Disclosure on the Processing of Personal Data

Membership, email verification, password recovery, webinar orders, agreement acceptance and private learning materials use your name, email, account security data, order/billing details and access records. The Membership and Webinar Privacy Notice separately describes purposes, legal bases, recipient groups and your rights; it is available from registration and checkout forms. Acknowledging a notice does not constitute consent. Marketing permission is not a condition of membership or webinar enrollment.

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

Stratify is operated by Lümen Eğitim Danışmanlık Yazılım Teknoloji Limited Şirketi. This Disclosure explains how 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”, “www.stratify.com.tr” 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.

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.

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).

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.

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.

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.

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.

Legal company name: Lümen Eğitim Danışmanlık Yazılım Teknoloji Limited Şirketi. Registered address: Fenerbahçe Mah. İğrip Sokak No: 13/1, Kadıköy / İstanbul, 34726. Email: kerem@stratify.academy. Phone: +90 532 330 18 16. Tax office: Göztepe. Tax identification number: 6091381177. MERSIS number: 0609138117700001. Trade registry number: 1049457.

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