PERSONAL DATA PROTECTION LAW (KVKK) DISCLOSURE AND EXPLICIT CONSENT TEXT

As ConnecThrive Information Technologies Education and Consulting Inc. (“ConnecThrive”), we pay the utmost attention to the security of your personal data.

In order for you to benefit from the services offered by ConnecThrive, register on the Website, create your Service Provider and/or Service Recipient Profiles, personalize your platform experience, and ensure that the services offered are performed as required, some of your personal data is processed.

Pursuant to Articles 5, 6, 8, and 9 of the Personal Data Protection Law No. 6698 (“KVKK”), your explicit consent is required for data processing activities other than those provided for by law.

This text relates only to data processing and data transfer activities that require your explicit consent.

1. PERSONAL DATA PROCESSED BY CONNECTHRIVE REQUIRING EXPRESS CONSENT

You can access your processed personal data, the purposes for which this data is processed, and the legal grounds for processing activities in the table below:

Person Group	Personal Data Category	Personal Data	Purpose of Processing	Legal Grounds
Service Provider	Identity	First Name, Last Name, Title, Date of Birth, Gender, Nationality	Profile Creation and Publication Service Processes Verification	KVKK Article 5/1 – Explicit Consent
Service Recipient	Identity	First Name-Last Name	Profile Creation and Publication Service Processes Verification	KVKK Article 5/1 – Explicit Consent
Service Provider	Communication	Phone, Email, Address	Communication Processes, Notifications, Account Verification	KVKK Article 5/1 – Explicit Consent
Service Recipient	Communication	Phone, Email	Communication Processes, Notifications, Account Verification	KVKK Article 5/1 – Explicit Consent
Service Provider	Area of Expertise Experience	Areas of Expertise, Service Language, Years of Experience, Total Hours of Service	Profile Creation and Viewing, Matching Processes, Service Verification	KVKK Article 5/1 – Explicit Consent
Service Provider	Documents	Diplomas, Certificates, Profile Photo, Title Images (ACC, PCC, MCC, etc.)	Competency Verification, Profile Creation and Viewing, Information Accuracy	KVKK Article 5/1 – Explicit Consent
Service Provider	Finance	IBAN, Bank Details, Fee, Invoice Data	Payment Processes, Billing, Financial Obligations	KVKK Art. 5/2 (c) – Establishment/Performance of the Contract / KVKK Art. 5/2 (ç) – Legal Obligation
Service Recipient	Finance	Transaction ID, Payment Amount, Transaction Time, Payment Status (Successful/Failed), Payment Provider Verification Information	Maintaining Transaction Records, Verifying Service Delivery, Integrating with the Payment Provider	KVKK Art. 5/2 (c) – Establishment/Performance of the Contract / KVKK Art. 5/2 (ç) – Legal Obligation / KVKK Art. 5/2 (f) – Legitimate Interest
All Users	Transaction Security	IP, Device Information, Log Records	System Security, Detection of Suspicious Transactions	KVKK Art. 5/2(a) – Provided for by Law / KVKK Art. 5/2(f) – Legitimate Interest
All Users	Marketing	Usage Data, Preferences	Personalization, Campaigns, Experience Improvement	KVKK Article 5/1 – Explicit Consent
All Users	International Data Transfer	All Personal Data Categories	Technical Infrastructure, Cloud Services, Communication Infrastructure	KVKK Article 9 – Transfer with Explicit Consent

2. Data Processing Purposes Requiring Explicit Consent

The processing of some of your personal data within the scope of user registration, profile creation, service receipt, and service provision processes carried out on the ConnecThrive Website falls under the exceptions set forth in Articles 5/2 and 6 of the Law; however, the following operations will only be performed based on your explicit consent. In this context, your explicit consent applies to both service providers and service users.

2.1. CREATION, PUBLICATION, AND DISPLAY OF PROFILE INFORMATION

With your explicit consent;

• First name–last name, title, areas of expertise, years of experience, total coaching/mentoring hours, languages served,
• Diplomas, certificates, title visuals (ACC, PCC, MCC, etc.),
• Profile photo, short biography, service descriptions,
• Information shared by users on their profile pages at their own discretion,

It can be published on the Website in a manner visible to other users.

This scope is necessary for both Professionals to be able to offer their services and Service Recipients to be able to select a Professional.

2.2. MARKETING, PROMOTION, AND PERSONALIZED CONTENT DELIVERY

With your explicit consent;

• Campaign, announcement, informational, program, training, and event content,
• Personalized recommendations based on your website usage history,
• Promotional and marketing messages via email, SMS, and mobile notifications

may be sent to you.

If you wish, you can opt out by sending an email to info@connecthrive.com stating that you do not wish to receive these notifications.

2.3. Tracking Using Cookies and Similar Technologies

With your explicit consent;

• Analysis of website usage behavior,
• Monitoring of visitor traffic,
• Experience improvement and personalization,
• Interest-based advertising activities using advertising cookies

Cookies will be used for this purpose.

2.4. DATA TRANSFER ABROAD

ConnecThrive uses:

• Hosting services,
• Server and cloud infrastructure,
• Email services,
• Analytics and communication tools

which may be located abroad.

Therefore, in accordance with your explicit consent;

• Your profile information,
• Your contact information,
• Your technical usage data,
• Your professional and financial transaction records,

may only be transferred abroad with appropriate security measures in place.

2.5. Financial Data Related to Payment Transactions

Payments are made through third-party payment providers, therefore, in accordance with your explicit consent;

• Transaction ID,
• Payment amount,
• Transaction time,
• Payment status,
• Payment provider verification details

Processed by ConnecThrive.

2.6. PROCESSING OF MESSAGING, CALLING, AND SERVICE-RELATED CONTENT

On the Website, belonging to you:

• Message content,
• Meeting notes,
• Service request information,
• Other content you share through the system

is processed solely for the purpose of providing services and ensuring security, in accordance with your explicit consent; it is not shared with third parties.

3. TRANSFER OF PERSONAL DATA

Your personal data may be transferred to the persons and organizations specified below in accordance with the purposes specified in this Consent Statement and in compliance with the data transfer conditions stipulated in Articles 8 and 9 of the Law, provided that the necessary technical and administrative measures are taken to ensure data security.

3.1. TRANSFER TO RECIPIENT GROUPS LOCATED WITHIN THE COUNTRY

Your personal data may be transferred to:

• Legally authorized public institutions and organizations,
• Judicial and administrative authorities,
• Payment service providers,
• Suppliers from whom we receive technical services, hosting, messaging, and analysis services,
• Our business partners (only when necessary to perform the relevant service),
• To independent audit firms with auditing authority,
• To third parties from whom we receive occupational safety and legal advisory services in mandatory situations,
• To the other party when necessary to match service providers with service recipients,
• may be transferred to the extent required by law.

In this context, data transfer is carried out in accordance with the provisions of Article 5/2(c) (establishment or performance of a contract), 5/2(ç) (legal obligation), 5/2(a) (provided for by law), and 5/2(f) (legitimate interest) of the Law.

3.2. TRANSFER ABROAD

ConnecThrive’s;

• Server services,
• Cloud storage solutions,
• Email service providers,
• Analytics tools,
• Technical infrastructure services.

As it may be located abroad, your personal data listed below may only be transferred abroad with your explicit consent:

• Your profile information,
• Your contact information,
• Your expertise and experience data,
• Your transaction and log records,
• Your website usage data,
• Payment transaction verification information,
• Cookie data and analytics information.

Your personal data may be transferred abroad in accordance with the methods specified in Article 9 of the Law and the Regulation on the Procedures and Principles Regarding the Transfer of Personal Data Abroad, provided that such transfer complies with the relevant legislation.

3.3. TRANSFERS BETWEEN SERVICE RECIPIENTS AND SERVICE PROVIDERS

In ConnecThrive’s core business model;

• The service provider’s profile, so that the service recipient can make a selection,
• The service recipient’s contact information, so that the service provider can offer the service

may only be shared between the parties for the purpose of carrying out the relevant process.

This sharing constitutes a mandatory data transfer for the establishment or performance of the contract under Article 5/2(c) of the Law.

3.4. DATA TRANSFER IN PAYMENT PROCESSES

Payments are made through third-party payment providers, therefore, in accordance with your explicit consent, with the payment provider;

• Transaction verification,
• Reference number,
• Payment status,
• Transaction time, and similar

mandatory information is shared.

3.5. Security Measures Taken During Transfers

In transfer processes:

• Encryption,
• Access permission restrictions,
• Logging,
• Confidentiality agreements,
• Security measures compliant with the KVKK

is being implemented.

4. METHODS OF COLLECTING PERSONAL DATA AND LEGAL GROUNDS

Your personal data;

• Registration forms on the website,
• Profile creation screens,
• Messaging records,
• Payment page and through the payment provider,
• Cookies, log records, and technical usage data

is collected electronically through it.

Legal reasons:

• KVKK Art. 5/2(c) – Establishment or performance of a contract
• KVKK Art. 5/2(ç) – Compliance with the legal obligation of the data controller
• KVKK Art. 5/2(a) – Expressly provided for by law
• KVKK m.5/2(f) – Legitimate interest
• KVKK m.5/1 – Explicit consent (marketing, transfer abroad, publication of expert profiles, etc.)

Special category personal data shall only be processed under the legal conditions set forth in Article 6 of the Law or with explicit consent.

5. DATA SUBJECTS’ RIGHTS

By contacting ConnecThrive, the data controller under Article 11 of the KVKK:

• Find out whether your personal data is being processed,
• Requesting information about whether your data has been processed,
• Learning the purpose of processing and whether it is being used appropriately,
• Learning the individuals or institutions to whom your data has been transferred,
• Requesting the correction of incomplete or incorrectly processed data,
• You have the right to request the deletion or destruction of your data if the processing conditions no longer apply,
• to request that these actions be communicated to third parties to whom the data has been transferred,
• and to request compensation for damages incurred due to unlawful processing.

You can send your applications to info@connecthrive.com.

By creating a ConnecThrive account, you consent to the processing of your personal data specified in this Information and Consent Statement, the transfer of such data to service providers located within and outside the country as necessary, the creation of service recipient and service provider profiles, and the use of such data for the purposes of the Website, Digital Solution, and/or Services; and to be transferred to service providers located within and outside the country when necessary; and to be used for the purposes of creating service recipient and service provider profiles, executing service processes, providing payment integrations, and ensuring Website security.

The statements regarding the processing of personal data have been provided to you, and your continued use of the Website, Digital Solution, and/or Services indicates that you have read and understood this text and accept it.