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.     To keep communication with you; to respond to your inquiries and fulfil your requests; to send to you administrative information, including information regarding the services and changes to our terms, conditions and policies; to send to you marketing communications that we believe may be of interest to you, unless you opt-out in accordance with the "Legal basis” section below. For instance: e-mail, phone number, names of contact persons.

3.     To comply with legal requirements, to respond to requests from public or government authorities, including public or government authorities outside your country of residence.

4.     To improve our services, to safeguard you from the scam, fraud, and misuse of your Personal Data, to carry out a quality assessment, data analysis, audits, developing new products. For instance: device data, cookies, publicly available information from your social networks.

 

Your Personal Data is not used for any additional purposes not mentioned in this Privacy Policy. You may contact us to find out details on how your Personal Data is processed.

 

How we can share your Personal Data

Your Personal Data may be shared:

1.     To our third-party service providers that may provide services such as employment agencies, hosting of our Website, data analysis, IT services and infrastructure, customer support service, e-mail delivery, auditing, payment processing and other services. We contractually oblige our third-party service providers to keep the information confidential and secure.

2.     To other Users. In case of personal account – to potential employers, and in case of business account – to potential employees and Users looking for job opportunities. You have the right to manage your profile information make it publicly available or hide it.

3.     By you, through messages (including files, video and audio calls and text messages), chats, message boards, forums, public profile pages, user directories and blogs and other functionality with which you are able to share or post information and materials. Please note that any information and materials that you post or disclose using such functionality will become public information, and may be available for other users of the services and the general public to record, access, use, alter, manipulate or disclose to other individuals or social networking sites such as Facebook or LinkedIn. We are not responsible for such recording, access, use, alteration, manipulation or disclosure. We urge you to be very careful when deciding to disclose your Personal Data.

4.     To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding).

5.     To our professional advisers (such as lawyers, accountants, auditors, it consultants, management consultants), who is under a professional obligation to maintain confidentiality and security of Personal Data.

6.     To court or government bodies with the purpose to comply with applicable laws, regulations, instructions.

We may produce anonymous and grouped analytics and reports, which we may share publicly. Please be aware that in such a case the data will cease to be Personal Data and is not a subject of the obligations set in this Privacy Policy.

 

Cross-border data transfers

We can engage the third-party service providers outside the Turkey. Data protection law of third countries may be different from Turkey or EU data protection laws and not guaranty adequate level of security. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that personal data remains protected.

Also we rely on the EU-US Privacy Shield to transfer personal information to some of our third-party service providers in the United States, where they are certified to receive such information under the Privacy Shield Program.

 

Where and how long we store your data

 

All Personal Data collected from you is stored on secured cloud servers and is protected using data masking and encryption techniques. Every part of our system has a multiple redundancy, backups are made systematically and stored for a rolling 30 days period.

Your Personal Data may be used for as long as reasonably necessary for the providing of our Services to you. You may request deletion of your data if you decide to terminate the work with us. We will consider and fulfil your request within 30 days.

Please be aware that we may be obliged to keep store your data, regardless of your deletion request, to comply with anti-money laundering requirements, tax reporting or auditing or if otherwise required by law. In such a case we will protect the confidentiality of your Personal Data and will not actively process it.

Your Personal Data processed for the purposes of direct marketing are used as long as you have Account with us or until you unsubscribe from receiving such messages using the link in the bottom of the e-mail or by using the functionality of the Website.

 

Age Restrictions

We do not intentionally collect, use or disclose Personal Data of persons under 18 or younger than equivalent minimum age in your jurisdiction. Turkey Key’s Services are not designed to attract minors. If you are under the age of 18 (or the relevant minimum age in your jurisdiction), you must not submit any Personal Data to us or subscribe for our Services. If we become aware that we have obtained the Personal Data of a minor, we will delete it as soon as possible without prior notification.

Your rights in regards to Personal Data

You, as a data subject, have the following rights:

•           to know what your Personal Data we process and in what way;

•           to ask us to erase or delete all or some of your Personal Data. Note that not all Personal Data may be deleted due to security or legal reasons. Also, you must complete the authentication procedure you before we can fulfil your request.

•           to ask us to change, update or fix your Personal Data if it is inaccurate.

•           to ask us to provide a copy of your Personal Data we keep unless this adversely affects the rights and freedoms of other users.

•           to object the usage of Personal Data for direct marketing purposes;

•           and other rights established in Data Protection Laws.

When making a request to us you should specify your name, surname, contact details, relevant information, which would indicate why you believe that your Personal Data must be deleted, changed or it’s processing be limited. After examining your request, we will report the results within a reasonable time and, if the decision is positive, state the actions were taken to satisfy your request.

 

Feel free to contact us to make a complaint, the request or query about realization of your rights using the contact information in the “Contact Us” section below.

 

Legal basis

Processing of Personal Data is permitted only under the several legal bases described by Data Protection Laws.

By providing you with our Services, we process your Personal Data based on:

1.    Contract: We can process personal data to fulfil our contractual obligations with you.

2.     Legitimate interest: We can rely on this legal basis when we carry out procedures which are the part of our Services or which are transparent, expectable and are the stable business practice, including without limitations the direct marketing. We can send you information or promotion on products and services that we offer that is similar to and related to our Services. If you do not want to receive a direct marketing message from us, you can opt out at any time by changing settings of your Account, clicking on the respective link in each e-mail, or message you received, or by contacting us.

3.     Consent: We can request from our Users or partners a consent for processing when we process the sensitive Personal Data or if otherwise required by law. It includes some cases when we process your facial images or use cookies or similar technologies. Where we rely on your consent to process your Personal Data, you have the right to withdraw or decline your consent at any time using the Website functionality or contact us directly.

 

This list is not exhaustive and we may use other ground provided by Data Protection Laws if none of the above-mentioned basis can be applied.

 

Cookie and Tracking technology

Our Website may use cookie and tracking technology depending on the features offered. Cookie and tracking technology are useful for gathering information such as browser type and operating system, tracking the number of visitors to the Website, and understanding how visitors use the Website. Cookies can also help customize the Website for visitors. Personal Data cannot be collected via cookies and other tracking technology; however, if you previously provided personally identifiable information, cookies may be tied to such information. Aggregate cookie and tracking information may be shared with third parties.

Any data that we collect and store through the use of cookies is first obtained through notice and consent. We obtain your consent by providing you with transparent notice of the use of the cookies and, to the extent described herein, providing you with the opportunity to make a choice to disable these cookies, except the session cookies. We offer certain Website features and services that are available only through the use of the cookies. You are always free to block, delete, or disable cookies if your browser, installed application, or device so permits. However, if you decline cookies or other similar technologies, you may not be able to take advantage of certain site features or Services.

You can learn more about cookies from https://www.aboutcookies.org/.

Third-party advertisers

We may use third-party advertising companies to serve ads when you visit our Website or use our Services. Please note that these companies may use information about your use of the Services to provide advertisements about goods and Services that may be of interest to you. In the course of serving advertisements to the services, these companies may place or recognize a unique cookie on your browser. Upon you have accepted the use of cookies on our Website, we may use Google Analytics. Google Analytics is third-party technology, which allows collecting and analysing information about how you use our Website and creating relevant reports. you can at any time opt-out through google ads settings. Google also provides a google analytics opt-out plug-in for the web.

 

Security measures

We seek to use within Turkey Key reasonable organizational, technical and administrative measures to protect Personal Data under our control. To keep your Personal Data safe we apply:

·         Firewall and data encryption protection

·         Securing data processing equipment and personal computers

·         User identification and authentication procedures

·         Tunnelling, logging, transport security

·         Audit trails and documentation

·         Backup procedures,

·         And more.

Unfortunately, no data transmission over the Internet is guaranteed to be 100% secure. Please also be aware that we are not responsible for the data security measures of any third parties.

 

Customer Responsibilities

Please note that when you submit any content to us, including your photos, videos or text, you remain the owner of such content. This means that you are responsible for its accuracy, quality and legality.

You are responsible for all content posted and activity that occurs under your Account.

You shall (i) use reasonable efforts to prevent unauthorized access to your Account, and notify Turkey Key immediately of any such unauthorized access or use, and (ii) use the Website only in accordance with Turkey Key instructions and all applicable laws and government regulations (iii) not use the Website or Account to store or transmit libellous, infringing or otherwise unlawful or tortious material, or to store or transmit material in violations of third-party privacy rights, (iv) use the Website or Account to store or transmit viruses, worms, time bombs, Trojan horses, or other harmful or malicious code, files, scripts, agents, or programs, (v) not violate any intellectual property rights of any third party, including but not limited to, Turkey Key trademarks, copyrights, patents, etc.We have the right to remove any posting you make on our Website if, in our opinion, your content violates this Privacy Policy or applicable law.

By submitting your contents to us you give us a worldwide license to use, host, store, reproduce, communicate, publish, publicly perform and publicly display such content.

After you upload any contents to your Account other Users will be able to find and see your publicly-shared content, including your name (and photo if you have provided one).

You may manage the sharing or visibility settings in your Account at any time. For example, you can choose not to show your photos, videos or other content to other Users.

 

Password Policy

You shall maintain the confidentiality of password and login from your Account. We recommend you to sign out of the Account when you have finished work with it. Your email address or phone number may be used to reset a forgotten password of your Account. Please contact us if you suspect that the security of your Account has been compromised. Nevertheless please keep in mind that you bear responsibility for any loss of passwords and misuse of your Account.

 

Direct Marketing

We may send you personalized offers of services and products or information or promotion on products related our Services. We give you several options to limit using your Personal Data for marketing purposes. you may opt-out from receiving marketing-related e-mails from us based upon your Personal Data, by accessing the notification settings in your Account, or by clicking the "unsubscribe" link that is included at the end of such marketing-related e-mails. Also you have an option to contact us in accordance with the "Contacting us" section below to stop receiving marketing-related e-mails.

Please also note that you cannot opt-out from receiving administrative messages.

 

Changes to this Privacy Policy

We can make amendments to this Privacy Policy at any time by the means of publishing a revised edition on our Website. The revised version will be in effect immediately upon publishing and be noted by updated date in the end of this Privacy Policy.You agree that it is your responsibility to monitor changes to our Privacy Policy.  You are entitled to terminate our Services if you do not agree on any changes. By continuing using our Services and Website, you accept the changes.

 

Contact us

 

If you have any questions about this Privacy Policy, please contact us by sending an e-mail to [email protected]. Please note that information you submit through e-mail may not be secure; so please do not include your Personal Data in your messages to us.

 

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