Personal Data Protection Policy and Clarification Text

Zeynep Bilgiç Danışmanlık Anonim Şirketi (the “Company”), we attach great importance to the protection and processing of personal data. We are sensitive about the processing, protection and transfer of the relevant data in compliance with the Law on the Protection of Personal Data No. 6698. (“Internet Site”) of the website www.workflexnow.com operated by the Company and owned by the Company, by us, as the Company, in the capacity of data controller. Personal Data Protection Policy and   Clarification Text (“Clarification Text”) ; It includes our statements and explanations regarding the processed personal data, the purpose of data processing, the data categories, the collection method and legal reason for the data, to whom and for what purposes it can be transferred, our information as the data controller, the data processing time and your rights regarding your data.

  1. DEFINITIONS AND ABBREVIATIONS:
    1. Explicit Consent: Represents the consent that is based on information and freely expressed regarding a certain subject.
    2. Anonymization:It means making personal data not to be associated with an identified or identifiable natural person under any circumstances, even by matching with other data.
    3. Relevant Person/Data Owner: Represents the real person whose personal data is processed.
    4. Law: Law on the Protection of Personal Data No. 6698, published in the Official Gazette dated 7 April 2016 and numbered 29677
    5. Personal Data: Refers to any information relating to an identified or identifiable natural person.
    6. Special Quality Data: The person's race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothing, association, foundation or union membership, health, sexual life, It includes data on criminal convictions and security measures, as well as biometric and genetic data.
    7. Processing of Personal Data: Obtaining, recording, storing, preserving, changing, rearranging, disclosing personal data completely or partially automatically or non-automatically provided that it is a part of any data recording system means all kinds of operations performed on data such as transferring, taking over, making it available, classifying or preventing its use.
    8. Data Controller: A 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 recording system.
    9. Data Processor: A natural or legal person who processes personal data on behalf of the data controller based on the authority given by the data controller.
    10. Data Registration System: It is the registration system in which personal data is processed and structured according to certain criteria.
    11. Application Form: This is the form containing the application to be made by the data owner to exercise their rights within the framework of the relevant legislation.
    12. Policy: Personal Data Protection and Privacy Policy (“Policy”)
    13. Destruction: It is the deletion, destruction or anonymization of personal data.
    14. Recording Medium: Any medium in which personal data is processed wholly or partially automatically or non-automatically provided that it is a part of any data recording system.
  2. GENERAL PRINCIPLES REGARDING THE PROCESSING OF PERSONAL DATA
    1. Compliance with the law and honesty rules: All personal data processed by the Company are processed in accordance with the law, without violating the Constitution of the Republic of Turkey and the KVKK as well as all legislation and honesty rules.
    2. To be accurate and up-to-date when necessary: ​​The Company attaches importance to the fact that the personal data it processes is correct, does not contain false information, and to update the personal data in case of a change in the personal data and when these changes are notified.
    3. Processing for certain clear and legitimate purposes: The Company processes personal data for clearly and precisely determined legitimate purposes. Data is not processed other than for these purposes.
    4. Being connected, limited and measured for the purpose for which they are processed: Personal data processed by the company is used in accordance with the KVKK and other legislation, limited to the purpose for which they are processed and to the extent required by the service.
    5. Preservation for as long as required by the relevant legislation or for the purpose for which they are processed: Personal data processed by the Company is retained for the period required for the purpose for which they are processed in the relevant legislation.
  3. CONDITIONS OF PROCESSING PERSONAL DATA
    1. Personal data processed by the Company is processed in accordance with the conditions determined in accordance with KVKK. The processing conditions of personal data are listed in Article 5 of the KVKK, and accordingly, it is possible to process personal data if at least one of the following conditions is present:
    2. Existence of the person's express consent,
    3. explicitly stipulated in laws,
    4. The person who is unable to express his/her consent due to de facto impossibility or whose consent is not given legal validity is compulsory for the protection of himself or someone else's life or bodily integrity,
    5. It is necessary to process the personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract,
    6. It is mandatory for the data controller to fulfill its legal obligation,
    7. The person concerned has been made public by himself,
    8. Compulsory data processing for the establishment, exercise or protection of a right,
    9. The data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject,
    10. The processing conditions of personal data, that is, their compliance with the law, are determined by counting in the Law, and these conditions cannot be extended.
  4. PERSONAL DATA COLLECTED

    The following personal data may be collected within the scope of the Company's business and activities:

    1. Contact Information (“Contact Information”): Address information, e-mail address, contact address, registered e-mail address (KEP), telephone number, fax number, workspace social media account,
    2. Identity Information (“Identity Information”): Name-surname, TR identity number,
    3. Personal Information: Users; educational status, certificate and diploma information, foreign language information, CV, courses attended, work experiences, references, performance information, work preferences, working hours, education and skills, information on the date of education, e-mail, signed participation form , target realization status, payment preferences and information, bank account information from which they request payment,
    4. Transaction Information:  Workflex user registration information, call center records, website navigation and click information, internet access logs, entry and exit logs, cookie usage information, Internet protocol (IP) address , device ID, web page views and statistics on mobile and other digital applications,
    5. Answers to survey and form questions: Periodic survey information, answers to forms or surveys organized by the Company by phone, e-mail and/or within the portal, and natural and legal persons with whom the Company cooperates Responses to the surveys conducted by
    6. Visual and Audio Data: Photo of real person.
  5. PERSONAL DATA OWNERS:
    1. Visitor: Persons who visited the Website.
    2. Talent/Talent Candidate: Real persons who have applied to Workflex/Company to join the Talent ecosystem or have opened their CV and related information to the Company's review.
    3. Customer: A person who is in a managerial position in the company, who is matched with Talents within the scope of Workflex/Company activities and provides benefits by getting certain works done on a project basis.
    4. Shareholders of the Company:The shareholders of the Company are natural persons.
    5. Company Officials: Company board member and other authorized natural persons.
    6. Employees, Shareholders and Authorities of Collaborating Institutions/Customers: Institutions/companies with which the Company has any business relationship (such as but not limited to business partners, suppliers) and Customers natural persons, including employees, shareholders and officials of these institutions.
  6. COLLECTION METHOD AND LEGAL REASONS OF PERSONAL DATA

    Your personal data; It will be collected physically and/or electronically via the website, call center, user agreement, written forms and statements and e-mails and can be stored for the period required for the purpose for which they are processed in the KVKK and relevant legislation. You can review our “Retention and Disposal Policy within the scope of the periods during which your personal data will be retained.

    Personalized by the companyYour data may be collected, processed and transferred for the purposes specified in this Clarification Text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVKK, in accordance with the basic principles stipulated by the KVKK in line with the realization of the purposes described above.

    In this context; Your personal data is within the scope of Article 5 of the KVKK, (i) it is necessary for the data controller to fulfill its legal obligation, (ii) it is necessary to process the personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract, (iii) the basic data of the data subject. Provided that it does not harm the rights and freedoms of the data controller, it is collected, processed and transferred on the basis of legal reasons that data processing is compulsory for the legitimate interests of the data controller or (iv) your express consent.

  7. PURPOSE OF PROCESSING AND USE OF PERSONAL DATA

    The Company processes personal data within the framework permitted by the Law and for the purposes and reasons listed below.

    • Execution of Information Security Processes: Measures taken for the safe use of our site,
    • Fulfilling the Requirements of User Agreements: Evaluation of the applicants to the site, matching and execution of the processes in case of initiation of user on the Platform,
    • Fulfilling our legal obligations regarding the Conduct of Activities in Compliance with the Legislation and the operation of the Site, fulfillment of tax obligations,
    • Execution of Finance and Accounting Affairs,
    • Execution / Supervision of Business Activities,
    • Execution of User Relationship Management Processes,
    • Executing Activities for User Satisfaction,
    • Executing Marketing Analysis Studies,
    • Tracking of Requests / Complaints,
    • Informing Authorized Persons, Institutions and Organizations,
    • Monitoring the Security of Data Controller Operations,
    • The Processing of Personal Data is Necessary for the Performance and the Data Processing is Mandatory for the Establishment, Use or Protection of a Right,
    • Becoming a Contracting Party
    • Execution of Communication Activities
    • Execution of Storage and Archive Activities
    • Informing the Public and Users and Providing Additional Benefits to Users
    • Mandatory Data Processing for the Legitimate Interests of the Company, Provided that Fundamental Rights and Freedoms are Not Infringed
    • Providing Communication and Communication between Users on Platforms Established within the Company.

    Accordingly, the Company processes your personal data within the framework of the Website Terms of Use and Personal/Corporate User Agreement, which you approve by accepting our general terms of use when you register on the site. If you want to review our website terms of use, you can reach it by clicking the link.

    For this reason, all the data you transmit to us during the creation and management of your profile, the data required for matching with the institution and the project, and the tracking, performance, monitoring and billing of the project process, in connection with our support service or services we provide as part of secure messaging and communication, and legally. rendered within the frame.

    If you have entered your personal information to benefit from Company services, we will use your data to enable you to access these services and to track your access to the services. For example, if you are an independent consultant/freelancer, etc. who have expertise in a certain field and you want to take part in the Company platform, your personal information can be used to create a summary (“Profile”) to introduce you in projects that match your expertise, and this Profile will be used by the Company within the scope of the project. It will be visible to customers. The consent you have given for the use of your personal data on the Website will also be valid for the Website managed by the Company for the purposes and within the scope specified in the Clarification Text on the Protection and Processing of Personal Data, and the Company www.workflexnow.com will be able to use your personal data on the website.

    Your personal data may be processed in the presence of your express consent to be obtained in accordance with Articles 5 and 8 of the KVKK, in order to fulfill the requirements arising from the contract and the law, including the purposes listed above.

    Legitimate interest: In addition, we process some of your data on the basis of our legitimate interest for management purposes. In this context, there are requirements for providing secure access to the Website, taking precautions against fraud, and accounting.

    Explicit consent: Your personal data, including the above-mentioned purposes, are protected by contract and law.In order to fulfill the requirements, it can be processed in the presence of your explicit consent to be obtained in accordance with Articles 5 and 8 of the KVKK. For example, we process your Personal Data based on your explicit consent, in cases where your profile photo is reused by our services or you have not created an account on the platform but you want to receive information about our commercial offers / newsletter.

    Legal obligations: Your Personal data is processed due to the legal obligations imposed on us in connection with the management of payments made through the Platform and especially in connection with the fight against terrorism and money laundering.

    Other Data Processing Reasons: It is also possible to process your personal data on the grounds that the data processing is clearly stipulated in the law, the data processing is made public by the data subject himself, and the data processing is mandatory for the establishment, exercise or protection of a right.</p >

    Your Private Data: We specifically refrain from processing your private data. In this context, in the context of your membership, any personal information that is not directly related to your competencies, and especially your private (sensitive) data (race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, costume and clothing, association, foundation or We strongly recommend that you refrain from mentioning union membership, health, sexual life, criminal convictions and security measures, biometric and genetic data) in the company, and that you blacken out the relevant parts in the CV and documents you have given in writing, if any.

    If you are providing your personal data for a purpose other than the Workflex Platform registration, we may use your data in accordance with the purpose you have specified. For example, if you have reached us via e-mail, we may use the data you provide to respond to you or to solve your problem.

    The company or its subsidiaries or business partners will use the personal data you provide in order to contact you about the services. You can withdraw your consent for the use of your personal data at any time by applying to the Company in writing (including via e-mail), and with the cancellation of the consent, your right to take part in the platform and to benefit from the services provided by the Company on the Website will also come to an end. . However, if the use of your personal data is necessary within the scope of the commercial relationship you have established with other users of the Website or the Company during the period of your consent, your personal data may be used by the Company to the extent necessary until the payment and completion of this service and the payments related to the service.

    Your personal data collected through the site will also be used to inform you about the Company's services and developments. In the advertisement and promotional e-mails sent to you, there will be a section that will allow you to stop receiving these promotional e-mails, which you can unsubscribe at any time.

    You can request that the use of your personal data be stopped or the information that you think is wrong be changed by making a written application to the Company. Your cookies are used within the framework of the purposes specified in the Cookie Policy and this Clarification Text.

  8. CONDITIONS WHERE PERSONAL DATA MAY BE PROCESSED WITHOUT EXPRESS CONSENT

    By the Company (from www.workflexnow.com) with the express consent of the Relevant Person and pursuant to Article 5 of the Law. and 6, without express consent, has the right to process general and special data.

    Situations where data can be processed without seeking explicit consent:

    explicit in laws; It is necessary for the protection of the life or physical integrity of the person or another person, who is unable to express his consent due to actual impossibility or whose consent is not legally valid; Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract; It is mandatory for the data controller to fulfill its legal obligation; It has been made public by the person concerned; Data processing is mandatory for the establishment, use or protection of a right, Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

    For example, contact and identity information such as name-surname, telephone, e-mail etc., company information, answers to survey questions, entries to forms, documents uploaded to the system, your education status and resume, work history and bank account information/credit card Information on payment records is included in the scope. The Site, you as a user, Protection of Personal Data, processing and aThe Company will not allow this data to be transferred to the Company's records without reading and approving the Clarification Text and Cookie Policy regarding the transfer of data.

  9. THE PERSONAL DATA THAT CAN BE TRANSFERRED

    Your personal data specified below may be transferred within the scope of the company's business and activities.

     

    1. Contact Information: Address information, E-mail address, Contact address, Registered e-mail address (KEP), Telephone number, fax number, etc. Workflex users, Company officials, employees and officers for situations such as providing communication between users, providing additional benefits to users, business partner, sponsor, supplier, natural person or legal person, if necessary, if service is received for the fulfillment of these transactions. may be transferred to its officials and employees.

       

    2. Identity Information: Name-Surname data Within the scope of communication between Talents and Customers, it may be shared with Company employees, real or legal persons from whom services are received, employees and officers.

       

    3. Transaction Information: Workflex Platform registration information, call center records, website browsing and click information, internet access logs, entry and exit logs, cookie usage information, Internet protocol (IP) address , device ID, website views, statistics on mobile and other digital applications, Company employees, officials, shareholders, and third parties, in case of service for these purposes, and their employees and officials, in order to ensure website security and efficiency; In addition, these data may be shared with authorized public institutions and organizations upon request for reasons arising from the Law.

       

    4. Survey/Question Answers: Periodic survey information and answers to surveys organized by the Company via telephone, e-mail and/or within the Platform, and responses to surveys made by real and legal persons with whom the Company cooperates The answers can be shared with the public in channels such as Company Talent and Customers, real and legal persons, employees and officers with whom the Company cooperates, and Company social media accounts, digital communication platforms, e-bulletins, and the website.

       

    5. Visual Data: The photos shared by the users with the Company can be shared with the public on their profiles on the Platform and on the Company's social media accounts, digital communication platforms, e-bulletins, and the website.

    6. Personal Information: Users; education status, certificate and diploma information, foreign language information, CV, courses attended, work experiences, references, performance information, work preferences, working hours, education and skills, information on which date of education he received, e-mail, signed participation form , target realization status, payment preferences and information may be shared with Customers for the purposes of matching Talent and Customers and realizing related projects.

  10. PURPOSE OF TRANSFERRING YOUR PERSONAL DATA

    As explained in detail above, personal data processed by the Company limited to the purposes mentioned in this clarification text and in accordance with Articles 5 and 6 of the law;

    • Execution and execution of business activities and ensuring the registration of users on the site, Establishing communication between Talent and Customers, Communication with Talent and Customers, necessity within the scope of legislation or performance of activities, providing analysis and efficiency for user opinions and expectations It can be transferred in order to fulfill the requirements under the scope of.
    • In case of transfer of a commercial enterprise, personal data may also be transferred as an asset of the Company, in case the Company is transferred to another company through merger or transfer, establishment of a partnership or merging their business with another company. In this case, the data of the people who apply for and become members in the system will be visible to the relevant Company as a part of the system.
    • To the registration companies and representatives that we have authorized, operating on behalf of and on behalf of our Company,
    • Regulatory and supervisory institutions and public institutions or organizations that are expressly authorized to request personal data in laws,
    • Within the scope of the specified purposes, business partnerships, suppliers and contractor companies, banks, credit risk and financial institutions and other real or legal persons,
    • Tax and similar consultants, obligatory persons regarding legal proceedings, publicIt can be transferred to institutions and organizations and third parties, including auditors, from whom we receive consultancy, and to business partners, third parties from whom service is received, authorized persons and organizations for the above-mentioned purposes.
    • Your personal data is not transferred abroad by the Company in any way, and if necessary, your express consent for the transfer will be obtained separately.
    • Your personal data may be transferred in the presence of your express consent to be obtained in accordance with Article 8 of the KVKK, for the purposes of fulfilling the requirements arising from the Individual and Customer User Agreements, including the purposes listed above, and for other purposes arising from the law.
  11. CONDITIONS WHERE YOUR PERSONAL DATA MAY BE TRANSFERRED WITHOUT EXPRESS CONSENT

    Your personal data is clearly stipulated in the Laws in accordance with the second paragraph of Article 8 of the KVKK; It is necessary for the protection of the life or physical integrity of the person or another person, who is unable to express his consent due to actual impossibility or whose consent is not legally valid; Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract; It is mandatory for the data controller to fulfill its legal obligation; It has been made public by the person concerned; Data processing is mandatory for the establishment, exercise or protection of a right; Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject,

    Personal data other than health and sexual life listed in the first paragraph of Article 6 regulated in the third paragraph of Article 6 of the KVKK, without seeking the explicit consent of the person concerned, in cases stipulated by the laws; Personal data related to health and sexual life can only be transferred without your explicit consent, in accordance with the confidentiality obligation, for the purposes of protecting public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing.

  12. TRANSFERED PERSONS AND METHODS OF TRANSFER

    Within the framework of the above-described purposes, requirements and the limits specified in the legislation; Legally authorized public and private institutions and organizations, Company officials, employees, officers and shareholders, domestic business partners, Customers and users, suppliers and sponsors, group companies, subsidiaries and affiliates, independent audit companies, service procurement required for the performance of activities We share with real and legal persons at borders, with users in profiles created on the Workflex Platform, with relevant real and legal persons through secure electronic or other communication channels, depending on the characteristics of the data and activity, by publishing the profile information on the Platform on the Internet Site.

    In case of communication between users using electronic communication devices and applications within the scope of company activities, the device or application operator may be transferred to the third party ("Third Party") by the user, in order to use the related devices and applications that can be shared between the parties of the communication. ) In case the personal data provided is processed by the Third Party and/or transferred to other persons, institutions and organizations due to the communication being carried out on the Third Party applications, this is in accordance with the terms of use, privacy and personal data protection policies of the Third Party devices or applications. subject to The Company has no responsibility in this case.

  13. STORAGE AND DISPOSAL OF PERSONAL DATA

    The Company keeps the personal data kept in accordance with all relevant legislation, especially the KVKK, for the purpose of carrying out its commercial activities and for the period required by the processing purposes specified in this clarification text, taking into account the statute of limitations in the Law and other legislation.

    The Company collects the personal data obtained from this Clarification Text and Website Terms of Use, Individual User Agreement and Corporate User Agreement within the framework of the conditions and for the period necessary for the purpose for which they are processed in order to fulfill the obligations arising from the nature of these Agreements.

    In addition, in case of any conflict that may arise from the Website Terms of Use and Personal/Corporate User Agreement or the Clarification Text and Cookie Policy, the Company will take the necessary defenses within the scope of the dispute.

    The Company bases all its operations and activities on all administrative and technical protection measures sought by the legislation in order to ensure the protection of personal data specified in this Policy, within the framework of the general principles regarding the processing of personal data, and within the framework of the purposes specified in this Policy, and periodically renews it.

    In the event that the purpose of processing personal data disappears, the data will be deleted, destroyed or anonymized by our institution ex officio or upon the request of the person concerned. In the event that the data is deleted as we have stated, the data cannot be reused and cannot be restored in any way.

    In the event of the expiration of the terms or services, the said data is deleted or destroyed in accordance with the Law.

    For more information about the storage and destruction of your personal data, you can find www.workflexnow.com at You can review the "Retention and Disposal Policy".

  14. MEASURES TAKEN TO PROTECT PERSONAL DATA

    The company is committed to protecting your personal data securely.

    Company; With the conditions specified in the Law and this Clarification Text; undertakes to take all necessary technical and administrative measures to protect personal data, to ensure that personal data is not processed unlawfully, to prevent unlawful access to personal data, and to prevent data leaks, and to carry out all necessary inspections in a timely and complete manner.

    Your personal data will be processed by taking all necessary information security measures, provided that it is not used outside of the purposes and scope notified to you, and will be stored and processed during the legal retention period or, if such a period is not foreseen, for the period required by the processing purpose. When this period expires, your personal data will be removed from the Company's data streams by deletion, destruction or anonymization methods.

  15. RELATED YOUR RIGHTS AS A PERSON

    You can always contact the Company for information on the following matters within the scope of the law;

    According to Article 11 of the KVKK, your personal data; a) learning whether it has been processed, b) requesting information if it has been processed, c) learning the purpose of the processing and whether it is used in accordance with its purpose, ç) knowing the third parties to whom it has been transferred, d) requesting correction if it has been processed incompletely / incorrectly, e) To request deletion / destruction within the framework of the conditions stipulated in Article ., f) to request notification of the transactions made in accordance with subparagraphs (d) and (e) above, to the third parties to whom it has been transferred, g) to object to the emergence of a result against you because it is analyzed exclusively by automatic systems, ğ) You have the right to demand the compensation of the damage in case you suffer damage due to unlawful processing.

    Channels You Can Reach Us With Your Requests:

    As the company that is the data controller that will process your personal data, you can personally submit your requests within the scope of Article 11 of the KVKK, which regulates the rights of the person concerned, in accordance with the "Communiqué on the Procedures and Principles of Application to the Data Officer", Şişikler Business Center No: 1 / 9 Feneryolu Mahallesi Bayrak Çıkmazı Sokak 34724 Kadıköy/ İstanbul Turkey, send it via the notary public channel or other methods determined by the Personal Data Protection Board, or info@workflexnow.com.

    Your request will be responded to as soon as possible and in accordance with the law, within thirty (30) days at the latest. However, if the transaction requires an additional cost, the Company reserves the right to charge a fee, in accordance with the Law, at the tariff determined by the Personal Data Protection Board.

  16. ENFORCEMENT

    The effective date of this Policy is 01.02.2021. The Company reserves the right to make changes in the Policy in line with the legal regulations. You can find the current version of the Policy on our website.

    We recommend that you read this Clarification Text prepared for you before approving, thank you in advance for reading.

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