CLARIFICATION TEXT WITHIN THE SCOPE OF THE LAW NO. 6698 ON THE PROTECTION OF PERSONAL DATA

As LENA STRATEJİ YÖNETİM VE DANIŞMANLIK Anonim Şirketi, we attach the utmost importance to the processing and preservation of all types of personal data belonging to all individuals associated with the COMPANY, including those utilizing our products and services, in accordance with the Law No. 6698 on the Protection of Personal Data (“KVKK”), the privacy of private life, and universal legal norms.

This clarification text contains explanations regarding the information of the data controller, the purposes for which personal data will be processed, to whom and for what purposes it may be transferred, the methods and legal grounds for collecting personal data, and the rights of the personal data subject.

DATA CONTROLLER

The Data Controller is LENA STRATEJİ YÖNETİM VE DANIŞMANLIK Anonim Şirketi.

ADDRESS: MASLAK MAH. TASYONCASI SK. MASLAK 1453 T4 BLOK NO:1 U IC KAPI NO: B97 SARIYER/ ISTANBUL

PHONE: 0212 809 31 49

E-MAIL ADDRESS: info@lenastrateji.com

Our Company manages its registration obligations and declarations in VERBİS (Data Controllers Registry Information System) within the framework of the relevant legislation and in accordance with data security standards.

PURPOSE OF PROCESSING YOUR DATA (KVKK Art. 10/1-b)

Personal data refers to any information relating to an identified or identifiable person. In this context, your data collected by the COMPANY, such as your name, surname, T.C. identity number, address, telephone number, and e-mail address, are processed for the purposes of creating your membership, managing your orders, executing invoicing processes, and providing our training and support services. These processing activities are carried out in a limited and proportionate manner under the categories of “Identity”, “Contact”, “Customer Transaction”, and “Transaction Security” which includes log records.

METHOD AND LEGAL GROUND FOR DATA COLLECTION (KVKK Art. 10/1-ç)

Your personal data is obtained through all types of verbal, written, or electronic media for the purpose of providing our services in line with the aforementioned objectives, and to enable our Company to fully and accurately fulfill its contractual and legal obligations.Your data is collected based on the legal grounds set forth in Article 5/2 of the KVKK, namely: “the establishment or performance of a contract”, “the fulfillment of a legal obligation”, and “the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject”.

TO WHOM AND FOR WHAT PURPOSE THE PROCESSED PERSONAL DATA MAY BE TRANSFERRED (KVKK Art. 10/1-c)

Your collected personal data; may be transferred to our business partners, our suppliers (companies providing logistics and information technology services), legally authorized public institutions and private persons, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVKK, for the purpose of carrying out the necessary work by our business units to enable you to benefit from the products and services offered by our Company.

RIGHTS OF THE PERSONAL DATA SUBJECT ENUMERATED IN ARTICLE 11 OF THE KVKK

As personal data subjects, you have the right to learn whether your data is processed, to request information if it has been processed, to learn the purpose of use, to know the third parties to whom the data is transferred, to request the rectification of incomplete/inaccurate data, and to request the erasure or destruction of your data.

You may submit your requests in writing to our address stated above or to the address info@lenastrateji.com, along with documents verifying your identity. Our Company will conclude your requests within thirty days at the latest.

In the event that a fee is foreseen by the Personal Data Protection Board, a fee may be requested by our Company; and regarding your request, additional information may also be requested in order to understand who the personal data subject actually is, to verify their identity, and to share the information with the correct person.