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Privacy Policy

Version 2.0Effective: July 2025Replaces: v1.0 — 7 April 2016

As CALIGO Teknoloji Anonim Şirketi (“Company”), acting as data controller under Law No. 6698 on the Protection of Personal Data (“KVKK”), we inform you that your personal data will be processed lawfully, fairly, accurately and in a current manner, for specific, explicit and legitimate purposes, and in a way that is relevant, limited and proportionate to those purposes.

This notice covers three groups of data subjects: Website Visitors (caligo.com.tr), Job Applicants, and Prospective Clients / Contact Requests.

01

Website Visitors

Personal data processed:

CategoryData Processed
Technical DataIP address, browser type and version, operating system, pages visited, session duration
Cookie DataMandatory session cookies; analytics cookies (Google Analytics) only if consent is given
Interaction DataClick flow, page view sequence (only with explicit consent)

Purposes and legal bases:

PurposeLegal Basis
Technical operation and security of the websiteKVKK Art. 5/2/(f) — Legitimate interest
Measuring and improving website performance (Google Analytics)KVKK Art. 5/1 — Explicit consent
Legal obligations and competent authority requestsKVKK Art. 5/2/(ç) — Legal obligation

Analytics cookies are loaded only after you give explicit consent via the cookie banner. You may change your preferences at any time via the “Cookie Preferences” link in the website footer.

International data transfer: Google Analytics is provided by Google LLC (USA). Where you have consented, technical analytics data is transferred to this platform. Google LLC is bound by EU Standard Contractual Clauses under GDPR; for Türkiye, the transfer is based on your explicit consent under KVKK Art. 9. Transfer ceases immediately upon withdrawal of consent.

Retention: Web server logs maximum 1 year. Analytics data subject to Google Analytics default retention policy (14 months).

02

Job Applicants

Personal data we process:

CategoryData Processed
Identity DataName, surname, ID number, date and place of birth, sex, marital status
Contact DataE-mail address, street address, district/province, land and/or mobile phone
Sensitive Personal DataAssociation, foundation, union, political party memberships (if included in CV); information relating to religious or philosophical beliefs, ethnical origin or race; health information; personality test results; former conviction status / criminal records
Education DataEducation status, certificates and diplomas, specialties, foreign language skills, training and skills, seminars and courses, computer skills, job interviews and assessments
Work Experience DataOverall experience, work status and title, work experiences (company names, periods, job descriptions)
Audio-Visual DataPhotograph of the natural person
OtherCompetences, military status, reference details (name, title, workplace, phone, e-mail); any Word, Excel or PowerPoint files attached to the CV; cover letter; aptitude test results

Purposes and legal bases: We process your data to evaluate your job application for the establishment of an employment contract (KVKK Art. 5/2/(c)). Specifically:

We also process data pursuant to legal authority requests (Art. 5/2/(ç)) and for the right of defence in legal proceedings (Art. 5/2/(e)). Within the scope of the recruitment process, we may share your CV data with Clients under Art. 5/2/(c). Sensitive personal data not requested and not required for processing purposes (religious knowledge, blood type, union/association/foundation memberships) will be destroyed using blackout methods.

Data collection sources: Career pages (linkedin.com, kariyer.net), e-mails sent to kvkk@caligo.com.tr, consultancy companies, Company employee references, or directly from you.

You accept and guarantee that any reference contact data you disclose has been shared with the knowledge and consent of the relevant reference contact.

03

Prospective Clients & Contact Requests

When you contact us via info@caligo.com.tr or by phone, we process your name, surname, e-mail address, company name, title and the content of your message.

Purpose and legal basis: Conducting business communications and taking steps toward establishing a business relationship (KVKK Art. 5/2/(c)).

Retention: 2 years if no business relationship is established; 10 years from contract termination if a relationship is established.

04

Technical and Administrative Measures

As data controller, the Company takes all necessary technical and administrative measures to prevent unlawful processing of and access to personal data, and to ensure its safeguarding. Technical measures include penetration testing, secure environments for personal data, user account and access control systems, log records, intrusion detection/prevention systems, data loss prevention software, network and application security, anti-virus systems, firewalls, and an ISO/IEC 27001:2022 certified information security management system. Administrative measures include physical access controls, a personal data processing inventory, data security policies and procedures, confidentiality agreements, regular training and awareness activities, and VERBİS registration.

05

Transfer of Personal Data

Within Türkiye: Personal data and sensitive personal data may be transferred to third parties in Türkiye with the explicit consent of the data subject, or where required by law and with necessary security measures, in accordance with Art. 8 of KVKK.

Outside Türkiye: Personal data may be transferred abroad with the explicit consent of the data subject, or where the destination country provides adequate protection or the Company and relevant foreign data controllers provide written commitment of adequate protection, subject to the Board’s permission. For Google Analytics, this commitment is based on Google LLC’s EU Standard Contractual Clauses.

06

Retention and Destruction of Personal Data

Personal data is stored securely in physical or electronic environments for as long as necessary for the Company’s commercial activities. Upon expiry of the applicable retention period or upon the data subject’s request, data is deleted, destroyed, or anonymised. The Company carries out periodic destruction every 6 months (June and December). Retention periods include:

ProcessRetention Period
Unsuccessful job applicants2 years from application
Contract preparation10 years after contract termination
HR and accounting processes10 years after activity ends
Payroll10 years after employment ends
Health and safety data10 years after employment ends
Website visitor logs1 year maximum
Visitor and meeting records2 years after the event
CCTV footage6 months
07

Your Rights

Pursuant to Art. 11 of KVKK, upon proving your identity you have the right to:

You may submit your requests to kvkk@caligo.com.tr via a secure electronic or mobile signature, or in writing to: Levent Mahallesi Meltem Sokak İş Kuleleri Kule-2 Kat 9 No:10/10 P.K:34330 Beşiktaş, İstanbul-Türkiye (via notary or registered letter with return receipt). Applications will be concluded free of charge within 30 days at the latest.

Questions About This Policy?

For all requests and enquiries regarding personal data, contact us at kvkk@caligo.com.tr or in writing to: Levent Mahallesi Meltem Sokak İş Kuleleri Kule-2 Kat 9 No:10/10 P.K:34330 Beşiktaş, İstanbul-Türkiye.