PERSONAL DATA PROTECTION- PROCESSING POLICY AND CLARİFİCATİON TEXT
As INKA ULUSAL İSTİHDAM ORG.VE.İNSAN.KAYN.TUR.LTD.ŞTİ (hereinafter referred to as the "Company"), we respect and attach importance to the privacy of private life. For this reason, we would like to inform you about your rights regarding the use and protection of your personal data within the scope of the Law on Protection of Personal Data No. 6698 (hereinafter referred to as "KVKK").
The Law on Protection of Personal Data (KVK Law) was published in the Official Gazette dated 7 April 2016 and numbered 29677. The KVK Law is regulated to protect the fundamental rights and freedoms of natural persons, including the privacy of private life, which is also protected by the Constitution, and to determine the obligations of natural and legal persons who process personal data.
The purpose of this policy is to make explanations about the personal data processing activity carried out by the relevant digital platform in accordance with the law, to create management instructions, procedural conditions and a technical policy in order to ensure the processing and protection of personal data of the persons concerned in accordance with KVKK.
The basic principles adopted by our Company in the processing of personal data in this Policy are as follows:
To process personal data in accordance with the law and honesty rules,
Keeping personal data accurate and up-to-date when necessary,
Processing personal data for specific, explicit, and legitimate purposes,
To process personal data in connection with the purpose for which they are processed, limited and measured,
Keeping personal data for as long as required by the relevant legislation or for the purpose for which they are processed,
To clarify and inform personal data owners,
Establishing the necessary system for personal data owners to exercise their rights,
To take the necessary measures for the protection of personal data,
To act in accordance with the relevant legislation and KVK Board regulations in the transfer of personal data to third parties in line with the requirements of the processing purpose,
To show the necessary sensitivity to the processing and protection of sensitive personal data.
According to the Constitution of the Republic of Turkey, everyone has the right to demand the protection of their personal data. Regarding the protection of personal data, which is a constitutional right, according to the KVKK, our Company shows due diligence and makes it a Company policy.
This Policy: It concerns all personal data of our candidates, customers, potential customers, employee candidates, employees and officials of the institutions we cooperate with, and third parties, which are processed automatically or non-automatically, provided that they are part of any data recording system.
This policy has been prepared based on the KVKK and other legislation on the processing and protection of personal data.
3- IMPLEMENTATION OF POLICY AND RELEVANT LEGISLATION
In case of inconsistency between the current legislation and the Policy, our Company accepts that the applicable legislation will find an area of application. Our company carries out the necessary systems and preparations to act in accordance with the effective periods stipulated in the KVKK.
4- DEFINITION and ABBREVIATIONS
Company: İNKA ULUSAL İSTİHDAM ORG.VE İNSAN. KAYN. TUR. LTD.ŞTİ
Third Party/Supplier/Person: The company from which the Company receives and provides service and the personnel of this company
Explicit consent: Consent on a specific subject, based on information and expressed with free will
“Anonymization” means rendering personal data impossible to link with an identified or identifiable natural person, even though matching them with other data,
Personal data” means any information relating to an identified or identifiable natural person,
Personal Data Owner / Relevant Person: Natural person who is a member of the Platform with a service contract
Special categories of personal data: Data on people's ethnic origin, political opinion, philosophical belief, other beliefs, disguise, membership in associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data
“Processing of personal data” means any operation which is performed on personal data, wholly or partially by automated means or non-automated means which provided that form part of a data filing system, such as collection, recording, storage, protection, alteration, adaptation, disclosure, transfer, retrieval, making available for collection, categorization, preventing the use thereof,
“Data Processor” means the natural or legal person who processes personal data on behalf of the data controller upon its authorization,
“Data filing system” means the system where personal data are processed by being structured according to specific criteria,
Data Controller” means the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data filing system.
Identity of Data Controller: resident at 19 Mayıs Cad. Golden Plaza k:3 n:3 Şişli/İSTANBUL, Mecidiyeköy Tax Administration, taxpayer number: 462 033 3364, İNKA ULUSAL İSTİHDAM ORG.VE İNSAN KAYN. VE TUR. LTD. ŞTİ When the Data Controllers Registry is accessable, the company declares that it will become a registered data controller by registering the data controller.
5- PERSONAL DATA PROCESSING POLICY
Our Company, in accordance with Article 20 of the Constitution and Article 4 of the KVKK, regarding the processing of personal data; pursuing legitimate aims in accordance with the law and good faith; For this purpose, it carries out a connected, limited and measured data processing activity. Our Company retains personal data for as long as required by law or for the purpose of processing personal data.
Our company processes personal data in accordance with Article 5 of the KVKK.
Our company informs the personal data owners in accordance with Article 10 of the KVKK and provides the necessary information in case personal data owners request information.
Our company acts in accordance with the regulations stipulated for the processing of Special categories of personal data in accordance with Article 6 of the KVKK.
Our company acts in accordance with the regulations stipulated in the law and set forth by the KVK Board on the transfer of personal data in accordance with Articles 8 and 9 of the KVKK.
5.1- Processed Personal and Special Categories of Personal Data
As a company, your personal and private data that we are obliged to keep in accordance with the legal regulations we are bound by; We inform you that it will be stored in our systems via ____________ for five years from the last date you accessed the system with your username and password.
Identity Information: Name, surname, date and place of birth, TR Identity / nationality, gender, marital status, military service, driver's license
Contact Information: Residence address, e-mail address, telephone (mobile, home, work) number, personal web address, social network addresses
Education Information: Educational status, name of the education institution attended, department, date range, graduation status and date, type of education, grade point average
Career Information: Company name, location, web address, industry, position, date range, working type, employment status, reason for leaving, salary received, work experience, career target, roles of interest, preferred country/city, expected salary
Qualification Information: Professional qualification / years of experience, work and projects, certificate, foreign language, proficiency exams and their dates and degrees
Audio-Visual Data: Photographs of real people, video interviews, audio-visual recordings, camera photos and recordings, support and hotline audio recordings
References: Personal and institutional reference information given by the person concerned, reference name, company, position, degree of closeness, telephone and e-mail information
Special Category of Personal Data: If you share your photo, nationality, disability status, smoking preferences, member communities, interests, your special category of personal data recorded in the automatic voice recording system on the support line, video interview visual and audio recordings, camera photos and recordings
Platform / Application Usage Data: User name of the member, date of membership, last login time to the site, date of the last update of the CV, date of creation of the CV, CV link, tests and results initiated and concluded on the platform, the candidate's interview and employment processes and results. Information notes and tags added about the candidate, the name of the sector in which the candidate wants to work, the last log-in date, the usage of the applications.
Optional Information Provided by the Member: Membership communities, interests, place of birth, personal web address, full residence address, home address, work mobile phone, social network connections, career goal, positions of interest, preferred city, country, expected salary range , profession, title, professional qualifications, disability, disability percentage if disability is disclosed, explanation about disability status, any additional information added to the resume. We strongly remind you that if this information is entered by the member, this data will also be processed.
Purpose of Processing Personal Data
In the event that the relevant activities of our Company regarding the processing of your personal data are expressly stipulated in the Laws.
In case the processing of your personal data is necessary for our Company to carry out its activities.
In case the processing of your personal data by our Company is directly related to and necessary for the conclusion or performance of a contract
In case the processing of your personal data is necessary for our Company to fulfill its legal obligations
Provided that your personal data has been made public by you; for your processing by our Company in a limited manner for the purpose of publicizing
In case the processing of your personal data by our Company is mandatory for the establishment, exercise or protection of the rights of our Company or you or third parties
In case it is necessary to process personal data for the legitimate interests of our Company, provided that it does not harm your fundamental rights and freedoms.
If the processing of personal data by our Company is necessary for the protection of the life or physical integrity of the personal data owner or someone else, and in this case, the personal data owner is unable to express his consent due to actual impossibility or legal invalidity.
Purpose of Processing Private Personal Data
By our company; If the personal data owner does not have the express consent of the personal data owner, sensitive personal data is processed in the following cases, provided that adequate measures to be determined by the KVK Board are taken:
Special category of personal data other than the health and sexual life of the personal data owner, in cases stipulated by the laws, are under the obligation of keeping confidential for the purpose of protecting public health, providing preventive medicine, medical diagnosis, treatment and care services. It is processed by persons or authorized institutions and organizations.
In the absence of the above-mentioned conditions; In order to process personal data, the Company seeks the express consent of personal data owners. The explicit consent of the personal data owner should be disclosed on a specific subject, based on information and free will. Company operates for the following purposes, but not limited to:
For the purpose of planning, auditing and execution of information security processes
In order to establish and manage the information technology infrastructure
For the purpose of planning and executing the satisfaction processes of our company's customers and business partners
For the purpose of monitoring and/or auditing our Company's business activities
For event management purposes
For the follow-up of finance and/or accounting works
For the follow-up of legal affairs
For the purpose of planning human resources processes
For the purposes of planning and execution of business activities
For the purpose of planning and executing information access authorizations of business partners and/or suppliers.
For the management of relations with business partners and/or suppliers
For the purpose of planning and executing corporate communication activities
For the purpose of planning and/or executing enterprise risk management activities
For the purpose of planning and executing corporate sustainability activities
For the purpose of planning and executing corporate governance activities
For the purpose of planning and executing customer relationship management processes
For the purpose of planning and/or monitoring customer satisfaction processes
In order to follow up customer demands and/or complaints
In order to carry out personnel procurement processes
For the support services after the sale of the services offered by our company
In order to ensure the security of company fixtures and/or resources
For the purpose of planning and executing company audit activities
For the planning and execution of external training activities
For the purpose of planning and executing the necessary operational activities to ensure that the company's activities are carried out in accordance with company procedures and/or relevant legislation.
For the purpose of planning and/or executing the Company's financial risk processes
For the purpose of planning and/or executing the Company's operational risk processes
For the purpose of realizing Company Law transactions
In order to follow the contract processes and/or legal demands
For the execution of strategic planning activities
For the purpose of management of third party companies, planning and execution of these processes.
For the purpose of planning and executing human resources needs, which are the subject of our company's business.
For the purpose of planning and executing the operation processes of our company's services
For the purpose of planning and executing market research activities for the sales and marketing of our company's services
For the purpose of planning and executing the marketing processes of our company's services
For the purpose of planning and executing the sales processes of our company's services
For the purpose of planning and executing the promotion and/or marketing processes of our company's services
In order to ensure that the data is correct and up-to-date
Talent – for the planning and execution of career development activities
In order to provide information to authorized persons and/or organizations based on legislation
6- POLICY ON THE TRANSFER OF PERSONAL DATA
Our company notifies the personal data owner of the groups of persons to whom personal data is transferred in accordance with Article 10 of the KVK Law.
In accordance with Articles 8 and 9 of the KVK Law, our company may transfer personal data to the following categories of persons:
Our company's customers, business partners,
Our company's suppliers,
Our company's business partners,
Legally Authorized public institutions and organizations,
Legally authorized private legal persons
Our company may transfer personal data to third parties based on one or more of the personal data processing conditions specified in Article 5 of the Law, in line with the legitimate and lawful personal data processing purposes.
Transfer of Special Category of Personal Data
Our company, by showing the necessary care, taking the necessary security measures and taking the adequate measures prescribed by the KVK Board; In line with the legitimate and lawful personal data processing purposes, it can transfer the Special Category of Personal Data of the personal data owner to third parties in the manner specified in Article 6 of the Law and in cases stipulated by the law or in cases with the explicit consent of the person.
Transfer of Personal Data To Abroad
Our company can transfer the personal data and special category of personal data of the personal data owner to third parties residing abroad by taking the necessary security measures. Personal data by our company; to be transferred to foreign countries that are declared to have adequate protection by the KVK Board or, in the absence of sufficient protection, to foreign countries where data controllers in Turkey and the relevant foreign country undertake an adequate protection in writing and where the permission of the KVK Board is available. Accordingly, our company acts in accordance with the regulations stipulated in Article 9 of the KVK Law.
Purposes of Transfer of Personal Data
Your personal data mentioned above are processed for the following purposes in order to evaluate your application, if you apply to the Company and/or Platform and sign the Service Agreement.
To create employment, to provide internship, to create MT, full-time, part-time, temporary employment and to support your work placement process,
To provide test and training services provided by the Company or by third parties in order to benefit you, in order to improve your competencies and strengthen your resume, and to inform about relevant notifications and new developments,
To ensure that content and notifications that can support you in your recruitment process are sent,
To find a job for you and to match with employer customer postings by using your personal data so that our employer customers can reach the right candidate.
Transfer your CV to the employer that you are applying for or who is seeking employment that matches your CV,
Answering your incoming calls and responding to your support needs,
If there is a complaint about the services we provide, to conclude the said complaint,
Examining your Platform account in line with your request or in case of complaints on social media,
Increasing our service quality and providing service control
To facilitate your access to our mobile applications
To inform about our new services
Receiving feedback from the candidate when surveys and competitions are held
Market interpretation, sales, marketing analysis, managerial analysis, financing planning, interpreting the use of the site.
To increase the quality of the service we provide to you and to ensure quality control
Sending bulk e-mails and SMS to help you apply
Developing our current applications and marketing the product in the management process
Developing the software used in the company by using internal and external resources
In legal cases that are mandatory within the scope of KVKK,
To increase service sales for our employer customers, to provide marketing and customer satisfaction analysis, to support our domestic and foreign employer customers
Contacting members when necessary
To increase your employment opportunities within the scope of your General Application, to enable you to do an internship, to create MT, full-time, part-time, temporary employment, to examine your resume and to identify a new candidate to be employed, to share with the employer customer
To share the video interview about the process, the test results you received, the results of the evaluation center tools, reports, survey results within the scope of your general application or company-specific applications during the evaluation process.
Sharing the notes on your resume with the employer so that the employer can better understand and get to know the candidate.
Confirming the data with the reference people you include in your resume
Saving your resume information to verify how well you fit the position and for future confirmation.
In order to provide you with our employment service, to share your personal data, including your personal data of special nature in your resume, with its annexes, with domestic and/or foreign-based employer(s) within the scope of the Service Agreement you have signed.
We have an obligation to share your personal data when we are asked to share your personal data through legal requests such as legal and procedural prosecution requests and court decisions, and in accordance with the current legal regulations to which we are subject. In addition, if your personal data is the subject of a dispute in which we are also a party, we may need to share your personal data with media and persons such as lawyers, experts, courts, which are necessary for us to exercise our right of defense. We may process your personal data in order to fulfill these legal obligations and to exercise our right of defense.
7- PERSONAL DATA STORAGE POLICY
Our company stores personal data for the period specified in these legislations, if it is stipulated in the relevant laws and regulations.
If the legislation regarding how long personal data should be stored is not regulated for a period of time, personal data is processed for a period of time that requires it to be processed in accordance with our Company's practices and commercial life practices, depending on the services our company provides while processing that data, and then it is deleted, destroyed or anonymized.
The purpose of processing personal data has ended; if the storage periods determined by the relevant legislation and the company have come to an end; Personal data can only be stored to provide evidence in possible legal disputes or to assert the right related to personal data or to establish a defense. Despite the expiry of the statute of limitations and the statute of limitations for the right to assert the aforementioned right in the establishment of the terms herein, retention periods are determined based on the examples in the previous requests made to our Company on the same issues. In this case, the stored personal data is not accessed for any other purpose, and only when necessary to use it in the relevant legal dispute, access to the relevant personal data is provided. Here, too, personal data is deleted, destroyed or anonymized after the aforementioned period expires.
8- PERSONAL DATA SECURITY POLICY
In accordance with Article 12 of the KVK Law, our company, in the capacity of data controller, of personal data;
• in order to prevent unlawful processing,
• to prevent unlawful access,
• to ensure its preservation
declares that it is obliged to take all kinds of technical and administrative measures.
9- RIGHTS OF THE RELATED PERSON
In accordance with Article 11 of the KVK Law, the person concerned.
The User has following rights;
- To learn whether personal data is processed or not,
- If personal data has been processed, to request information about it,
- To learn the purpose of processing whether,
- To know the third parties to whom personal data is transferred in the country or abroad,
- To request correction of personal data if incomplete or incorrectly processed,
- To request the deletion or destruction of personal data within the framework of the conditions stipulated in the relevant legislation,
- To request the notification of the correction, deletion and destruction processes made in accordance with the relevant legislation to the third parties to whom personal data has been transferred,
- To object to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,
To request the compensation of the damage in case of damage due to the unlawful act of processing of personal data
If you submit your requests regarding your rights in question to us using the methods specified in the KVKK Application Form on the Site, your applications will be evaluated and finalized as soon as possible and within 30 (thirty) days at the latest. Although it is essential not to charge any fees regarding the requests, the Company reserves the right to charge a fee based on the fee schedule determined by the KVK Board.
The Personal Data Owner may submit their request regarding his/her personal data until a separate method(s) is determined by the KVKK Board., İNKA ULUSAL İSTİHDAM ORG.VE İNSAN. KAYN. TUR. LTD.ŞTİ 19 Mayıs Cad. Golden Plaza k:3 n:3 ŞİŞLİ/İSTANBUL send its request to the address using a written and wet signature, secure electronic signature or registered electronic mail (KEP) address and mobile signature.
In the application containing the explanations regarding the right to be made and requested by the Personal Data Owner to use the above-mentioned rights; The requested matter must be clear and understandable, the requested matter must be related to the applicant's person or, if acting on behalf of someone else, they must be specifically authorized in this regard and this authority must be documented, the application must include identity and address information, and documents proving their identity must be attached to the application.
Such requests will be made individually and requests made by unauthorized third parties regarding personal data will not be taken into consideration.
If the request is accepted, the relevant transaction is implemented and a written or electronic notification is made. In case of rejection of the request, the applicant is notified in writing or electronically by explaining the reason..
Requests regarding personal data are concluded as soon as possible and in any case within 30 (thirty) days at the latest, free of charge, or against the fee in the tariff if the conditions in the tariff to be published by the KVK Board are met. Additional information and documents may be requested during the application or while the application is being evaluated.
In cases where the application is rejected, the answer we give is insufficient or the answer is not given on time; The applicant has the right to make a complaint to the KVK Board within 30 (Thirty) days from the date of learning the answer and in any case within 60 (Sixty) days from the date of application.
Updating, Changing and Deleting of Personal Data
On our Platform, where you are a member, it is technically impossible for any company other than our member, including our Company, to interfere with the member's personal data created by entering their username and password. Due to the technical requirements of our data recording system, the personal data owner can only update, change and/or delete their personal information.
All your personal data that you share by becoming a member of the Platform is only possible if your person completes the account closing process, all your personal data will be deleted from our system, your membership will be canceled and your resume will be permanently removed from the system. As per our system, the authority to delete the member account belongs only to the member.
If you close your account, both our Platform and the employers with whom you have an active process will no longer be able to access your resume and applications. Account closure will be done within 24 hours after the account closing order is given for security reasons. During this period, you can cancel the account closure process. After this period expires, your account will be deleted.
Personal data can also be processed in non-automatic ways, provided that it is part of any data recording system. While such data is being deleted/destroyed, a system of physical destruction of personal data is applied so that it cannot be used later..
10- PUBLICATION AND STORAGE OF THE DOCUMENT
This Personal Data Protection and Processing Policy will be notified to users with personal data with the obligation of disclosure under the KVK Law and will also be published on the websites affiliated with the Company.
11- UPDATE PERIOD
In case of changes in line with the economic and commercial decision of the company or the policy decisions of the Personal Data Protection Board, this situation will be notified to our members whose data is recorded, by the way they registered.
12- ENTRY INTO FORCE
This Personal Data Protection and Processing Policy enters into force on the date of publication and remains in effect until it is removed from the website.