Privacy Policy

This Privacy Policy last modified on [5.November.2019]



This Privacy Policy describes how we, Turkey Key, collect, use, store, share and protect personal information collected from you in the course of providing our Services to you. Please read this Privacy Policy carefully before you use the Turkey Key’s website or submit any personal information to us.

By clicking "I accept" button or opening, accessing or using this Website, creating an account or otherwise using our Services you acknowledge that you have read and fully understood this Privacy Policy. If you do not agree with all or part of this Privacy Policy or if you do not have authority to bind yourself, then you shall not click "I accept" button and must refrain from opening, accessing or using this Website and any of our Services.

 


Definitions


“Account” means personal or business account on the Website, where you can edit your profile, submit your CV, announce for the job vacancies or be notified about them or publish real estate announcements and use other available options.


Data Protection Laws” mean Turkish Law on the Protection of Personal Data No. 6698 dated April 7, 2016, Directive 95/46/EC of the European Parliament and any regulations implementing such Directive, General Data Protection Regulation (GDPR) (EU) 2016/679 and any other laws, rules or regulations implementing requirements regarding the collections, storage, use, protection and/or security of Personal Data.


“Users” mean any users of our Website or any of our Services, regardless such person has an account within the Website or just views the Website.


“Personal Data” means any information relating to natural person, who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.


“Services” mean services of facilitating the skilled workers to find a job as well as businesses to find such workers, informational services for employers and employees provided by Turkey Key through its Website and ancillary services as may be provided by Turkey Key upon agreement with User.


“You”, “your”, “yours” refers to any User of the Turkey Key’s Services or the Website.


Turkey Key” means a business name of a [TURKEY KEY İÇ VE DIŞ TİCARET DANIŞMANLIK LİMİTED ŞİRKETİ], a legal entity registered in Turkey with its tax registration number [8710990496] and having its place of business at [ZİYA GÖKALP MAH. SÜLEYMAN DEMİREL BLV. MALL OF İSTANBUL OFİS NO: 7 E İÇ KAPI NO: 136 BAŞAKŞEHİR/ İSTANBUL]. Any references to Turkey Key shall refer to [TURKEY KEY İÇ VE DIŞ TİCARET DANIŞMANLIK LİMİTED ŞİRKETİ].


“We”, “Our” and “Us” refers to “Turkey Key”.


“Website” means current website https://turkeykey.com, including all its content.

 

Our Role in the protection of Personal Data

When you access the Website or create the Account within the Website, we collect your Personal Data, which means that we act as a data controller and you act as a data subject under applicable Data Protection Laws and we both have respective rights and obligations.

Being a data controller means we decide ‘why’ and ‘how’ your Personal Data should be processed. We have a great responsibility to protect your Personal Data and do our best to comply with requirements and restrictions in this regard.

 

Personal Data we may collect

When you create and access your Account the following types of User’s data may be gathered:

1.             Personal information, used for opening and managing of Account:

a)    First and last name

b)    Date, country and place of birth

c)    Gender

d)    Email address

e)    Current and previous job position

f)     Education

g)    Residential address

h)    Links of social media profiles

i)     Company's name

j)     Facial photographs

 

2.             Contact details used to maintain permanent communication with you, to send you information notices:

a)    First and last name

b)    Address

c)    Phone number

d)    Email address

 

Your contact data as mentioned above may be used for the purposes of the sending personalized offers of our Services (direct marketing). These communications may be via email or by SMS. You always have an option to unsubscribe from our promotional messages by managing settings in your Account, by contacting us directly or using instructions in the relevant e-mail or SMS.

 

3.             Device data (such as a type of device, operating system, web browser, IP-addresses and advertising ID’s, your approximate location, time zone, web and mobile network data), сookies and usage data on how you use our Website. It is used to ensure that the Website functions properly, to diagnose and respond to problems, to improve the use and performance of the Website and to safeguard you from fraud and misuse of your Personal Data. For more details about cookies please see the “Cookie and Tracking technology” section below.

4.             Information related to you provided by third parties like services for marketing agencies or your publicly available profile information (LinkedIn, Facebook, Twitter, Google Accounts etc.).

5.             Any images, videos, texts and other Users’ content, including without limitations logos or other designs designed by designers, company pictures, pictures of factory machines, indoor or outdoor pictures of a company

Please be aware that the list of information types mentioned above is not exhaustive and we reserve the right to collect additional information about you in some other ways, for example by your contacting our customer support or taking part in surveys, etc.

We warrant you that we do not collect any extra data but only that information that is necessary for the purpose of providing you with high-quality services.

 

Sensitive Personal Data

Sensitive Personal Data is data, which requires special treatment in accordance with the Data Protection Laws. We do not intentionally collect any sensitive personal data, such as your biometric data, religious beliefs, health information, racial or ethnic origin etc. We do not intentionally collect any other sensitive Personal Data. Nevertheless, there might be cases when information or documents data subject submits to us contain sensitive information or we can obtain it in the course of providing our Services. Depending on such data purpose we may delete it or to request you to provide explicit consent to process your sensitive Personal Data by e-mail. Such information may be processed only by your consent or if it is not prohibited by Data Protection Laws.[M.K.1] 

Turkey Key uses all required technologies and measures to protect sensitive Personal Data. We use data encryption protection system, physical authorization control system, Data access control technologies and much more.

In some cases, your facial images also can be considered by legislation as sensitive Personal Data. When you submit your facial images you may be required to provide your explicit consent for the processing of it for the purpose of providing our Services for You. You have the right to not submit your photos or delete your photos or withdraw your consent at any time by using Account options or by contacting us directly.

You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services, including helping recruiters and business opportunities find you. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.

 

How we may use your Personal Data

We may use your Personal Data:

1.     For opening and managing your Account with us, to administer our Services. Such Personal Data may include first and last name, date, country and place of birth, gender, names, roles, and contact details of your officers.

2.