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PRIVACY PERSONAL DATA PROTECTION

This Privacy Personal Data Policy ("Policy") aims to provide information about personal data collected, stored, processed, shared, and transferred by Nefes AI Software Technologies Limited Company ("Nefes AI", "we", "our company").

This Policy covers all natural persons who visit the Nefes AI website (https://nefes-ai.com), benefit from our services (e.g., a customer making a payment via our website), contact us, are representatives/employees of institutions we collaborate with, or apply for education/consultancy/internship/mobility programs.

The terms "personal data", "personal information", and "your information" are used interchangeably and cover all information relating to an identified or identifiable natural person (e.g., name-surname, email address, date of birth, ID/passport number, payment information).

We are aware of the importance of personal data for our customers and service users; everyone within Nefes AI will make every effort to comply with this Policy and ensure the security of your personal data in all circumstances.

The purpose of this Policy is to:

• Explain our purpose and method of using the data we obtain in the clearest and most understandable way possible,
• Explain, with your consent, what information we obtain and for what purposes and how this information is processed,
• Provide information on the purposes and methods by which this information is transferred to third parties,
• Inform you about your legal rights regarding your personal data,
• Explain our responsibility to protect your rights and privacy.

1. IDENTITY OF THE DATA CONTROLLER

Pursuant to the Personal Data Protection Law No. 6698 ("KVKK"), your personal data may be processed by Nefes AI Software Technologies Limited Company, whose identity information is provided below, as the data controller.

Data Controller: Nefes AI Software Technologies Limited Company Address: Ayazağa Mah. Kemerburgaz Cad. Vadi İstanbul Park Sitesi 7A Blok No: 7B Kat: 2, Sarıyer 34475 İstanbul / Turkey MERSİS No: 0630142275900001 Email: info@nefes-ai.com Web: https://nefes-ai.com

2. PERSONAL DATA COLLECTED BY NEFES AI

We collect various personal data about you when you visit our website, benefit from our services, make payments through our website, or contact us. To effectively and securely provide the services you request, we may collect the following information:

• Personal and identity information: name-surname, Turkish ID number/passport number, date of birth, nationality, address, email address, phone number.
• Payment and financial information: payment instrument information used for payments made through our website. Payment transactions are carried out via iyzico and bank infrastructure, and sensitive data such as card number and CVV are not stored on Nefes AI servers; this data is processed within the PCI DSS compliant payment infrastructure.
• Third-party transaction information: personal data belonging to third parties may be obtained when someone sends payments to third parties or performs another transaction requiring information about third parties.
• Customer/client transaction information: requested service, offer, invoice, contract records, order and payment history.
• Professional information: institution/university information, title, curriculum vitae (CV) content.
• Consultancy/Education/Internship/Mobility Program specific data: education information, health insurance and travel insurance information, emergency contact information, passport/ID information — only within the scope of the relevant program and within the framework of necessary consent/legal basis.
• Transaction security information: IP address, data obtained via cookies, log records, browser/device information, geographical location.
• Marketing information: with your explicit consent, information used for notifications and campaign communications tailored to your interests.
• Visual and audio records: with your explicit consent, photos and video images from event/training records.
• Information obtained from other channels: information about you shared with us through universities, institutions, or program consortiums we collaborate with.

Some or all of this information may constitute personal data; institutions/individuals sharing this information with us must guarantee that they are authorized to share such data.

3. PURPOSES AND LEGAL GROUNDS FOR PROCESSING PERSONAL DATA

We use the personal data we hold for various purposes permitted by legal regulations in Turkey and, where applicable, in the European Union (KVKK, GDPR). The legal grounds we rely on when processing this data may include fulfilling our contractual obligations, our legitimate interests, our legal obligations, and your explicit consent.

To provide you with our website and services:

We need to use your personal information to provide access to services, process payments, enable you to create an account and perform transactions on it, and coordinate EU grant consultancy, career consultancy, internship/mobility, and artificial intelligence solutions projects.

To securely conduct payment transactions:

Payments made through our website are processed in a PCI DSS (Payment Card Industry Data Security Standard) compliant environment via the iyzico payment infrastructure. Your necessary personal data is shared with the payment service provider and relevant financial institutions to ensure the security of your payment information. Sensitive payment data such as card number and CVV are not stored on Nefes AI servers.

To improve our services and manage our operational requirements:

We monitor and analyze the use of our website and services to improve our performance.

Risk management and security:

We measure risk levels to prevent malicious transactions and fraud. Decisions on this matter may be made by automated algorithms within certain rules or by our personnel directly. You can request information about an application or transaction rejected as a result of these reviews by contacting us using the communication details below.

To contact you when necessary:

We use your contact information to inform you about the status of your transactions and account, and to resolve any issues that arise. Those who contact you may be direct Nefes AI employees or business partners from whom we receive services; in this case, your personal data must be shared with these business partners.

To fulfill our legal obligations or resolve disputes:

Regulations in the places where we operate may require us to use and store your information in certain ways; we are obliged to keep and review records related to payment, tax, grant reporting, and audit processes in accordance with the relevant legislation. In the event of a dispute, your personal information may be used to resolve this dispute and transferred to authorized bodies.

Marketing and feedback:

We may also use your information for other purposes for which you have given consent; we may obtain your consent for processing activities such as sending you marketing communications or receiving feedback. In such cases, you can always withdraw your consent; you can contact us using the communication details below for this purpose. Your notification of consent withdrawal will be effective for the future.

4. USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

During your use of our website, access data such as the name of your internet service provider, IP addresses, and pages you visit are collected. This information may be used for providing the website infrastructure and for statistical analysis.

Currently, our website does not actively use analytical or marketing third-party cookies/tracking technologies, except for strictly necessary first-party cookies. If analytical or marketing cookies/tracking tools begin to be used in the future, this Policy will be updated; the type, purpose, and retention period of the cookies used will be explained in detail.

In payment transactions carried out through our website, iyzico's payment page and infrastructure are activated; the cookies and tracking technologies used by iyzico in this process are subject to iyzico's own privacy policy.

You can refuse the use of cookies by selecting the appropriate settings on your browser; however, please note that if you do so, you may not be able to use our website with full functionality. For comprehensive information about cookies, we also recommend reviewing the separately published "Cookie Information Text."

5. RETENTION AND DELETION OF PERSONAL DATA

The period for which Nefes AI will store your personal data in a way that allows your identity to be determined is the shortest period required to meet our legal obligations and operational requirements. When the retention period for your personal data expires, we delete, destroy, or anonymize this data in accordance with our internal procedures.

When you close your account or request the deletion of your personal data, we delete or anonymize data other than what we are legally obliged to retain.

Example retention periods:

• Financial documents: 5 (five) years in accordance with the Tax Procedure Law.
• Commercial books and documents: 10 (ten) years in accordance with the Turkish Commercial Code.
• Payment and transaction records: periods determined in accordance with relevant financial legislation and iyzico infrastructure requirements.
• EU grant, education consultancy, and mobility program data: minimum retention periods stipulated by the relevant program consortium or funding organization (European Commission, National Agency, etc.).
• Consultancy contract records and webinar/training records: 2 (two) years.
• The cookies we use have specific validity periods; if you do not use our website or services during this period, the cookies will be automatically deactivated. You can also delete these cookies using your internet browser settings.

6. TRANSFER OF PERSONAL DATA TO THIRD PARTIES

While providing our services, we may share your personal data with third parties for the purposes described below and with necessary security measures:

• Payment service providers and financial institutions: in payments made through our website, your payment information is shared with the payment infrastructure provider (iyzico) and relevant bank/financial institutions to complete the payment transaction. This sharing occurs in a PCI DSS compliant secure environment.
• Due to legal obligations: authorized public institutions and organizations, law enforcement agencies, courts, and enforcement offices — we share this information only when legally obliged or when we deem it necessary to prevent or investigate a crime.
• Service providers and business partners: contracted supplier companies (cloud/hosting providers, insurance companies, IT support, software license providers) to provide our services securely and uninterruptedly. These sharings are carried out within the framework of confidentiality and data processing agreements concluded with the relevant companies.
• Corporate use: transfer of information regarding the use of services accessed by individuals who are members of the site under corporate packages to their respective institutions (provided the user has given consent for this).
• Program partners: universities we collaborate with, EU grant/mobility program consortiums, and partner organizations.
• Professional consultants: our consultants from whom we receive legal consultancy, career consultancy, financial advisory, and audit services.
• Operational purposes: within the scope of various activities such as company audits, corporate governance, and exercising our legal rights, always in compliance with legal regulations.

Technical and legal measures are taken to prevent rights violations during the transfer of data to third parties. Nefes AI cannot be held responsible for violations arising from the data protection policies of the third party receiving personal data and occurring exclusively within the responsibility of that third party.

7. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

Due to the nature of the services we provide, we may need to transfer some personal data internationally. The international internship/mobility programs and consultancy activities we conduct may involve the transfer of some personal data abroad. If you access our website from a country other than Turkey or use our services, your personal data will be transferred to our servers in Turkey.

These transfers are carried out in accordance with Article 9 of the KVKK and the relevant regulations of the Personal Data Protection Board; to countries with an adequacy decision, in cases where appropriate safeguards (standard contractual clauses, etc.) are provided, or with your explicit consent. In all cases, we guarantee that your personal data will only be transferred to countries that provide adequate protection or to individuals who undertake to ensure the security of your data.

8. YOUR CHOICES

You can make certain choices regarding your privacy:

• You can always refuse to provide your personal data requested by Nefes AI. However, we remind you that if the information you refuse to provide is mandatory for us to provide our services, you may not be able to benefit from the relevant services. For example, if you do not enter your payment information for a service that requires payment, we will not be able to process the payment.
• You can use your internet browser settings to reject cookies; however, in this case, you may not be able to use our website and services with full functionality.
• You cannot refuse to receive notification messages regarding transactions, but you may be able to change the method and addresses to which they are sent.

9. PROTECTION OF PERSONAL DATA

All personal data obtained by Nefes AI is transmitted and stored subject to reasonable security conditions accepted in the industry. In this context, technical and administrative measures such as access authorization, data encryption, regular backup, firewall applications, and personnel awareness training are implemented.

In payment transactions carried out through our website, payment security is ensured by iyzico's PCI DSS (Payment Card Industry Data Security Standard) compliant infrastructure. Sensitive payment data such as card number and CVV are not stored on Nefes AI servers; this data is processed directly within iyzico's secure payment infrastructure.

While we take all reasonable measures to protect your personal information, it is also your responsibility to ensure the security of your password and account information. We would like to remind you that no data transmission over the internet is 100% secure.

10. PERSONAL DATA OF CHILDREN

Nefes AI's general website services, including its payment infrastructure, are not intended for independent use by minors (under 18 years of age); we do not collect payment or personal data from children or individuals who are legally unable to benefit from our services.

However, within the scope of some internship/mobility and education programs we conduct, data of student/intern candidates under the age of 18 may be processed with the explicit consent of their legal representatives (parent/guardian) and through the relevant educational institution, in full compliance with the special protection requirements for children under the KVKK.

If we realize that we have obtained personal data belonging to a child due to an error or oversight, we immediately delete this data unless we are legally obliged to retain it. If you detect such a situation, please contact us immediately using the communication details below.

11. YOUR RIGHTS

We would like to state that you have the rights specified below pursuant to Article 11 of the KVKK No. 6698:

a) To learn whether personal data is processed,

b) To request information if personal data has been processed,

c) To learn the purpose of processing personal data and whether they are used in accordance with their purpose,

ç) To know the third parties to whom personal data is transferred domestically or abroad,

d) To request the rectification of personal data if it is incomplete or incorrectly processed,

e) To request the erasure or destruction of personal data within the framework of the conditions stipulated in Article 7 of the KVKK,

f) To request notification of the operations carried out pursuant to subparagraphs (d) and (e) to third parties to whom personal data has been transferred,

g) To object to the occurrence of a result against the person himself/herself by analyzing the processed data exclusively through automated systems,

ğ) To demand compensation for damages incurred due to unlawful processing of personal data.

You can exercise your rights mentioned above by contacting us through the communication channels below. When making this application, you must fully specify the information you provided when registering or benefiting from our services and attach a copy of an official identity document so that we can identify you. Your application will be concluded within 30 (thirty) days at the latest.

12. OTHER INFORMATION

This Policy is valid only for the use of Nefes AI products and services. For all websites and environments not belonging to Nefes AI, the privacy policy and rules of the relevant person or institution will apply. In cases where the payment infrastructure of iyzi Ödeme ve Elektronik Para Hizmetleri A.Ş. (Iyzico), which is the payment service provider, is integrated into our website, both this Nefes AI Policy and Iyzico's own privacy policy will apply.

Our users and customers are obliged to follow possible updates and to inform third parties about Nefes AI's data processing activities and this Policy before transferring their information to Nefes AI.

13. CHANGES TO THE POLICY

We may make changes to this Policy. Changes made will be effective from the date the updated Policy is published on our website. We recommend that you regularly visit our website to follow changes made to this Policy.

14. CONTACT INFORMATION

Data Controller: Nefes AI Software Technologies Limited Company Address: Ayazağa Mah. Kemerburgaz Cad. Vadi İstanbul Park Sitesi 7A Blok No: 7B Kat: 2, Sarıyer 34475 İstanbul / Turkey MERSİS No: 0630142275900001 Email: info@nefes-ai.com Web: https://nefes-ai.com

For any questions, opinions, and applications regarding your personal data, you can reach us at any time through the communication channels above, especially via the email address info@nefes-ai.com.

DISTANCE SALES AGREEMENT

Online Training and Consultancy Services

ARTICLE 1 – PARTIES

This Distance Sales Agreement ("Agreement") has been concluded between the SELLER and the BUYER, whose information is provided below, within the framework of the provisions of the Law on Consumer Protection No. 6502 and the Regulation on Distance Contracts.

1.1 Seller Information

Information	Detail
Title	Nefes AI Software Technologies Limited Company
MERSİS No	0630142275900001
Address	Ayazağa Mah. Kemerburgaz Cad. Vadi İstanbul Park Sitesi 7A Blok No: 7B Kat: 2, Sarıyer 34475 İstanbul / Turkey
Email	info@nefes-ai.com
Website	https://nefes-ai.com
Payment Infrastructure	iyzico (iyzi Ödeme ve Elektronik Para Hizmetleri A.Ş.)

1.2 Buyer Information

The BUYER is identified by the name-surname, email, contact, and invoice information provided in the order/contact form or during the iyzico payment step. The Buyer declares and undertakes that this information is accurate and up-to-date.

ARTICLE 2 – DEFINITIONS

The terms used in this Agreement shall have the following meanings:

• "Service": All hourly/session-based online consultancy and online training programs offered by Nefes AI through the website;
• "Online Consultancy": One-on-one or group consultancy sessions, purchased on an hourly/session basis and conducted remotely (video conference/digital platform);
• "Online Training": Training programs, courses, webinars purchased through the website and offered in a digital environment (recorded video, live webinar, or hybrid format);
• "Live Service": A consultancy session or webinar held on a specific date and time, requiring prior appointment/reservation;
• "Recorded Content": Video/audio/text content uploaded to the platform after purchase, accessible by the BUYER for a certain period or indefinitely;
• "iyzico": iyzi Ödeme ve Elektronik Para Hizmetleri A.Ş., which provides the payment infrastructure service;
• "Agreement Date": Refers to the date on which the BUYER completes the payment via iyzico after confirming the order.

ARTICLE 3 – SUBJECT AND SCOPE OF THE AGREEMENT

This Agreement regulates the rights and obligations of the parties regarding the online consultancy and/or online training service purchased by the BUYER through the Nefes AI website (https://nefes-ai.com) via the iyzico payment infrastructure.

The services covered by the Agreement are:

Service Type	Description	Format
Hourly Online Consultancy	One-on-one or small group consultancy sessions on EU grant consultancy, career coaching, project consultancy, and artificial intelligence solutions	Live (Zoom/Teams etc.)
Online Training Program	Structured training curriculum, course, or seminar series on specific topics	Live / Recorded / Hybrid
Webinar	Online seminars organized on specified topics and dates, based on open or recorded participation	Live / Recorded
Internship Mobility Program	Consultancy and coordination services for international internship and mobility processes	Online Office

ARTICLE 4 – SERVICE FEE AND PAYMENT TERMS

4.1 Fee and VAT

The service fee is the price announced on the website and displayed to the BUYER in the order form. VAT is included in the price; unless otherwise stated.

4.2 Payment Method

Payments are made via iyzico (iyzi Payment and Electronic Money Services Inc.) secure payment infrastructure:

• Credit card and debit card (Visa, Mastercard, Troy)
• Installment payment: Determined according to the installment feature of the BUYER's credit card and their bank's campaigns; installment options are shown in the payment step.
• Wire Transfer/EFT: To the announced IBAN; with the order number and full name as description. The service is activated after payment confirmation.

4.3 Security

Sensitive payment data such as card number, CVV, etc., are not transmitted to Nefes AI servers; this data is processed and stored directly within iyzico's PCI DSS compliant infrastructure.

4.4 Payment Confirmation

Upon receipt of payment confirmation from iyzico, the Contract comes into force and the service activation process begins. If payment is not confirmed, the order will not be created.

ARTICLE 5 – SERVICE ACTIVATION AND DELIVERY

5.1 Activation Period

After payment confirmation is received from iyzico, the service will be activated within the following periods:

Service Type	Activation Period
Hourly Online Consulting	Appointment/reservation link sent via email within 1 business day at the latest
Recorded Online Training	Access information sent via email within 24 hours at the latest after payment confirmation
Live Webinar / Live Training	Reservation link/participation link sent within 24 hours at the latest; if applicable, at least 24 hours before the event date
Internship Mobility Consulting	Initial meeting scheduled within 2 business days at the latest

5.2 Access Channel

Access to services is provided through the following channels:

• Online consulting sessions: Via Google Meet, Zoom, Microsoft Teams, or a platform determined by Nefes AI; appointment link sent via email.
• Recorded training content: Accessed via email/membership panel with access information sent to the BUYER.
• Live events: Meeting/webinar link sent via email is used.

5.3 BUYER's Obligations

The BUYER is responsible for providing a correct email address, regularly checking communication channels, and attending appointments on time. Nefes AI cannot be held responsible for delays caused by incorrect/incomplete information.

5.4 Force Majeure

In cases of force majeure such as cyber-attacks, platform outages, internet infrastructure failures, natural disasters, or epidemics, Nefes AI may temporarily suspend service provision; the BUYER shall not make additional demands for this period, and the service will be rescheduled as soon as possible.

ARTICLE 6 – RIGHT OF WITHDRAWAL

6.1 General Right of Withdrawal

Pursuant to Article 12 of Law No. 6502 on Consumer Protection and the Regulation on Distance Contracts, the BUYER has the right to withdraw from the contract within 14 (fourteen) days from the date of conclusion of the contract (date of payment confirmation) without stating any reason and without paying any penalty.

6.2 Exercise of the Right of Withdrawal

One of the following methods can be used to submit a withdrawal request:

• Email: info@nefes-ai.com (the subject line must include "WITHDRAWAL REQUEST – ")
• Written application: Registered mail to Nefes AI's address stated above

It is sufficient for the withdrawal notification to be sent clearly and in writing by the BUYER within the 14-day period; the date of dispatch, not the date of receipt, shall be taken as basis.

6.3 Exceptions to the Right of Withdrawal (Legal Exceptions)

In the following cases, the BUYER's right of withdrawal is legally extinguished:

Exception	Description	Legal Basis
Consulting session started and completed	If the service session has been performed during the session period with the BUYER's request and explicit consent, the right of withdrawal is extinguished.	RDC Art. 15/(g)
Access to digital content initiated	If the BUYER has declared that they waive their right of withdrawal upon accessing digital content during purchase and access has been initiated, the right of withdrawal ends.	RDC Art. 15/(m)
Access to recorded webinar or training	If the recorded content has been opened/viewed by the BUYER, the right of withdrawal ends.	RDC Art. 15/(m)
Participation in live event	If the BUYER has participated in the live event on the specified date, the service is deemed to have been performed.	RDC Art. 15/(g)

6.4 Pre-Withdrawal Consent Notification

When purchasing a service containing digital content (recorded training, webinar recording, etc.), the BUYER confirms the following statement at the payment step: "I agree that I want to access the digital content immediately and that I waive my right of withdrawal upon initiation of access." Without this consent, digital content will not be activated.

ARTICLE 7 – APPOINTMENT / SESSION CANCELLATION AND RESCHEDULING

7.1 Cancellation by BUYER

Cancellation Time	Application
48 hours or more before the session date	Right to free cancellation or rescheduling
24–48 hours before the session date	Right to one free rescheduling; 50% of the session fee is deducted for the second change
Less than 24 hours before the session date	No cancellation or refund; the session is deemed to have taken place
No-show for session	Session fee is not refunded

7.2 Cancellation by Nefes AI

For sessions canceled by Nefes AI, the BUYER is notified as soon as possible and offered a choice:

• Setting a new date/time (free of charge)
• Full refund (according to the refund procedure below)

ARTICLE 8 – REFUND CONDITIONS AND PROCEDURE

8.1 Cases Entitling to a Refund

The BUYER has the right to request a refund in the following cases:

• Within the 14-day withdrawal period, if the service has not been performed and digital content has not been accessed (pursuant to Article 6.1)
• For a session canceled by Nefes AI and not accepted for rescheduling
• If the service cannot be provided at all due to technical reasons

8.2 Refund Procedure

Submitting a refund request:

• Send your refund request to info@nefes-ai.com, with "REFUND REQUEST" in the subject line.
• In your request, please specify the service name, payment date, and reason for refund.

Refund process and duration:

• The request will be evaluated within 14 business days at the latest after it reaches us, and a written response will be given to the BUYER.
• For approved refunds, payment will be made via the iyzico payment infrastructure, according to the table below:

Payment Method	Refund Channel	Estimated Time
Credit Card (single payment)	Refund to card (iyzico → bank → account)	3–10 business days (varies by bank)
Credit Card (installments)	Each installment is refunded to the card in the relevant period	May extend over the number of installments
Debit Card	Refund to card	1–5 business days
Wire Transfer/EFT	Wire transfer to the IBAN provided by the BUYER	3–5 business days

Credit card refunds cannot be made in cash. The refund is transmitted to the relevant bank channel via the iyzico infrastructure; the time it takes for the bank to reflect it in the account may vary from bank to bank.

ARTICLE 9 – INTELLECTUAL AND INDUSTRIAL PROPERTY RIGHTS

All content provided within the scope of the website and services (training materials, presentations, video recordings, audio files, written documents, methodologies, tools) is the intellectual property of Nefes AI or its licensors and is protected under the Law on Intellectual and Artistic Works No. 5846.

The BUYER may use the content within the scope of the purchased service:

• Only for personal / internal training purposes
• May not share, reproduce, distribute, sell, or use for commercial purposes with third parties
• May not copy or publish by recording, screenshot, or any other means

In case of violation of these provisions, Nefes AI reserves the right to claim compensation for damages incurred and all its rights under Law No. 5846.

ARTICLE 10 – PRIVACY AND PROTECTION OF PERSONAL DATA

Personal data belonging to the BUYER is processed in accordance with the Law on Protection of Personal Data No. 6698 ("KVKK") and for the purposes and methods specified in the Privacy Personal Data Policy and KVKK Clarification Text published on the website.

Data related to the payment process (card information, etc.) is processed within iyzico's PCI DSS compliant infrastructure and is not stored on Nefes AI servers. The BUYER is also subject to iyzico's privacy policy and user agreement at the payment step.

For the BUYER's rights under KVKK (access, correction, deletion, objection, etc.): info@nefes-ai.com

ARTICLE 11 – FORMATION OF THE CONTRACT AND BUYER'S DECLARATIONS

The BUYER, upon completing the order form and payment, declares and accepts that:

• They have read, understood, and accepted the terms of this Contract;
• They have been sufficiently informed in advance about the nature and content of the service purchased;
• They have been informed about the right of withdrawal and refund procedure through this Contract;
• For services including digital content (recorded training, webinar recording), they waive their right of withdrawal upon initiating access to the content;
• They are over 18 years old and acting with legal authority on their own behalf or on behalf of the institution they represent.

declares and accepts.

The Contract comes into force upon payment approval by iyzico and notification to Nefes AI. A copy of the Contract is sent to the BUYER via email.

ARTICLE 12 – RESOLUTION OF DISPUTES

The following authorities are authorized in disputes arising from this Contract.

Type of Dispute	Application Authority
Consumer disputes (according to monetary limit for 2025)	Provincial or District Consumer Arbitration Committee pursuant to Law No. 6502 on Consumer Protection
Consumer disputes exceeding the arbitration committee limit	Consumer Court at the BUYER's domicile or where the service is provided
Commercial disputes	Istanbul Courts and Enforcement Offices

The parties undertake to resolve disputes amicably first. Turkish Law shall apply to disputes.

ARTICLE 13 – OTHER PROVISIONS

13.1 Right to Amend

Nefes AI reserves the right to change service prices, content, and terms without prior notice. Changes apply to new orders from the date of publication on the website; existing orders are not affected.

13.2 Severability

If any provision of this Contract is deemed invalid or unenforceable, the validity of the remaining provisions of the contract shall not be affected.

13.3 Applicable Legislation

This Contract shall be interpreted within the framework of Law No. 6502 on Consumer Protection, the Regulation on Distance Contracts, Law No. 6698 on KVKK, and other relevant legal regulations.

13.4 Change of Payment Infrastructure

Nefes AI reserves the right to change its payment infrastructure provider (iyzico). In this case, the information of the new provider will be announced on the website; ongoing installment transactions will be finalized with the current provider.

ARTICLE 14 – EFFECTIVENESS

This Distance Sales Contract is dated October 4, 2026, and comes into force upon the BUYER's order confirmation and completion of payment via iyzico.

SELLER	Nefes AI Software Technologies Limited Company
Authorized to Sign on Behalf of	Company Official
Date	October 4, 2026
BUYER	Person/institution specified in the order form
Method of Approval	Electronic approval (order completion + iyzico payment confirmation)

TERMS OF USE

https://nefes-ai.com Website

ARTICLE 1 – INTRODUCTION AND SCOPE

Nefes AI Software Technologies Limited Company ("Nefes AI", "Company"), which offers software, training, and consultancy services, provides its services through the address https://nefes-ai.com ("Website").

These Terms of Use regulate the binding conditions that Website visitors and customers purchasing our services ("Customer") must comply with. Visiting the Website or benefiting from any service means that these terms have been read and accepted.

These Terms of Use form an integral whole with the following documents:

• Distance Sales Contract
• Clarification Text on the Processing of Personal Data within the Scope of KVKK
• Clarification Text on Cookies

These documents are published on the Website and are an integral part of the Terms of Use.

ARTICLE 2 – RIGHT TO AMEND

Nefes AI reserves the right to make changes to any document published on the Website, including these Terms of Use, at any time. Changes come into effect from the date of their publication on the Website; the Customer is advised to regularly follow the documents. Nefes AI may also notify significant changes via email; however, this is not an obligation.

ARTICLE 3 – ACCOUNT CREATION AND USER OBLIGATIONS

3.1.

To purchase services and fill out forms on the Website, the user must have full legal capacity (be over 18 years old and of sound mind). Participation of individuals under 18 in internship/mobility or training programs is only possible with the explicit consent of their legal representatives (parent/guardian) and through the relevant educational institution, by providing the necessary consent/approval documents.

3.2.

The user is obliged to provide current, accurate, and complete information. Providing erroneous, incorrect, or incomplete information constitutes a material breach of contract and gives Nefes AI the right to terminate without compensation.

3.3.

For detailed information on the processing of personal data, please refer to the "Clarification Text on the Processing of Personal Data within the Scope of KVKK" published on the Website.

3.4.

All content, property, and rights on the Website exclusively belong to Nefes AI. Nefes AI may close any user account or make changes to the site at any time.

3.5.

The Customer may not transfer the purchased service or their account to a third party. In case of unauthorized access to the account, the situation must be immediately reported in writing to info@nefes-ai.com.

ARTICLE 4 – FEES AND PAYMENT

4.1.

Service fees are announced on the Website and displayed to the Customer at the order step. Nefes AI cannot unilaterally change the fee for a confirmed and paid service.

4.2.

Payments are made via iyzico (iyzi Payment and Electronic Money Services Inc.) secure payment infrastructure using credit card, debit card, or wire transfer/EFT. Sensitive payment data such as card number and CVV are not stored on Nefes AI servers; this data is processed within iyzico's PCI DSS compliant infrastructure.

4.3.

After payment confirmation, an invoice is sent to the Customer's email address.

4.4.

Nefes AI reserves the right to change the calendar of training/consultancy services, provided that prior notice is given.

4.5.

The right of withdrawal and refund conditions are regulated in Articles 6 and 8 of the Distance Sales Contract. The Customer cannot unilaterally terminate the contract, subject to these articles.

ARTICLE 5 – INTELLECTUAL PROPERTY RIGHTS

5.1.

Intellectual and industrial property rights over all training materials, presentations, video/audio recordings, project documents, methodologies, and other content prepared by Nefes AI exclusively belong to Nefes AI; they are protected under the Law on Intellectual and Artistic Works No. 5846.

5.2.

The Customer may use these materials only for personal/internal purposes; the following are strictly prohibited:

• Sharing, reproducing, distributing, or using for commercial purposes with third parties
• Unauthorized audio, video, or screen recording
• Publishing or selling content in parts or as a whole

5.3.

In case of violation of these provisions, Nefes AI reserves the right to claim compensation for damages incurred and to exercise all its rights under the relevant legislation.

ARTICLE 6 – LIMITATION OF LIABILITY

Nefes AI undertakes that the services will be performed by qualified personnel in accordance with generally accepted standards in the industry. However:

• The trainings offered are not affiliated with any official institution or accreditation body.
• The Customer's success in their professional life or mastery of relevant subjects after training is not guaranteed.
• Nefes AI shall not be liable for any indirect, special, or consequential damages other than those caused by its own willful misconduct or gross negligence.

ARTICLE 7 – USE OF COOKIES

First-party cookies, which are mandatory for the provision of the service, are used on the Website. For detailed information on cookie types, purposes, retention periods, and preference management, please refer to the "Clarification Text on Cookies" published on the Website.

ARTICLE 8 – VISUAL AND AUDIO RECORDINGS

Photographs and videos taken during Nefes AI's events, trainings, or promotional activities that include the Customer may only be used on Nefes AI's Website or social media channels within the scope of the free, specific, and informed explicit consent previously given by the Customer. This consent may be withdrawn at any time in accordance with the provisions of Law No. 6698 on KVKK and Law No. 6502 on Consumer Protection.

ARTICLE 9 – NOTIFICATIONS

The addresses declared by the parties are considered legal notification addresses; changes of address must be notified to the other party in writing in advance. Notifications to the Customer are deemed validly made by sending them to the email address provided in the registration.

ARTICLE 10 – INTEGRITY OF CONTRACTS

These Terms of Use form an integral whole with the Distance Sales Contract, the KVKK Clarification Text, and the Clarification Text on Cookies. In case of conflict between the documents, the document specific to the subject shall apply primarily.

ARTICLE 11 – APPLICABLE LAW AND AUTHORIZED COURT

Turkish Law shall apply to the interpretation of these Terms of Use and all disputes arising from this document.

Type of Dispute	Authorized Authority
Consumer disputes (according to monetary limit)	Provincial or District Consumer Arbitration Committee (Law No. 6502 on Consumer Protection)
Consumer disputes exceeding the arbitration committee limit	Consumer Court
Commercial disputes	Istanbul Courts and Enforcement Offices

ARTICLE 12 – MISCELLANEOUS PROVISIONS

12.1.

In cases of force majeure (cyber-attack, platform outage, natural disaster, epidemic, etc.), Nefes AI may temporarily suspend or postpone services; the Customer will be informed without delay.

12.2.

If any provision of these Terms of Use is deemed invalid or unenforceable, the validity of the remaining provisions shall not be affected.

12.3.

Nefes AI's failure to exercise any right or delay in exercising it does not constitute a waiver of that right.

ARTICLE 13 – CONTACT AND EFFECTIVENESS

These Terms of Use are effective as of their last update date, October 4, 2026, and come into force from the moment they are published on the Website.

Information	Detail
Data Controller / Company	Nefes AI Software Technologies Limited Company
MERSIS No	0630142275900001
Address	Ayazağa Mah. Kemerburgaz Cad. Vadi İstanbul Park Sitesi 7A Blok No: 7B Kat: 2, Sarıyer 34475 Istanbul / Turkey
Email	info@nefes-ai.com
Web	https://nefes-ai.com

CLARIFICATION TEXT ON COOKIES

1. PURPOSE AND DATA CONTROLLER

This Cookie Clarification Text has been prepared by Nefes AI Software Technologies Limited Company ("Nefes AI" or "Company"), whose identification information is provided below, in its capacity as data controller, in accordance with the Law on Protection of Personal Data No. 6698 ("Law") published in the Official Gazette dated April 7, 2016, and numbered 29677, the Communiqué on the Procedures and Principles to be Complied with in Fulfilling the Obligation to Inform ("Communiqué") published in the Official Gazette dated March 10, 2018, and numbered 30356, and relevant legislation.

Data Controller / Company: Nefes AI Software Technologies Limited Company Address: Ayazağa Mah. Kemerburgaz Cad. Vadi İstanbul Park Sitesi 7A Blok No: 7B Kat: 2, Sarıyer 34475 Istanbul / Turkey MERSIS No: 0630142275900001 Email: info@nefes-ai.com Web: https://nefes-ai.com

The purpose of this Cookie Clarification Text is to inform you about what types of cookies we use for what purposes, the legal reason for this processing, and your rights in this context, regarding the processing of personal data obtained automatically through the placement of cookies on your website (https://nefes-ai.com).

On our website, currently, only first-party session and persistent cookies that are strictly necessary for the provision of the service are used. Third-party cookie/tracking technologies (e.g., Google Analytics, advertising networks) for analytical or marketing purposes that track user behavior are not currently used on our site. Should there be any changes in this scope, this Text will be updated, and the new cookies used, their purposes, and durations will be explained in detail here.

2. WHAT IS A COOKIE?

A cookie is a small text file, usually consisting of letters and numbers, stored on the user's computer or mobile device when a website is visited. Cookies can be used for various purposes, such as ensuring the proper functioning of the visited website, improving user experience, analyzing website performance, and collecting statistical information related to the website.

3. TYPES OF COOKIES

3.1. By Duration of Use

• Session Cookies: These are cookies that are valid during the user's visit to the website and are automatically deleted when the browser is closed.
• Persistent Cookies: These are cookies that are not deleted when the internet browser is closed and are automatically deleted on a specific date or after a certain period.

Our website uses both session and persistent cookies based on their duration of use.

3.2. By Party

• First-Party Cookies: These are cookies placed directly by the visited website (the domain name visible in the browser's address bar).
• Third-Party Cookies: These are cookies placed by a domain name different from the visited site.

Our website uses only first-party cookies.

3.3. By Purpose of Use

• Strictly Necessary Cookies: These are cookies essential for the website to function and are mandatory for providing information society services explicitly requested by the user; they do not require user consent.
• Functional Cookies: These cookies provide ease of use by remembering user preferences.
• Performance/Analytical Cookies: These cookies collect information about how users interact with the website, allowing for the measurement of site performance.
• Advertising/Marketing Cookies: These cookies enable the delivery of content and advertisements based on the user's interests.

Our website uses strictly necessary cookies to provide the information society services you have explicitly requested.

4. COOKIES USED ON OUR WEBSITE

By default, the content management system (WordPress) used in our website's infrastructure creates two main types of cookies: session cookies and comment cookies. Both are classified as "strictly necessary" cookies as they are required for the site to function properly and do not require user consent; however, they collect certain personal information (e.g., IP address) to operate.

Cookie Name/Type	Purpose	Duration	Type
Session Cookie	Ensuring the integrity of user navigation within the site	Until browser closes	Strictly Necessary / First-Party
Comment Cookie	Remembering user comment/form information	Approximately 1 year	Strictly Necessary / First-Party

Your personal data is processed through these cookies by associating it with your IP address. The processing of personal data via these cookies is based on the processing condition of "the necessity of data processing for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject" in accordance with Article 5, paragraph 2, subparagraph (f) of the Law.

5. MANAGING YOUR COOKIE PREFERENCES

You have the option to personalize your cookie preferences by changing your browser settings. You can completely reject cookies, accept only certain types of cookies, or be notified before a cookie is saved to your device by a website.

Most browsers automatically accept cookies by default; however, if you wish, you can delete or block cookies from your browser settings. Example links for configuring browser settings:

• Google Chrome: chrome://settings/cookies
• Mozilla Firefox: about:preferences#privacy
• Safari: Preferences > Privacy
• Microsoft Edge: Settings > Cookies and Site Permissions

We would like to remind you that if you reject or block strictly necessary cookies, some parts of our website may not function fully.

6. RIGHTS OF THE PERSONAL DATA OWNER

To exercise your rights regarding your personal data processed via cookies, within the scope of Article 11 of the Law (to learn whether your personal data is processed, to request information if it has been processed, to learn the purpose of processing, to know the third parties to whom it is transferred domestically/abroad, to request correction/deletion/destruction, to object, and to request compensation for damages), you can contact us through the communication channels specified in Article 7. Detailed explanations regarding these rights are included in the "Privacy and Personal Data Policy."

7. CONTACT

Data Controller / Company: Nefes AI Yazılım Teknolojileri Limited Şirketi Address: Ayazağa Mah. Kemerburgaz Cad. Vadi İstanbul Park Sitesi 7A Blok No: 7B Kat: 2, Sarıyer 34475 İstanbul / Türkiye MERSİS No: 0630142275900001 Email: info@nefes-ai.com Web: https://nefes-ai.com

8. TEXT AMENDMENTS

Nefes AI reserves the right to make changes to this Cookie Information Text in line with the scope of cookies used on the website, legislative changes, or technical infrastructure updates. The updated text becomes effective from the date of its publication.