tuition fees before or after the training.

B. PRINCIPLES REGARDING THE PROCESSING AND TRANSFER OF PERSONAL DATA

Our Company acts in accordance with the principles established and adopted under all applicable legislation, particularly the Constitution of the Republic of Türkiye and the KVKK, regarding the protection of personal data.

We use the personal data we collect from you in several different ways. The table below explains this matter and shows the types of personal data collected, the purposes of collection, collection methods, legal basis/reason, and principles of transfer to third parties:

PARTICIPANT

Data Categories:

● Identity Information (Name-Surname)

● Contact Information (Corporate E-Mail Address (company extension), Corporate Telephone Number)

● Professional Experience (Name and title/position of the company where they work)

● Transaction Information (Message content information added while creating the Registration Form, information on how they became aware of the training, reference code information)

● Financial Information (Bank/Payment Institution Information, Payment Account Information, Payment Details, Account Holder Name, Receipt/Slip/Invoice Information, Bank Account Number, IBAN Number, Statement Information, Account Information)

● Marketing Information (Commercial communication, commercial electronic communication)

Purposes of Processing Personal Data:

Managing participation in the training and training processes, ensuring communication, contacting the participants, providing the training, carrying out post-training processes, conducting accounting transactions, resolving requests, issues and complaints, carrying out communication activities, carrying out goods/services production and operational processes, conducting retention and archiving activities, legal processes and compliance with legislation, ensuring that activities are carried out in accordance with our company procedures and the relevant legislation, and ensuring information and transaction security.

Within the scope of marketing and commercial communication processes; carrying out promotional activities, campaign notifications, customer relations and communication activities for products and services, sending marketing communications, planning and executing corporate management and commercial communication activities, managing customer/prospective customer relations, creating and executing product, service, promotion, advertising, marketing and sales strategies to reach customers/prospective customers, sharing newly planned trainings, carrying out post-training sales and marketing activities, storing data and communication during/after the training.

Legal Basis / Legal Reason for Processing Personal Data:

The personal data within this scope is processed by SUFLE based on the legal grounds specified in Article 5 of the KVKK and the relevant legislation, for the fulfillment of the purposes listed above;

● Processing of personal data of the parties to a contract is necessary, provided that it is directly related to the establishment or performance of a contract,

● Processing of data is mandatory for the legitimate interests of the data controller, provided that it does not prejudice the fundamental rights and freedoms of the relevant person,

● Within the scope of marketing and commercial communication processes, for the purposes of promotion, advertising, marketing, sales, sharing newly planned trainings, and carrying out post-training sales and marketing activities; the existence of explicit consent.

Methods of Collecting Personal Data:

Your personal data specified above is collected through automatic or non-automatic methods within the scope of fulfilling the purposes stated above, through the channels where you contact our Company; in physical/electronic environments, via printed/physical/digital forms, digital registration screens, electronic mail, and verbal interviews conducted face-to-face.

Transfer of Personal Data:

The personal data of the Participants is transferred in accordance with the transfer rules of the KVKK and by taking the necessary technical and administrative measures, only to the extent necessary for the realization of the relevant purpose, to;

● Service providers from whom services are obtained for the execution, management, and reporting of the training organization,

● Legal advisors, financial advisors, and other consultants, judicial authorities, and authorized persons, institutions, and organizations for the purpose of providing information and documents to authorized persons and official institutions required by legal regulations and legislation, fulfilling our other related obligations, and exercising our legal rights in order to fulfill our legal obligations,

● Service providers (IT infrastructure and software providers, database and server service providers, e-mail server service providers) for the purposes of obtaining products and technical service support related to information technologies.

Important Notes:

In the context of training participation and form completion, we kindly request that you do not share your personal email address with our company. Commercial communication activities to be carried out to corporate extension e-mail addresses are considered within the scope of the exception, and within the scope of the Law No. 6563 on the Regulation of Electronic Commerce and related secondary regulations, there is no requirement to obtain a separate commercial electronic communication consent from these persons who are considered merchants/tradespeople.

C. YOUR RIGHTS AS A DATA SUBJECT LISTED UNDER ARTICLE 11 OF THE KVKK

As a data subject, you may submit your requests regarding your rights by filling out the relevant Application Form Regarding Personal Data of the Data Subject attached hereto, in accordance with the procedures and principles specified therein; by applying to our KEP (Registered Electronic Mail) or e-mail address specified in Section D, through an application submitted via your mobile-signed, e-signed, or written-approved e-mail address registered in our systems, or by personally submitting a written application bearing your wet signature to the Company’s physical address specified in Section D through the relevant form, or through a notary public.If you submit your request to our Company, our Company will finalize the request free of charge as soon as possible and within a maximum period of thirty days, depending on the nature of the request. However, if the transaction requires an additional cost, a fee will be charged by our Company in accordance with the tariff determined by the Personal Data Protection Board.

Within this scope, as a data subject, you have the right to:

● Learn whether personal data is being processed,

● Request information if personal data has been processed,

● Learn the purpose of processing personal data and whether such data is used in accordance with its purpose,

● Know the third parties to whom personal data is transferred within or outside the country,

● Request the correction of personal data if it is incomplete or incorrectly processed and request that the transaction carried out within this scope be notified to third parties to whom the personal data has been transferred,

● Request the deletion or destruction of personal data if the reasons requiring its processing have ceased to exist, even though it has been processed in accordance with the Law No. 6698 and other relevant legal provisions, and request that the transaction carried out within this scope be notified to third parties to whom the personal data has been transferred,

● Object to the occurrence of a result against the person by analyzing the processed data exclusively through automated systems,

● Request compensation for damages in case of suffering damage due to unlawful processing of personal data.

D. OUR DATA CONTROLLER INFORMATION

SUFLE TEKNOLOJİ ANONİM ŞİRKETİ

Address : Kozyatağı Mah. Şehit İlknur Keleş Sk. Dural Plaza No: 5/9 Kadıköy/İstanbul-Türkiye

Mersis No : 0782138245300001

KEP : sufle@hs03.kep.tr

Telephone : +90 850 305 1767

E-mail : info@sufle.io

SUFLE TEKNOLOJİ A.Ş.DATA SUBJECT APPLICATION FORM REGARDING PERSONAL DATA

This application form has been prepared in order to evaluate your applications to be made pursuant to Articles 11 and 13 of the Law No. 6698 on the Protection of Personal Data (KVKK) and to contact you where necessary.

As the data subject requesting to exercise your rights regarding your personal data within the scope of Articles 11 and 13 of the KVKK, you are required to fill in the information below. Within this scope, applications made through a written petition or this application form are accepted.

Full Name
Turkish ID Number For foreigners, nationality and passport number or foreign identification number.
Phone Number
E-mail Address
Address
Your relationship with Sufle	● Participant ● Customer ● Employee ● Other (Please specify) _________________________________

Your Request(s) Regarding Your Personal Data

I want to learn whether personal data about me is processed.
If personal data about me is processed, I request information about these data processing activities.
If personal data about me is processed, I want to learn the purpose of processing and whether it is used in accordance with this purpose.
If my personal data is transferred to third parties in Türkiye or abroad, I want to know these third parties.
I think my personal data has been processed incompletely or incorrectly and I request correction thereof (Please specify the reason)
Although my personal data has been processed in accordance with the law and other relevant legal provisions, I believe that the reasons requiring its processing have ceased to exist, and therefore I request that my personal data be:; • a) Deleted. • b) Destroyed. • c) Anonymized.	Your selection: a) b) c)
I request that the third parties to whom my personal data has been transferred also be notified regarding my requests specified in numbers 5 and 6.
I believe that my personal data processed by your Company has been analyzed exclusively through automated systems and that a result has arisen against me as a consequence of this analysis. I object to this result.
I have suffered damage due to the unlawful processing of my personal data. I request compensation for this damage. (Please provide details)

Details regarding the request (Please provide details regarding your request)

You may submit your application regarding these requests related to the implementation of the KVKK by one of the methods specified below;

1. By hand,

2. By registered letter with return receipt,

3. Through a notary public,

By wet signature to Kozyatağı Mah. Şehit İlknur Keleş Sk. Dural Plaza No: 5/9 Kadıköy/Istanbul-Türkiye address, or,

4. By signing with your secure electronic signature issued within the scope of the Electronic Signature Law No. 5070 and sending it to the sufle@hs03.kep.tr KEP address, or,

5. Via your registered and verified electronic mail address to the info info@sufle.io e-mail address,

6. By any other method stipulated by the Personal Data Protection Board,

you may submit it.

You must attach documents enabling the identification of your identity (identity card/driving licence containing Turkish ID number/passport copy etc.) and documents supporting your objection/request to your application.

Your request will be evaluated and concluded as soon as possible and in any case within the period specified in the KVKK. For written applications, the date on which the document is served to Sufle, and for applications made through other methods, the date on which the application reaches Sufle, shall be the application date.

In order for third parties to submit an application request on your behalf, a special power of attorney issued through a notary public in the name of the applicant must be provided. For applications to be made on behalf of children under custody/guardianship, a copy of documents proving the custody/guardianship relationship must be submitted.

Our Company may request information and documents from you in order to determine whether the applicant is you, and may ask you questions regarding your application to clarify the matters specified in the application.

In order for your application to be answered on time, you must complete all information in this form and provide the relevant information and documents. Otherwise, you will first be requested to complete the missing information before a response can be provided. This may extend the response period of your application.

Pursuant to Article 13 of the KVKK, the response to your application will be provided in writing or electronically.

Please specify the method by which the response to your application by our Company shall be notified to you.

● I want it to be sent to my address.

● I want it to be sent to my e-mail address.

If the process requires a cost, a fee determined according to the tariff set by the Board may be charged by our Company.

Data Subject Statement

I request that my application made pursuant to the KVKK be evaluated and concluded within the scope of the request(s) stated above, and I accept, declare and undertake that the information and documents I have provided in this application are accurate, complete, up-to-date and belong to me.

Full Name :

Date :

Signature :