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Personal Data Protection and Processing User Privacy Notice

  • As Sorwe Information and Mobile Technologies A.S. ("SORWE"), we attach high importance to the security and confidentiality of your personal data and we adopt the highest level of security measures to keep your data safe. With Sorwe’s “Data Controller and/or data processor” title, we operate in accordance of the Personal Data Protection Law No.6698 ("KVKK") and the relevant legislations applicable in Europe, as stated in detail in the Disclosure Text on Protection of Personal Data.
  • SORWE, Disclosure Text About Processing Personal Data, ("Disclosure Text") in accordance with the article titled "Obligation of Data Supervisor" in the 10th article of KVKK, has been prepared to inform you in the most transparent way about the identity of the data controller, the method of collecting personal data and the legal base, the purpose for which data will be processed, to whom and for what purpose it can be transferred, data processing period and your rights listed in Article 11 of the KVKK.
  • 1- What Personal Data Does SORWE Process?
    From SORWE’s channels, website, social media channels, call center, mobile applications and similar means prepared and presented to you by us; verbal, written or electronic identification (Name-Surname, Date of Birth, Gender), contact information (e-mail, telephone number), mail, mobile phone), professional experience (in-service training information), personnel (performance evaluation reports), marketing (cookie records) and some data on transaction security (IP address information, log records, password and password information, website / application login and exit information, your mobile device's operating system and operating system version number) and some of personal data based on your preferences and the answers to the questions in the system that are related to your identity information (race, ethnicity, political opinion, philosophical belief, religion, sect or other beliefs, clothing preference, association, foundation or union memberships, health, sexual life, criminal conviction and security measures, and biometric and genetic data can be processed by SORWE

    The method of collecting your qualified personal data in the disclosure text is processed for the specified purposes and stated legal reasons by taking high-level security measures, and is shared only by being anonymized / unmatched with your identity, unless there is an explicit consent to share from you.

    2- Processing Method and Legal Reason for Your Personal Data:
    Although your personal data may vary depending on your relationship with SORWE, it may be collected verbally, in writing or electronically, by automatic or non-automatic methods, through the website, social media channels, call center, mobile applications and similar means. Your personal data can be created and updated as long as your relationship with SORWE continues and can be processed and kept in both digital and physical environments.

    Your personal data can be processed and transferred in line with the purposes stated in the third article below and within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law No. 6698.

    The legal basis for the processing of the Personal Data by SORWE is the "explicit consent" given by our users based on this disclosure text, our customers and SORWE’s legitimate interest provided that it does not harm the fundamental rights and freedoms of the users.

    3- Purposes of Processing Your Personal Data:
    Personal Data is obtained when using SORWE’s mobile, website, cookies and through direct answers to the questions during the use of the application,
    • - In order to fulfill the contract concluded between SORWE and your employer, while preserving the confidentiality of your identity information, unless you give your explicit consent,
    • - To carry out SORWE’S products and services by our relevant business unit for Real and /or legal third person institutions and organizations that have business relations with SORWE
    • - To conduct listing, reporting, verification analysis studies regarding the usage of the products and services offered by SORWE , to produce statistical and scientific information on this issue, to improve our products and services accordingly, to increase the satisfaction of our products and services and to make customizations for the user in this context
    • - To be able to make market research, promotion and necessary information about our products and services, to evaluate complaints and suggestions, and to contact you directly through communication channels shared with SORWE
    • - Supporting the execution of all Human Resources processes and policies of the EMPLOYER (data controller), who has signed a contract with SORWE,
    • - For SORWE and / or EMPLOYER (data controller)'s processes, and legal harmonization process of determining the business strategy, development and implementation,
    • - To enable SORWE’s accreditation and evaluation studies,
    • - Planning and management of financing and invoicing of all services offered by SORWE and / or EMPLOYER (data controller),
    • - Training and development of employees upon request by the EMPLOYER (data controller),
    • - Fulfilling participation requests to organizations , trainings, seminars, etc.,
    • - Carrying out risk management and quality improvement activities,
    • - Taking all necessary technical and administrative measures for the system and applications within the scope of data security
    Purposes and within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698.

    4- To Whom Processed Personal Data Can Be Transferred and For What Purpose
    Your personal data can be processed and transferred when necessary within the scope of the Personal Data Protection Law No.6698 ("KVKK") and the relevant legal legislation, the "General Principles of this" Disclosure Text "are limited to the purposes specified in article"3"titled "Purposes of Processing Your Personal Data " in accordance with the "Conditions for Processing of Personal Data" specified in Article 5 and the "Conditions for Processing Specially Qualified Personal Data" specified in Article 6 by SORWE and / or its subsidiaries and their subcontractors, legally authorized real and / or legal third person institutions and organizations, SORWE 's' business partners, subcontractors, suppliers, contracted or cooperating in any field to carry out their products and services, real and / or legal third person institutions and organizations residing in the country within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVK Law.

    5- Data processing time:
    Your personal data, limited to the purposes and legal basis specified in Article 3 of this Disclosure Text; it will be processed in accordance with the data processing and limitation periods specified in the legislation that SORWE is subject to and all other relevant laws and other legal regulations.

    If there is no legal regulation regarding the periods, this period is applied as ten (10) years from the date of the closure of the user account for any software created by SORWE.

    Regardless of whether you have a request after the end of this period; even if your personal data is matched with other data, all of the data that will make your identity specific or identifiable will be destroyed and made unrelated to you. In case of using your rights regulated by Article 6 of this disclosure text, your personal data will be anonymized by doing the same.

    In case of changes in the laws regarding data processing periods, the new terms will be taken as basis.

    6- Rights of Personal Data Owner based on Article 11 of KVKK
    Within the framework of Article 11 of the Law, without prejudice to the conditions stipulated in article 28 of KVKK titled "Exceptions", you can request the following from SORWE about your personal data;
    • a. Learning whether it has been processed,
    • b. Requesting information on this if it has been processed,
    • c. Learning the purpose of processing and whether it is used for stated purposes,
    • d. To know the third parties to whom they are transferred domestically or abroad,
    • e. To request correction if it is incomplete or incorrectly processed,
    • f. Requesting the deletion or destruction / destruction of your personal data within the framework of the conditions stipulated in Article 7 of the Law,
    • g. Request notification of the transactions made pursuant to subparagraphs (e) and (f) to third parties to whom personal data have been transferred,
    • h. Object to the emergence of a result against you because it is analysed exclusively with automatic systems,
    • i. In case you suffer damage due to unlawful processing, you have the right to demand the compensation of the damage.

    Applications can be made in writing or electronically, using the following methods, after filling the form on the Data Application Form

    In case of a written request;
    You can submit a wet signed copy of the Data Owner Application Form to SORWE with a ID document that identifies your profile or indicating that you are authorized to apply for the rights listed under Article 11 and by proxy with a notarized power of attorney, or through sending it by a notary to the address : "Campus Teknokent Arı 4 Building, Reşitpaşa Mahallesi, Katar Caddesi No: 2/50/6 Maslak / Sarıyer - İstanbul ”.

    Your requests submitted to SORWE will be answered in writing or electronically as soon as possible and within thirty days at the latest, in return for the transaction fee specified in the Article 7 of the Communiqué on the Principles and Procedures of Application to the Data Controller.