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Legal · KVKK · Data Protection

Privacy Policy

Version 1.0Effective: 7 April 2016 (KVKK)

As CALIGO Teknoloji Anonim Şirketi (“Company”), we hereby inform you as data controller that your personal data will be recorded, stored, maintained, organised, disclosed with institutions which are legally authorised to request it, and may be transferred to third persons within and outside the country — in accordance with law and good faith, maintaining accuracy and currency, for clear and legal purposes, and in a way that is relevant, limited, and restricted to the purpose for which it is processed.

01

Personal Data We Process

Your personal data that may be subject to our processing is as follows:

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
02

Purposes and Legal Bases for Processing

In the event you apply to our Company, we process your data to evaluate your job application in compliance with law for the establishment of a business contract within the employee candidate–employer candidate legal relationship. Under Art. 5/2/(c) of KVKK, we process your personal data to:

We also process personal data pursuant to legal notifications and when requested by legal authorities such as prosecution offices and courts (Art. 5/2/(ç) of KVKK). In case your personal data is subject to a dispute to which we are a party, we may process and disclose your data to attorneys, experts and courts for our right to defence (Art. 5/2/(e)).

Within the scope of the recruitment process and the evaluation of your suitability for the position, we may share your CV data with Clients under Art. 5/2/(c) of KVKK. Sensitive personal data not requested and not required for processing purposes (religious knowledge, blood type, union/association/foundation memberships, philosophical views) will be destroyed using blackout methods.

03

Purposes and Legal Bases for Processing Sensitive Personal Data

Under KVKK, your race, ethnical origin, political opinions, philosophical opinions, religion, sect or other beliefs, clothing and style, association/foundation/union memberships, health, sexual life, conviction status and related safety measures, and biometric and genetic data are considered sensitive personal data.

We recommend that you do not include sensitive personal data in your CV or during interviews unless we specifically ask you to. Your personal data will be stored for the term stated in the relevant regulation or required for the processing purpose, and for the legal limitation periods in any case.

You accept and guarantee that any reference contact data you disclose has been shared with the knowledge and consent of the relevant reference contact, and all responsibility will belong to you if the reference owner claims otherwise.

04

Method of Collecting Your Personal Data

For the legal reasons described above, your personal data may be obtained from career pages such as www.linkedin.com and www.kariyer.net, e-mails sent to kvkk@caligo.com.tr, consultancy companies, Company employee references, or directly from you through automatic and non-automatic means, and will be stored in electronic and physical environments.

05

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, and firewalls. 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.

06

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.

07

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
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
Visitor and meeting records2 years after the event
CCTV footage6 months
08

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.