PRIVACY POLICY AND PERSONAL DATA NOTICE

Last updated: 20 September 2026

1.DATA CONTROLLER

This Privacy Policy and Personal Data Notice explains how the following company collects, uses, stores, shares and protects personal data:

Legal Name: ADN COE EĞİTİM DANIŞMANLIK VE ORGANİZASYON LİMİTED ŞİRKETİ
Address: Atatürk Mah. Ertuğrul Gazi Sok. Metropol İstanbul A Blok, Apt. No: 2E, Floor: 21, Office: 331, Ataşehir, İstanbul, Türkiye
Telephone: +90 216 909 02 36
Email: accounting@adncoe.com
Website: www.adncoe.com
Tax Office: Kozyatağı Tax Office
Tax Identification Number: 0081750793

ADN COE EĞİTİM DANIŞMANLIK VE ORGANİZASYON LİMİTED ŞİRKETİ is referred to in this Policy as “ADN CoE”, “we”, “us”, the “Company” or the “Data Controller”.

Personal data is processed in accordance with Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”), applicable secondary legislation and other applicable data-protection requirements.

This Policy is an information notice and does not, by itself, constitute explicit consent. Where explicit consent is legally required, it will be requested separately, specifically and voluntarily.

2.SCOPE

This Policy applies to personal data processed in connection with:

visits to the ADN CoE website;
programme inquiries and applications;
online and in-person programme registrations;
courses, webinars, masterclasses and workshops;
fellowships, observerships and clinical-education programmes;
payment, invoicing and accounting processes;
learning-management, videoconferencing and digital education platforms;
certificates and attendance records;
accommodation, transfer or organisational services purchased through ADN CoE;
communications with participants, faculty members, sponsors, partner institutions and other business contacts; and
customer service, complaints, cancellations, refunds and dispute management.

Partner hospitals, educational institutions, payment providers and third-party platforms may act as separate data controllers for their own processing activities. Their processing is governed by their own privacy notices where applicable.

3.PERSONAL DATA WE MAY COLLECT

Depending on the nature of the relationship and the programme, we may process the following categories of personal data:

Identity Information

name and surname;
date of birth;
nationality;
national identification or passport information where required;
signature;
participant, registration, application or customer number.

Contact Information

email address;
telephone number;
postal address;
billing address;
country of residence;
preferred communication language.

Professional and Educational Information

profession and medical specialty;
academic title;
employing institution;
department and position;
curriculum vitae;
professional licence or registration details;
diploma, certificate and qualification information;
professional experience;
training interests and programme eligibility information.

Registration and Programme Information

programme applications and registrations;
attendance and participation records;
assessment results, assignments and course progress;
platform-access and course-completion records;
certificate information;
correspondence with faculty members and programme coordinators;
requests for accommodation, transportation or invitation documents.

Financial and Transaction Information

billing and invoice information;
tax information;
payment status;
order and transaction numbers;
currency, payment amount and payment date;
bank-transfer information;
cancellation, refund and chargeback records.

Card payments are generally processed by authorised payment service providers. ADN CoE does not ordinarily receive or store complete card numbers, card security codes or other authentication data processed directly by the payment provider.

Technical and Usage Information

IP address;
device and browser information;
date and time of access;
login and access records;
platform-usage information;
security and authentication records;
cookie and similar technology data;
technical-support communications.

Communication and Request Information

emails, contact-form messages and telephone communications;
complaints, requests, feedback and survey responses;
cancellation and refund requests;
records relating to contractual or legal disputes.

Audio-Visual Information

photographs;
video or audio recordings;
live-session participation data;
profile photographs voluntarily provided for professional or programme-related use.

Special Categories of Personal Data

ADN CoE does not normally require health data or other special-category personal data for ordinary programme registration.

Where accessibility requirements, dietary requirements, health and safety information or similar special-category information is necessary, such data will be processed only where legally permitted and limited to what is necessary for the relevant purpose. Separate explicit consent will be obtained where required.

4.HOW PERSONAL DATA IS COLLECTED

Personal data may be collected:

directly from the individual through registration, application, checkout or contact forms;
through email, telephone, messaging services or written correspondence;
during online or in-person programmes;
through the ADN CoE website and authorised digital platforms;
from the Purchaser where a company, sponsor, employer or another person registers a Participant;
from partner hospitals, faculty members, educational institutions or authorised representatives;
through payment, accounting, learning-management, videoconferencing and technical-service providers; and
from publicly available professional sources where lawful and necessary.

Personal data may be collected electronically, physically, verbally or through automated technical means, depending on the relevant process.

5.PURPOSES OF PROCESSING

Personal data may be processed for the following purposes:

responding to inquiries and programme requests;
assessing eligibility and processing applications;
creating and managing registrations;
concluding and performing contracts;
collecting payments and issuing invoices;
verifying identity and professional qualifications;
providing programme, platform and digital-content access;
communicating schedules, access details and programme updates;
organising online and in-person education;
coordinating with faculty members, hospitals and partner institutions;
arranging certificates and attendance records;
providing technical and participant support;
processing accommodation, transportation or organisational services where purchased;
preparing invitation, acceptance or programme-confirmation documents;
managing cancellations, withdrawals, transfers and refunds;
maintaining programme quality, security and operational continuity;
preventing unauthorised access, misuse and fraud;
maintaining accounting, tax, commercial and contractual records;
complying with legal, regulatory and administrative obligations;
establishing, exercising or protecting legal rights;
handling complaints, legal claims and disputes;
conducting internal reporting and service improvement using proportionate data; and
sending marketing communications only where a valid legal basis or separate consent exists.

Personal data will not be used for purposes that are incompatible with the purposes communicated at the time of collection unless another lawful basis exists and any additional notice required by law has been provided.

6.LEGAL BASES FOR PROCESSING

Depending on the relevant processing activity, personal data may be processed where:

processing is necessary for the conclusion or performance of a contract;
processing is necessary to comply with a legal obligation;
processing is expressly provided for by law;
processing is necessary for the establishment, exercise or protection of a legal right;
processing is necessary for ADN CoE’s legitimate interests, provided that the fundamental rights and freedoms of the individual are not harmed;
the data has been made public by the individual in a manner consistent with the relevant purpose; or
separate explicit consent has been obtained where required.

The performance of a contract or provision of a service will not be made conditional on consent to processing that is not necessary for that contract or service.

7.FACULTY, PARTICIPANT AND SESSION RECORDINGS

Where an online or in-person session will be recorded by ADN CoE for programme delivery, attendance, quality assurance or educational access, Participants will be informed before recording begins.

Where legally required, an appropriate legal basis or separate consent will be obtained.

A Participant’s photograph, voice, video, testimonial or statement will not be used for advertising, promotional campaigns, social media or unrelated republication solely on the basis of accepting this Privacy Policy. Separate consent will be obtained where required for such use.

A Participant may choose not to activate their camera or microphone during an online session unless their active participation is an essential and previously disclosed component of the programme.

8.PATIENT AND CLINICAL CASE INFORMATION

Participants must not upload, send or disclose patient names, identification numbers, identifiable medical images, health records or other unnecessary patient information through ADN CoE forms, live chats or educational platforms.

Clinical cases and medical images submitted for educational purposes must be appropriately anonymised and shared only where the Participant has the necessary institutional, professional and legal authority.

If identifiable patient information is inadvertently received, ADN CoE may restrict access, request anonymisation, remove the information or take other necessary measures to protect patient confidentiality and comply with applicable law.

9.SHARING OF PERSONAL DATA

Personal data may be shared, only to the extent necessary and lawful, with:

authorised ADN CoE employees and representatives;
faculty members and programme coordinators;
host hospitals, universities and educational partner institutions;
learning-management, webinar and videoconferencing providers;
cloud hosting, email, IT, cybersecurity and technical-support providers;
payment institutions, banks and financial-service providers;
accountants, financial advisers, auditors and legal advisers;
accommodation, transportation and organisational service providers where such services are purchased;
accreditation, certification or professional organisations where relevant and disclosed;
sponsors or employers paying for participation, limited to information necessary for registration, payment or attendance confirmation;
public authorities, courts, enforcement authorities and regulatory bodies where required by law; and
other parties where the individual has provided valid consent or where another lawful basis exists.

ADN CoE does not sell personal data.

Service providers acting on behalf of ADN CoE are expected to process personal data only for authorised purposes and to apply appropriate confidentiality and security measures.

9.INTERNATIONAL DATA TRANSFERS

Some digital services used for email, cloud storage, payment, videoconferencing, learning management, programme delivery or technical support may operate or store data outside Türkiye.

Personal data may be transferred abroad only in accordance with Article 9 of the KVKK and other applicable legislation, using an appropriate lawful transfer mechanism, such as:

a valid adequacy decision;
an approved standard contract or another appropriate safeguard;
binding corporate rules where applicable; or
another legally permitted transfer mechanism.

Where required, Participants will be provided with additional information regarding the relevant transfer and any separate consent required by law will be obtained.

Acceptance of this Privacy Policy alone does not constitute explicit consent to every international data transfer.

10.MARKETING COMMUNICATIONS

Marketing and commercial electronic communications are separate from operational communications necessary for a registration or purchased service.

ADN CoE may send programme announcements, campaigns, newsletters or promotional communications by email, SMS or telephone only where a valid legal basis or separate optional consent exists.

Marketing consent:

is not a condition of registration or purchase;
is obtained separately from the acceptance of contractual documents;
may be limited to selected communication channels; and
may be withdrawn at any time.

Consent may be withdrawn through the free opt-out method included in the communication, by contacting accounting@adncoe.com or through the Message Management System (İYS), where applicable.

Withdrawal of marketing consent does not affect registration, programme access or the lawfulness of processing carried out before withdrawal. Commercial communications through the relevant channel will be discontinued within the period required by law.

Service-related messages concerning payment, programme access, schedule changes, certificates, security or contractual obligations are not considered optional marketing communications.

11.COOKIES AND SIMILAR TECHNOLOGIES

The ADN CoE website and associated platforms may use cookies and similar technologies for:

website and platform functionality;
security and authentication;
remembering user preferences;
performance and analytics; and
advertising or marketing, where consent is required.

Strictly necessary cookies may be used without consent where permitted by law. Analytics, advertising and other non-essential cookies will be used only in accordance with the applicable cookie notice and consent preferences.

Further details should be provided in the website’s separate Cookie Policy or cookie-management panel.

12.RETENTION PERIODS

Personal data is retained only for as long as necessary for the purpose for which it was collected and for the periods required under applicable tax, accounting, commercial, consumer-protection, contractual and data-protection legislation.

Retention periods are determined by considering:

the duration of the programme and contractual relationship;
statutory record-keeping requirements;
applicable limitation periods;
the need to establish, exercise or protect legal rights;
security and dispute-management requirements; and
the individual’s valid requests and applicable legal obligations.

When the processing purpose and applicable retention period end, personal data will be deleted, destroyed or anonymised in accordance with applicable law and ADN CoE’s retention and destruction procedures.

13.DATA SECURITY

ADN CoE takes reasonable administrative, technical and organisational measures to protect personal data against:

unauthorised access;
unlawful processing or disclosure;
accidental loss;
alteration;
destruction; and
misuse.

These measures may include access restrictions, authentication controls, confidentiality obligations, secure storage, backups, logging, staff awareness and contractual protections with service providers.

Although reasonable security measures are applied, no electronic transmission or storage system can be guaranteed to be completely secure.

14.RIGHTS OF DATA SUBJECTS

Under Article 11 of the KVKK, individuals may have the right to:

learn whether their personal data is being processed;
request information about the processing;
learn the purpose of processing and whether the data is used in accordance with that purpose;
learn the third parties to whom personal data has been transferred in Türkiye or abroad;
request correction of incomplete or inaccurate personal data;
request deletion or destruction of personal data where the applicable legal conditions are met;
request notification of correction, deletion or destruction to third parties to whom the data has been transferred;
object to a result arising against the individual through analysis exclusively by automated systems; and
request compensation where damage is suffered due to unlawful processing.

Additional rights granted under another applicable data-protection law remain unaffected.

15.EXERCISING DATA-PROTECTION RIGHTS

Requests relating to personal data may be submitted to:

ADN COE EĞİTİM DANIŞMANLIK VE ORGANİZASYON LİMİTED ŞİRKETİ

Address: Atatürk Mah. Ertuğrul Gazi Sok. Metropol İstanbul A Blok, Apt. No: 2E, Floor: 21, Office: 331, Ataşehir, İstanbul, Türkiye
Email: accounting@adncoe.com
Telephone: +90 216 909 02 36

The request should contain sufficient information to identify the applicant and clearly explain the requested action. ADN CoE may request additional information where reasonably necessary to verify identity and prevent unauthorised disclosure.

Applications will be evaluated and answered as soon as possible and no later than the statutory period, subject to the procedures and exceptions provided under applicable law.

16.THIRD-PARTY WEBSITES AND PLATFORMS

The ADN CoE website or programme communications may contain links to third-party websites or platforms.

ADN CoE is not responsible for independent processing performed by third parties acting as separate data controllers. Participants should review the privacy policy of the relevant third party before providing personal data directly to that party.

17.CHILDREN

ADN CoE programmes are generally intended for adults and healthcare or other professionals.

ADN CoE does not knowingly collect personal data from children for ordinary programme registration. If participation by a person under the applicable legal age is permitted for a particular programme, the legally required parental or guardian authorisation and additional privacy information will be obtained.

18.CHANGES TO THIS POLICY

This Policy may be updated to reflect changes in legislation, technology, services or data-processing activities.

The updated version will be published with its revision date. Where a change materially affects an existing processing activity, additional notice or consent will be provided where required by law.

19.LANGUAGE

Where this Policy is provided in more than one language, the Turkish version shall prevail in the event of an inconsistency, to the extent permitted by applicable mandatory law.