This clarification text (the “Clarification Text”) is prepared for the fulfilment of the obligation to inform within the scope of Article 10 of the Personal Data Protection Law numbered 6698 (the “PDPL”), on the recording, storage, protection, adaptation, sharing with the institutions which are authorized by law to request the personal data mentioned below, transferring and assigning to domestic or foreign third parties, and categorization of your personal data as you have informed us or we have been informed of, by protecting their accuracy and actuality, in the scope of the purpose that requires them to be processed or connected to that purpose, in a limited and prudent manner, within the scope of our commercial relationship and/or our contractual relationship with you, by TG İstihdam Danışmanlık Hizmetleri Anonim Şirketi, a company established in Turkey with its head office in Nisbetiye Mahallesi Gazi Güçnar Sokak Uygur Apartmanı No:4/2 Beşiktaş/İstanbul, with the mersis number of 0843066019000001, registered to Beşiktaş Tax Office, a taxpayer with the tax number of 8430660190 (the “Company”) as the data controller.

The defined terms in this Clarification Text shall have the meaning given to them in the PDPL and the legislation related to the PDPL. Some of the defined terms are as follows:

Explicit consent: means specific, informed, and freely given consent,

Anonymization: means rendering personal data impossible to link with an identified or identifiable natural person, even through matching them with other data,

Data subject: means the natural person, whose personal data are processed,

Personal data: means any information relating to an identified or identifiable natural person,

Processing of personal data: means any operation which is performed on personal data, wholly or partially by automated means or non-automated means which 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,

Board: means the Personal Data Protection Board,

Authority: means the Personal Data Protection Authority,

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,

Personal data storage and disposal policy: means the policy which data controllers issue as a basis for erasure, destruction and anonymization of personal data and determination of maximum storage period for the purpose for which personal data are processed,

Contact person: means the natural person stated by the data controller during the registration with the Registry for the communication with the Authority relating to obligations of legal persons resident of Turkey and representatives of legal person data controllers non-resident of Turkey, within the scope of the PDPL and secondary legislation to be prepared in accordance with the PDPL.

Your personal data stated below and provided to us shall under all circumstances be processed if processing of the personal data of the parties to the agreement is necessary, within the framework of your explicit consent through approving this Clarification Text pursuant to Article 5/1 of the PDPL and provided that it is directly related to the fulfilment of our obligations under the contractual relationship you have entered into with our Company as per Article 5/2-c of the PDPL. Our policy regarding the processing of personal data is as follows: All collected personal data shall be processed in accordance with the principles listed in Article 4 of the PDPL. All collected personal data shall be processed in accordance with the conditions stated in Article 5 and 6 of the PDPL. In this context, during processing of the personal data, the data will be processed in accordance with the law and good faith, the data will be processed correctly and up-to-date when necessary, the data will be processed for specific, clear and legitimate purposes, the data will be processed in a limited and prudent manner and related to the purpose of processing, the data will be preserved for the period stated in the legislation or the period necessary for the purpose of processing.

We may process your personal data from time to time for realizing our Company’s purposes, within this scope, for the purpose of finding job positions appropriate for the persons who become members of our Company/our Company’s website for searching jobs, and providing a higher quality service to our members by preparing reports containing information on the sectors in which our members belong and the employment in these sectors by collecting the information and personal data of our members for the employers who may consider to employ our members, and additionally by operating some marketing activities, and for other purposes stated in this Clarification Text.

Your personal data that may be processed for the fulfilment of the services in question are as follows:

• ID data: Your name, surname, birth date and place of birth, gender, marital status, nationality
• Contact data: Your email address, address, mobile phone number, phone number, fax number
• Work experience data: Information on your past work experience, total work experience, current work status, current and past title, work experience (firm names, periods worked, job definition), details and experience on software knowledge, skills owned, information on the sectors in which you previously worked and on sectoral skills, software knowledge and experience
• Educational background data: Education status, the schools you have graduated, information on certificate and diplomas you have obtained, information on foreign languages you speak/write, information on the specializations you have, information on the seminars and courses you have participated, other information regarding your education and skills, information on your talents regarding computer use; software knowledge and experience
• Sensitive personal data: In case you include in any form or resume or any document or form you have submitted to our Company in written or electronic form; fingerprint, information on the membership of a political party, association, foundation, union, information on or information that may suggest your religious or philosophical view, ethnic origin and race, information on your health or your sensitive personal data which are recorded to the automatic sound recording system during your phone calls with our employees or call center (Under all circumstances, we process your sensitive personal data in accordance with the specific provisions in the PDPL and other legislation, particularly Article 6 of the PDPL. You are deemed to have given your explicit consent for processing your sensitive personal data by approving this Clarification Text.)
• Visual and auditory data: Photographs and audio recordings of natural persons
• Website/Application/Platform usage data: Membership date, positions you have been matched and/or are/were interested, website login frequency/times, ios/android/mobile site/website user, update date regarding all kinds of information, preferred job positions, cities, other criteria, information on current work status, the last login date of the candidate member, message/email delivery and receipt information, the sector in which the last message/email has been sent/received, the position for which the last message/email has been sent/received, the usage information of the website/application/platform (all moves and selections made in these)
• Miscellaneous: all information that may be included in resumes, notes regarding the members searching for jobs in case phone calls have been made, information on software developers to which the platform/membership is recommended and the software developers who have made a recommendation to the platform/membership (name, surname, title, recommendation reason, phone number, email address, linkedin profile link), Profile ID, Login ID, IP address, log records
• Besides, the projects the member is interested in, the criteria of the member for the company or the position which he/she would like to work (location, company size, side benefits etc.), salary expectation, profile links on platforms such as Linkedin and Github if available, and other information the members would like to share with our Company may be collected.

Your personal data in question will be disposed upon the expiry of the periods stated in the legislation we are subject to in connection with our employment agency activities conducted as per our contractual relationship.

We collect your personal data for the purpose of fulfilling our legal obligations as the Company within the framework of our service as an employment agency as follows:

Your personal data requested by us for the fulfilment of the membership agreement/terms of use and legitimate interest of the Company, are collected by your input of information, audio and image to our website/platforms/applications either physically or electronically and through recording of the information by yourself to the internet environment accessible by third parties, additionally through the phone calls between you and the Company’s employees and call center if we deem necessary, we collect your personal data through the audio records we obtain during the phone calls our Company makes with you within the framework of its legitimate purpose to increase customer satisfaction, we collect your personal data electronically through cookies used in our website for our legitimate purpose of improving our website/platform/applications, following their usage and making them more productive, useful and functional, as stated in detail in our cookie policy.

Moreover, personal data of employer members’ employees are collected for the purpose of communication within the scope of forms filled, emails and messages sent by the employer members and phone calls made with employer members pursuant to their communication with our Company. The employer members who transfer their employees’ personal data to our Company this way, hereby declare and undertake that they have obtained the employees’ explicit consents as per the PDPL and relevant legislation, with the transfer in question.

Your personal data stated above are being processed for the fulfilment of our contractual obligations for providing employment in accordance with the purposes below.

These purposes are;

• Fulfilling our contractual obligations by creating the relevant employment and supporting your process of finding jobs/recruitment,
• Forming and recording profiles and being informed of the companies and positions which match with the profiles,
• Reporting the notifications related to our platform/applications/website for your benefit in job opportunities appropriate to your experience and criteria; and the new developments,
• Finding jobs for members who are searching for jobs, determining the appropriate workplaces for these members, matching the personal data of members searching for jobs with the criteria and adverts of members searching for employees for the purpose of finding candidates for the positions which the employer members would like to fill, checking your references,
• Returning to your calls/emails/messages and answering to your requests and needs of help/support,
• In case there is a complaint regarding the services we provide, concluding that complaint,
• Examining your account on any website/application/platform of our company, particularly on talentgrid.io, in case of your request, or if there are complaints on any channel including social media,
• Financial management of our Company, preparing necessary reports within this scope,
• Controlling our service quality, auditing customer satisfaction within this scope, thus increasing our service quality,
• In order to provide employment to the members who are searching for jobs, sharing these members’ personal data/sensitive personal data on their resumes upon their approval, with our employer members with head offices in Turkey and/or abroad, preparing reports we deem necessary, making sector analyses, making analyses with regard to the employment status of the country and our clients and making them the subject of any bulletin, announcement, notice, analysis, declaration and study,
• Conducting analyses and studies with the aim of sales and marketing activities and financial planning, updating existing terms of work, operation and use,
• Improving and enhancing our existing and developing applications, marketing our products,
• Developing, updating, enhancing the software and applications our Company owns and/or uses, with internal and external human resource support,
• Following your actions on our applications and website/websites and based on these, providing you a personalized, easier, faster and higher quality service, increasing our existing service quality, remembering your various preferences,
• Supporting and informing potential employers within and outside of Turkey when we deem necessary or appropriate at our sole discretion.
• Personal data obtained from employer members searching for employees, belonging to the employees of such employers may be processed to communicate with such employers, for candidates we deem appropriate to communicate with such employers and for them to apply for jobs, for our Company to conduct other commercial operations, to operate marketing and advertising activities to employer members, to increase user and member experience, to make any kind of contact with the company within the scope of our contractual obligations and terms of use, to send publications, reports, bulletins, notifications to employer members, to answer member questions and provide a member service of good quality, to inform on new services, to make marketing to employer members, to communicate with employer members if necessary in other cases, to promote our Company’s services, publications, reports, websites, applications, to update information of employer members and determine their preferences better if necessary, to make surveys and market research, to fulfill our legal obligations.
• Upon the transfer of the personal data of our members searching for jobs for the purpose of their employment to potential employers, within the scope of this Clarification Text, such employer members become data controllers with regard to the personal data of our members searching for jobs, if you have any requests regarding the transactions such employer members will realize in the capacity of the data controller, such requests shall be shared with the relevant employer member(s). However, our Company has no liability regarding whether the employer member complies with your requests and their obligations as the data controller.
• Likewise, you may notify our Company for the erasure, destruction and anonymization of your personal data or sensitive personal data which were transferred to the potential employers, as stated in this Clarification Text.
• In case administrative authorities, prosecutors and courts legally request from us to share your personal data, your personal data will be shared in accordance with the legislation with such administrative authorities, prosecutors and courts. Similarly, in case your personal data becomes subject to any kind of dispute or judicial or administrative request our Company is a party to, your personal data may be shared with courts, prosecutors, attorneys, experts, mediators to enable us to use our legitimate defense right and in the scope that it is necessary for our legitimate defense right, your personal data may be processed with the purpose of such sharing and protecting our relevant defense right.
• It is your liability to inform the persons and to obtain their explicit consent for our collection and processing the personal data of the persons whom you recommend to our Company’s platform/website/applications if applicable, and of your references stated in your resume (name, surname, address, phone number, email address, topics interested, area of expertise, and other personal data). You hereby accept that you have obtained the relevant consents when you share the information of people whom you appoint as references or recommend to our platform/website/applications (in forms or resume or any other method), trade secrets of legal persons and/or confidential information. The Company preserves any legal rights against any administrative and/or criminal sanctions in this respect, you hereby declare and undertake that our Company will not incur any losses in this respect.

Personal data,

• May be transferred to all of our product and service suppliers, and other suppliers for the purposes of ensuring our service quality and maintaining our services.
• May be transferred particularly to the companies we collaborate with for searching employment, institutions searching for jobs and employees, and institutions searching for subcontractors or contractors, for the purpose of realizing our activities on providing employment, finding jobs.
• May be transferred to third parties including member employers and other employers for the purpose of providing our services of finding jobs, creating employment, realizing employment finding transactions to the member or non-member employers/companies which are searching for employees.
• Are transferred to our relevant product and service suppliers for the purpose of sending you mass or individual emails or SMS or other messages, in case you request, demand or choose the option to obtain information regarding our promotions, campaigns, products and services.
• May be transferred through the sector reports, country reports or other reports that include your personal data, to persons we deem important for the sector, potential employers and other private or public institutions and organizations which may be interested in such reports.
• May be transferred to third party software and hardware providers, server providers of whom the cloud system we use for maintaining our data.
• May be transferred to service providers and firms we work with such as Google Analytics, for our sales and marketing activities if you prefer, and under all circumstances for increasing our service quality, for improving and developing our products and services, and for all kinds of reporting activities related to our work, product, activity and member moves, for identifying your taste and area of interest better, creating/developing advertisements specific to you and the visitors of our website, for identifying persons to communicate and their contact information better, and for identifying and following where you have browsed and your operations and transactions in our application, website and platform you access via talentgrid.io.
• Although your personal data is used for the sector reports, country reports and other reports our Company prepares, these reports do not include the information on whose personal data the reports are based upon. However, we may transfer such reports within or outside of Turkey to persons we deem important for the sector, potential employers and other private or public institutions and organizations which may be interested in such reports.

Apart from the exemptions listed in Article 5 and 6 of the PDPL, data will not be transferred to third parties without the explicit consent of the data subject.

Data will not be transferred abroad without the explicit consent of the data subject apart from the exemption set forth in Article 9/2 of the PDPL.

Within the scope of Article 11 of the PDPL, each person has the right to apply to our Company about himself/herself to

1. learn whether his/her personal data are processed or not,
2. if his/her personal data have been processed, request information on this,
3. learn the purpose of the processing of his/her personal data and whether these personal data are used in compliance with the purpose,
4. know the third parties to whom his/her personal data are transferred within the country or abroad,
5. request the rectification of the incomplete or inaccurate data, if any,
6. request the erasure or destruction of his/her personal data under the conditions referred to in Article 7 of the PDPL,
7. request the reporting of the operations carried out pursuant to sub-paragraphs (e) and (f) to third parties to whom his/her personal data have been transferred,
8. to object to the occurrence of a result against the person himself/herself by analyzing the data processed solely through automated systems,
9. to claim compensation for the damages arising from the unlawful processing of his/her personal data if applicable.

Each person may make requests to our Company within the scope of their rights specified in Article 11 of the PDPL, in writing or by registered electronic mail (KEP) address, secured electronic signature, mobile signature or by the email address which has been previously notified to our Company and recorded in our Company’s system or by means of a software or application designed for the purposes of this request in case it is developed and provided by our Company. Written requests shall be sent to the following address: Nisbetiye Mahallesi Gazi Güçnar Sokak Uygur Apartmanı No:4/2 Beşiktaş/İstanbul; the requests sent to this address shall be in written form and include the wet-ink signature of the data subject.

The requests must also include the requester’s name, surname, signature, Turkish Republic identity number or nationality and passport number or identity number if available, correspondence address, email address if available, telephone and fax number if available, and demand. Related documents and information shall be attached to the request. The demand shall be stated clearly and lucidly. The requests will be evaluated pursuant to the PDPL and relevant legislation and Board decisions and valid requests will be put into process within this scope and the requester will be informed.

Our Company has the right to accept or refuse the request with the explanation of the grounds under the Communiqué on the Principles and Procedures for the Request to Data Controller. Our response will be notified in written or electronic form.

Our response will include the information regarding our Company as the data controller or our representative, the requester’s name and surname, for Turkish citizens, Turkish Republic identity number, for foreigners nationality, passport number or identity number if available, residential and business address subject to the notification, electronic mail address, telephone and fax numbers subject to notification if available, subject of demand,  and explanations of our Company regarding the request.

Our Company will conclude the demands set forth in the request as soon as possible by taking into account the nature of the demand and at the latest within thirty days and free of charge. However, if the process requires additional costs, fees laid down in Article 7 of the Communiqué on the Principles and Procedures for the Request to Data Controller may be charged. If the request is made due to the fault of our Company, the fee will be refunded to the data subject. In the case that the demand of the data subject is accepted, the demand shall be fulfilled by our Company as soon as possible and the data subject will be informed.

TG İSTİHDAM DANIŞMANLIK HİZMETLERİ A.Ş.

Mersis No: 0843066019000001

Contact: [email protected]

Address: Nisbetiye Mahallesi Gazi Güçnar Sokak Uygur Apartmanı No:4/2 Beşiktaş/İstanbul