Kariyer Online Education Services Consulting Trade Limited Company

Clarification Notice Regarding the Processing of Personal Data

Dear Spiritual Sciences course candidate, as Kariyer Online Education Services Consulting Trade Limited Company (hereinafter referred to as the "EDUCATION INSTITUTION"), we process your personal data as the "Data Controller" in accordance with the Law No. 6698 on the Protection of Personal Data ("KVKK") and take the necessary administrative and technical measures to ensure compliance within the limits and purposes specified below. Therefore, through this "Clarification Notice Regarding the Processing of Personal Data," we would like to inform you about the processing of your personal data and your rights under KVKK.

A. Personal Data Processed

We may require the following information about you and/or your family members who are Spiritual Sciences course participants:

• Identity information
• Contact information (phone number, email address)
• Personal information (date of birth, nationality)
• Information about your children (name, date of birth, age)
• Credit card number (for banking transactions and reservation purposes)
• Address information (for shipping your certificates or other documents to your address)
• Questions/comments after completing your education
• Information collected about persons under the age of 18 is limited to name, nationality, and date of birth and may only be provided by an adult.
  (Hereinafter, all of the aforementioned data will be collectively referred to as "Personal Data" in the text.)

B. When Your Personal Data Is Collected

Personal data may be collected in various circumstances, including but not limited to the following:

1. Educational Activities:
   • During course registration
   • When making education payments
   • Requests, complaints, and/or disputes

The processing of personal data under KVKK involves obtaining, recording, storing, preserving, modifying, rearranging, disclosing, transferring, inheriting, making accessible, classifying, or preventing the use of data, either in whole or in part, through automated or non-automated means as part of any data recording system.

2. Participation in in-person education or events:

   • Registering for loyalty programs
   • Participating in customer surveys (e.g., Guest Satisfaction Survey)
   • Online education
   • Subscribing to newsletters to receive offers and promotions via email

3. Transfer of information from third parties:

   • Relevant institutions for certificate printing

4. Internet Activities:

   • Connecting to the Spiritual Sciences websites (IP addresses, cookies)
   • Online forms (e.g., e-reservation, surveys, Spiritual Sciences pages on social networks, Facebook login, etc.)

B. Method and Legal Grounds for Processing Your Personal Data

In line with the requirements for service provision within our institution, your Personal Data may be collected and processed by the relevant departments of Kariyer Online and authorized departments through automated or non-automated methods, as specified in Article 3 of this Notice, to facilitate educational and other service processes and/or fulfill all of Spiritual Sciences' legal obligations. These methods include:

• Handwritten records, through Kariyer Online’s websites, via email, postal services, references, or from Kariyer Online's partners (such as universities, the Ministry of National Education, TSV websites) and/or social media accounts;
• Information obtained during meetings conducted in various formats (face-to-face, telephone, teleconference, video conference, fax, etc.).

Your personal data is processed based on the following legal grounds outlined in Article 5 of Law No. 6698:

i. The presence of your explicit consent ii. The necessity of processing as explicitly stipulated by law iii. The need to protect the life or physical integrity of yourself or another person in situations where it is impossible to obtain your consent iv. The necessity for the execution or performance of a contract v. The necessity to fulfill legal obligations vi. The publicization of data by the data subject vii. The necessity of processing for the establishment, exercise, or protection of a legal right viii. The necessity of processing for our legitimate interests, provided that it does not harm your fundamental rights and freedoms.

Your sensitive health-related data is processed based on your explicit consent or under the conditions specified in Article 6 of the Law.

Your personal data is processed in accordance with the Identification Law No. 1774, the Tax Procedure Law No. 213, the Turkish Commercial Code No. 6102, the Law on the Protection of Personal Data No. 6698, and other relevant legal regulations.

Our institution complies with the data processing principles and obligations outlined in the Turkish Constitution, international agreements to which Turkey is a party, EU data protection laws, KVKK, and other related legal regulations.

3. Processing of Special Categories of Personal Data

According to Article 6 of the Law on the Protection of Personal Data No. 6698, some personal data are classified as "special categories" due to their potential risk of causing harm or discrimination if processed unlawfully. These data include race, ethnic origin, political opinions, philosophical beliefs, religion, sect, or other beliefs, clothing, membership in associations or unions, health data, sexual life, criminal convictions, and security measures, as well as biometric and genetic data. Our institution processes these sensitive personal data in accordance with the regulations outlined in Article 6 of the Law on the Protection of Personal Data.

A. Processing Based on Explicit Consent

You may share your sensitive personal data with our institution to request customized services (e.g., requesting a special pillow due to a neck hernia, a ground-floor room due to a heart condition, or peanut-free desserts due to a peanut allergy). To provide you with these personalized services, our institution processes your sensitive personal data only with your explicit consent and solely for the purposes stated.

B. Processing Without Explicit Consent

Sensitive personal data other than your health-related data are processed in cases stipulated by law, while your sensitive health-related data are processed for public health protection, preventive medicine, medical diagnosis, treatment, and care services, as well as for the planning and management of healthcare services, only by authorized institutions and professionals subject to confidentiality obligations.

4. Purposes of Processing Your Personal Data

Your personal data are processed for the following purposes:

A. Fulfilling our obligations towards our customers B. Managing your educational records and education:

• Creating and maintaining legal documents in compliance with accounting standards

5. Transfer of Your Personal Data to Domestic or International Parties

To provide services within the institution, your personal data may be accessed by relevant departments of the university or its branches, and transferred to these entities when necessary.

6. Duration of Processing Your Personal Data

Your personal data will be processed for the period specified by the relevant legislation, or if no period is specified, until the purpose of processing is no longer applicable. After these periods expire, your personal data will be deleted, destroyed, or anonymized in accordance with the regulations, either upon your request or automatically.

You are responsible for informing the institution of any changes in your personal data during this period to ensure the accuracy and currency of your records.

7. Camera Surveillance at Kariyer Online's Main Office

To ensure the safety of the institution, customers, and workplace, cameras are used to monitor entrances, exits, hallways, common areas, and the building’s exterior, with appropriate signage in place. Please note that your rights under the Constitution and KVKK regarding these recordings are protected. The purpose of camera surveillance is to identify incidents such as theft that may occur within the workplace.

Only authorized personnel of the institution have access to these records. The recordings are kept for the period specified by relevant laws and regulations for security purposes, after which they are destroyed.

8. Your Rights as a Data Subject Under KVKK (Article 11)

Under KVKK and other relevant legislation, you have the right to:

i. Learn whether your personal data is being processed, ii. Request information if your personal data has been processed, iii. Learn the purpose of processing your personal data and whether it is being used for the intended purpose, iv. Learn the third parties, either domestically or internationally, to whom your personal data has been transferred.

For these requests to be fulfilled, the legal basis for processing your data must no longer exist, the statutory retention periods must have expired, or the statute of limitations must have passed. Your request for deletion cannot be fulfilled before these periods expire.

v. Request the correction of your personal data if it has been processed incompletely or incorrectly, vi. Request the deletion or destruction of your personal data in accordance with the conditions set forth in KVKK, vii. Request that third parties to whom your personal data has been transferred are informed of the actions taken under sections v and vi, viii. Object to a decision made solely based on automated data processing that produces unfavorable results for you.

9. How to Apply to the Education Institution to Exercise Your Rights

To exercise your rights under KVKK, you can fill out the form on www.kariyer.online, submit a signed copy of the form in person to the Kariyer Online office with your identification documents, send it via a notary or through the methods specified in KVKK, or send the relevant form to www.kariyer.online via email from the email address registered in our system.

We respectfully present this matter for your attention.

Kariyer Online Education Services Consulting Trade Limited Company