Disclosure on the Processing of Personal Data

1. Introduction

Our company is an education and consulting firm that organizes training programs and provides advisory services across various fields.

This Disclosure explains how our company, “Stratify Eğitim ve Danışmanlık” (Lümen Eğitim Danışmanlık Yazılım Teknoloji Limited Şirketi) (the “Company”), collects, uses, shares, and otherwise processes the Personal Data it obtains about the persons listed below:

• Visitors who use the website (“www.stratify.academy” or “www.lumenup.co”)
• People who complete the form under the “Contact” section
• People who complete the form on the “Decision-Making Audit” page
• People who complete the contact form on LinkedIn
• Customer and prospective-customer contacts
• Individuals employed by and/or benefiting from the customers we serve

In this Disclosure, “Personal Data” means any information relating to an identified or identifiable natural person processed by the data controller.

The Company provides this Disclosure as data controller under Law No. 6698 (the “KVKK”) to explain its personal-data processing practices and your rights under the KVKK. This document may be updated as needed to remain consistent with current legislation and amendments.

2. Collection of Personal Data

We may collect the following Personal Data verbally, in writing, or electronically — through automated methods (forms, various communication channels, electronic devices), non-automated methods (such as document archives), or via our business partners:

• Via the “Contact” form: name, surname, email address, phone number.
• Through website usage: IP address, browser version and settings, device identifiers (UDID), and site-usage details (via technologies such as cookies).
• Through the LinkedIn contact form: name, surname, email address, company information.
• To provide training and advisory services: name, surname, email, phone, workplace/role, and data collected from forms and surveys.
• To carry out business operations (such as invoicing): tax identification number.

We may collect your Personal Data directly from you, your employer, official authorities, or publicly available sources. When you submit a form to learn about our services, we may contact you through channels such as email, phone, WhatsApp, SMS, and social media.

3. Purposes of Processing

Your Personal Data set out above is processed primarily for the following purposes:

• Responding to requests for training and advisory services (as directly related to the establishment or performance of a contract).
• Delivering training and advisory services (to fulfill contractual obligations and for legitimate interests).
• Conducting business operations (fulfilling obligations with customers and suppliers, issuing and processing invoices).
• Ensuring the effective and functional operation of the website (for legitimate interests, without harming fundamental rights and freedoms).
• Analytics, statistics, and R&D (analyses and research needed to provide a better experience).
• Improving service quality (requesting feedback and survey participation).

4. Sharing of Personal Data

Personal Data may be shared with service providers we work with to run our operations (such as infrastructure, electronic, and financial service providers), our third-party business partners, and advisory firms. Personal Data may also be shared with financial institutions for invoicing and payment processing.

The Company may share Personal Data to comply with requests from regulators or public authorities, legally enforceable requests, subpoenas, court orders, or other legal requirements.

5. Retention Period

Pursuant to Article 7/1 of the Law, your personal data is processed for the purposes set out in this Disclosure; once those purposes no longer apply and/or upon your request, it will be deleted, destroyed, or anonymized in accordance with the relevant legislation.

6. Your Rights

By applying to the Company, you may exercise the following rights under the Law regarding the processing of your Personal Data:

• (a) To learn whether any of your personal data is being processed;
• (b) To request information about the processing of your personal data;
• (c) To learn the purposes of processing and whether it is used accordingly;
• (ç) To learn the third parties, domestic or abroad, to whom the data has been transferred;
• (d) To request correction if data has been processed incompletely or inaccurately;
• (e) To request erasure or destruction once the reasons for processing no longer exist;
• (f) To request that correction, erasure, or destruction be notified to third parties to whom the data was transferred;
• (g) To object to adverse outcomes arising from processing exclusively by automated systems;
• (ğ) To claim compensation for damages arising from unlawful processing of your personal data.

7. Contact

You may direct questions about your rights regarding the processing of your personal data to the addresses below. Your requests will be resolved as soon as possible and within thirty days at the latest, depending on their nature.

Address: Fenerbahçe Mah. İğrip Sk. No: 13 İç Kapı No: 1 Kadıköy / İstanbul 34726 — Email: kerem@stratify.academy

The Company reserves the right to amend this Disclosure from time to time as it deems necessary.

Last updated: February 2026