1. Purpose of the Clarification Text and Our Company's Data Controller Identity
Pursuant to the Personal Data Protection Law No. 6698 ("Law"), as Figaro Bilişim A.Ş. ("WorkPark" and "Company"), the processing and protection of personal data in accordance with the law is among our top priorities.
Within the framework of Article 10 titled "Disclosure Obligation of the Data Controller" and Article 11 titled " Rights of the Data Subject" regulated in the KVKK ; We hereby submit this Clarification Text ("Clarification Text") to your information in order to inform and enlighten you regarding the purpose for which your personal data will be processed, to whom and for what purpose your processed personal data can be transferred , the method and legal reason for collecting your personal data and your other rights listed in Article 11 of the KVKK.
Data Controller, Istanbul Trade Registry, company headquarters Sanayi Mah. Teknopark Blv. Teknopark Istanbul Pendik Istanbul / Turkey.
2. Purposes of Processing Personal Data
2.1 Carrying out the necessary work by the relevant units and carrying out business processes in order to benefit the relevant persons from the products and services offered by WorkPark :
- Planning and execution of sales processes of products and/or services,
- Planning and/or execution of after-sales support services activities,
- Planning and execution of customer relationship management processes,
- Follow-up of contract processes and/or legal requests,
- Follow-up of customer requests and/or complaints.
2.2 Planning and execution of WorkPark human resources policies and processes:
- Planning and execution of talent and career development activities,
- Fulfillment of obligations arising from employment contracts and/or legislation for company employees,
- Planning and execution of employee benefits and perks,
- Planning and execution of internal compliance activities,
- Planning and execution of employee exit procedures,
- Wage management,
- Planning human resources processes,
- Managing recruitment processes,
- Planning and executing appointment-promotion and termination processes for the company,
- Planning and execution of employee performance evaluation processes,
- Follow-up and/or supervision of employee work activities,
- Planning and/or execution of in-company training activities,
- Planning and execution of employee satisfaction and/or loyalty processes,
- Planning and execution of the processes of receiving and evaluating employee suggestions for the improvement of work and/or production processes,
- Planning and/or execution of the recruitment, placement and operation processes of interns and/or students.
2.3 Carrying out the necessary work by the relevant business units for the realization of the commercial activities carried out by WorkPark and carrying out the related business processes:
- Event management,
- Planning and execution of business activities,
- Planning and execution of corporate communication activities,
- Planning and execution of supply chain management processes,
- Planning and execution of production and/or operation processes,
- Planning, auditing and execution of information security processes,
- Establishing and managing the information technology infrastructure,
- Planning and executing the authorizations of business partners to access information,
- Finance and/or accounting affairs,
- Planning and executing corporate sustainability activities,
- Planning and execution of corporate governance activities,
- Planning and/or execution of business continuity activities,
- Planning and execution of logistics activities.
2.4 Planning and execution of the activities required to recommend and promote the products and services offered by WorkPark to the relevant persons by customizing them according to their tastes, usage habits and needs:
- Determination and/or evaluation of the persons to be subject to marketing activities in line with consumer behavior,
- Design and/or execution of personalized marketing and/or promotion activities,
- Designing and/or executing advertising and/or promotion and/or marketing activities in digital and/or other media,
- Designing and/or executing activities to be developed on customer acquisition and/or value creation in existing customers in digital and/or other media,
- Planning and/or executing data analytics studies for marketing purposes,
- Planning and execution of the marketing processes of products and/or services,
- Planning and/or execution of the processes of creating and/or increasing loyalty to the products and/or services offered by the company.
2.5 Planning and execution of WorkPark's commercial and/or business strategies:
Managing relationships with business partners.
2. 6 Ensuring the legal, technical and commercial business security of WorkPark and related persons in business relationship with WorkPark:
- Pursuit of legal affairs,
- Planning and execution of operational activities necessary to ensure that company activities are carried out in accordance with company procedures and/or relevant legislation,
- Providing information to authorized institutions arising from legislation,
- Creating and following up visitor records,
- Planning and executing emergency management processes,
- Performing company and partnership law transactions,
- Planning and performing company audit activities,
- Planning and/or performing occupational health and/or safety processes,
- Performing risk management of credit processes,
- Ensuring the security of company premises and/or facilities,
- Securing the security of company operations,
- Planning and/or executing the company's financial risk processes,
- Securing the security of company fixtures and/or resources.
3. Categories of Personal Data
WorkPark me processes the personal data listed in accordance with the personal data processing conditions set out in the Law and the relevant legislation:
- Identity information: Information contained in documents such as driver's license, identity card, residence, passport, lawyer ID, marriage certificate.
- Contact information: Information used to contact the person (e.g. e-mail address, telephone number, mobile phone number, address).
- Location information: Information used to determine the location of the data subject (e.g. location information obtained while driving).
- Customer transaction information: Information relating to any transaction carried out by customers using our products and services.
- Physical location security information: Personal data related to records and documents such as camera records, fingerprint records, etc. taken at the entrance to the physical space, during the stay in the physical space
- Transaction security information: Personal data processed to ensure technical, administrative, legal and commercial security while WorkPark conducts its business activities.
- Financial information: Personal data processed regarding information, documents and records showing all kinds of financial results created according to the type of legal relationship WorkPark has established with the personal data subject.
- Employee candidate information: Personal data processed in relation to individuals who have applied to become an employee of WorkPark or who have been evaluated as an employee candidate in line with human resources needs in accordance with commercial customs and honesty rules or who are in a working relationship with WorkPark.
- Legal transaction and compliance information: Personal data processed within the scope of determination, follow-up and fulfillment of WorkPark's legal receivables and rights, and compliance with legal obligations and company policies.
- Audit and inspection information: Personal data processed within the scope of WorkPark's legal obligations and compliance with company policies.
- Special quality data: Personal data relating to race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, appearance and dress, membership of associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data.
- Marketing information: Personal data processed for the marketing of the products and services offered by WorkPark by customizing them in line with the usage habits, tastes and needs of the personal data owner, and the reports and evaluations created as a result of this processing.
- Request/complaint management information: Personal data relating to the receipt and evaluation of any request or complaint addressed to WorkPark.
- Reputation management information: Information collected for the purpose of protecting WorkPark's commercial reputation and information about the evaluation reports and actions taken.
- Incident management information: Personal data processed for the purpose of taking necessary legal, technical and administrative measures against events that develop in order to protect the commercial rights and interests of WorkPark and the rights and interests of its customers.
Principles and Conditions Regarding the Processing of Personal Data
WorkPark, in accordance with Article 4 of the Law. In accordance with Article 4 of the Law, WorkPark carries out personal data processing activities in a limited and measured manner in accordance with the law and good faith, accurate and, where necessary, up-to-date, for specific, clear and legitimate purposes, in connection with the purpose. WorkPark retains personal data for the period stipulated by law or required by the purpose of personal data processing.
4.1 Principles Regarding the Processing of Personal Data
WorkPark informs data subjects in accordance with Article 10 of the KVK Law. In accordance with Article 10 of the KVK Law, WorkPark informs the data subjects and processes this personal data based on the following principles by requesting the consent of the data subjects in cases where consent is required.
4.1.1.1 Processing of Data in Compliance with the Law and the Rule of Good Faith
WorkPark acts in accordance with the principles introduced by legal regulations and the general rule of trust and good faith in the processing of personal data. In accordance with the principle of good faith, WorkPark takes into account the interests and reasonable expectations of the data subjects while trying to achieve its data processing objectives.
4.1.2 Ensuring that Personal Data is Accurate and Up-to-Date When Necessary
Keeping personal data accurate and up-to-date is necessary for WorkPark to protect the fundamental rights and freedoms of the data subject. WorkPark has an active duty of care to ensure that personal data is accurate and up-to-date when necessary. For this reason, all communication channels are open for WorkPark to keep the information of the data subject accurate and up-to-date.
4.1.3 Processing of Data for Specific, Explicit and Legitimate Purposes
WorkPark clearly and precisely determines the legitimate and lawful purpose of processing personal data. It processes personal data in connection with and necessary for the commercial activity it conducts.
4.1.4 Data Being Relevant, Limited and Proportionate to the Purpose of Processing
WorkPark processes personal data for the purposes related to the relevant subject and necessary for the conduct of its business. For this reason, it processes personal data in a manner that enables the realization of the specified purposes and avoids the processing of personal data that is not related to the realization of the purpose or is not needed.
4.1.5 Retention of Personal Data for the Period Stipulated in the Relevant Legislation or Required for the Purpose for which they are Processed
WorkPark retains personal data only for the period specified in the relevant legislation or required for the purpose for which they are processed. In this context; first of all, it determines whether a period of time is stipulated for the storage of personal data in the relevant legislation, if a period is determined, it acts in accordance with this period, and if a period is not determined, it keeps personal data for the period required for the purpose for which they are processed. Personal data are deleted, destroyed or anonymized by WorkPark after the purpose of personal data processing ceases to exist or the period stipulated in the legislation expires.
4.2 Conditions for Processing Personal Data
The personal data processing conditions set out in Article 5 of the Law. Your personal data is processed by WorkPark in the presence of at least one of the personal data processing conditions in Article 5 of the Law.
4.2.1 Explicit consent of the personal data owner
One of the conditions for processing personal data is the explicit consent of the owner. The explicit consent of the personal data subject must be related to a specific subject, based on information and free will.
In order to process personal data based on the explicit consent of the personal data owner, explicit consent is obtained from customers, potential customers and visitors through relevant methods.
4.2.2 Personal data processing activities are expressly provided for in the law
The personal data of the data subject may be processed in accordance with the law without the explicit consent of the data subject, if expressly provided for in the law.
4.2.3 Failure to obtain the explicit consent of the person due to actual impossibility
The personal data of the data subject may be processed if it is necessary to process the personal data of the person who is unable to disclose his/her consent due to actual impossibility or whose consent will not be recognized as valid, in order to protect his/her or another person's life or physical integrity.
4.2.4 The personal data is directly related to the conclusion or performance of a contract
Personal data may be processed if it is necessary to process personal data of the parties to the contract, provided that it is directly related to the conclusion or performance of a contract.
4.2.5 Fulfillment of WorkPark's legal obligations
The personal data of the data subject may be processed if the processing is necessary for WorkPark to fulfill its legal obligations as a data controller.
4.2.6 Publicization of the personal data of the data subject
The personal data of the data subject may be processed if the personal data of the data subject has been made public by the data subject.
4.2.7 Data processing is mandatory for the establishment or protection of a right
The personal data of the data subject may be processed if data processing is mandatory for the establishment, exercise or protection of a right.
4.2.8 Data processing is mandatory for the legitimate interests of WorkPark
Provided that it does not harm the fundamental rights and freedoms of the personal data owner, the personal data of the data owner may be processed if data processing is mandatory for the legitimate interests of WorkPark.
4.3 Processing of Special Categories of Personal Data
WorkPark acts sensitively and in compliance with the regulations stipulated in the KVK Law in the processing of personal data determined as "special categories" by the KVK Law.
WorkPark processes personal data of special nature in the following cases, provided that adequate measures to be determined by the PDP Board are taken:
- If the personal data owner has explicit consent or
- If the personal data owner does not have explicit consent;
- Special categories of personal data other than the health and sexual life of the personal data owner, in cases stipulated by law,
- Sensitive personal data relating to the health and sexual life of the personal data owner are processed only by persons or authorized institutions and organizations under the obligation of confidentiality for the purposes of protecting public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing.
5. Transfer of Your Personal Data
WorkPark may transfer the personal data and special categories of personal data of the data subject to domestic or foreign third parties by taking the necessary security measures in line with the lawful personal data processing purposes . In this respect, WorkPark acts in accordance with the regulations stipulated in Article 8 of the KVK Law .
Your personal data;
- To lawyers, auditors, tax consultants and other third parties from whom we receive consultancy and services; to carry out our business processes in accordance with the law and our legitimate interests, to exercise our right of defense in a possible judicial process,
- To your attorneys and representatives authorized by you; to fulfill our legal obligations,
- Regulatory and supervisory institutions and other official institutions such as courts and enforcement offices and other public institutions or organizations authorized to request your personal data; to fulfill our legal obligations,
- Our business partners from whom we receive services, to improve our services to our performance assistants, to improve infrastructure and security processes, and within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVKK. and 9 of the KVKK within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVKK.
6. Rights of the Data Owner and Exercise of Related Rights
6. 1 Rights of the personal data subject:
- Learning whether his/her personal data are processed,
- Requesting information if his/her personal data are processed,
- Learning the purpose of processing personal data and whether they are used in accordance with their purpose,
- To know the third parties to whom personal data are transferred at home or abroad,
- To request correction of personal data in case of incomplete or incorrect processing and to request notification of the transaction made within this scope to third parties to whom personal data are transferred,
- Requesting the deletion or destruction of personal data in the event that the reasons requiring its processing disappear, although it has been processed in accordance with the provisions of the KVK Law and other relevant laws, and requesting that the transaction made within this scope be notified to third parties to whom personal data is transferred,
- If a result occurs against the person himself/herself by analyzing the processed data exclusively through automated systems, to object to this result,
- In case of damage due to unlawful processing of personal data, to demand the compensation of the damage.
If personal data is not obtained directly from the data subject;
WorkPark may,
1) Within a reasonable period of time from the acquisition of personal data,
2) In the event that personal data will be used for communication purposes with the data subject,
3) During initial contact,
4) In the event that personal data will be transferred, activities are carried out to inform data subjects at the latest during the first transfer of personal data.
Pursuant to Article 28.2 of the KVK Law; In the cases listed below, personal data owners cannot assert their other rights listed in Article 5.1, except for the right to claim compensation for the damage:
In accordance with Article 28.2 of the KVK LawThey cannot assert their other rights listed in 1:
- Personal data processing is necessary for the prevention of crime or criminal investigation,
- Processing of personal data made public by the personal data owner himself/herself,
- Personal data processing is necessary for the execution of supervisory or regulatory duties and disciplinary investigation or prosecution by authorized public institutions and organizations and professional organizations in the nature of public institutions, based on the authority granted by law,
- Personal data processing is necessary for the protection of the economic and financial interests of the State regarding budget, tax and financial issues. Deletion, Destruction, Anonymization of Personal Data
7. As regulated in Article 138 of the Turkish Penal Code and Article 7 of the KVK Law, personal data shall be deleted, destroyed or anonymized upon the decision of WorkPark or upon the request of the personal data owner, in the event that the reasons requiring its processing disappear, although it has been processed in accordance with the provisions of the relevant law . In this context, WorkPark has taken the necessary technical and administrative
measures within the company in order to fulfill its relevant obligation ; has developed the necessary operating mechanisms in this regard; It trains,
assigns and raises awareness of the relevant business units to act in accordance with these obligations .
Contact Us!
Contact us to convey all your questions, suggestions and opinions regarding the Personal Data Protection Policy!
Your application will be answered in accordance with the relevant provisions stipulated in the KVKK and
WorkPark may request some verifying information from you in order to confirm that the applicant is the relevant person ; this information will only be requested in order to identify the identity of the relevant person and to share the results of the application with the right person.
E-Mail: info@workpark.app
Contact Address: Küçükbakkalköy Mh. Işıklar Cd. No:30 Ataşehir Istanbul - Turkey
Phone Number: 444 1 823
This information letter has been prepared to fulfill the disclosure obligation pursuant to Article 10 of the KVKK.
Figaro Bilişim A.Ş.