CLARIFICATION TEXT REGARDING THE PROTECTION OF PERSONAL DATA

  1. IDENTITY OF THE DATA CONTROLLER:

Clockwork Bilgi Teknolojileri Anonim Sirketi (“Clockwork”) has the capacity of data controller under the Personal Data Protection Law (“the Law”). We, as Clockwork, attach great importance to the protection of your personal data. Within this framework, this Clarification Text regarding the Protection of Personal Data (“Clarification Text”), which we prepared under the Communique on Principles and Procedures to be applied in the Fulfillment of the Law and the Clarification Obligation   (“Communique”) is submitted to the attention of our users and third persons using our website.

Clockwork takes the necessary measures in order to assure the proper level of security for the purpose of preventing the use of your personal data in contrary to the law and ensuring the protection of your personal data within the course of processing pursuant to the legislation.

  1. METHOD OF COLLECTING YOUR PERSONAL DATA:

Your personal data is collected in written or in electronic environment via our website and cookies.

Clockwork uses cookies in order to provide its services and ensure the compliance of the content with the requirements and interests.

  1. PERSONAL DATA CATEGORIES:

Your Identity Details: Name, surname, information set forth in the curriculum vitae

Your Contact Details: e-mail, mobile phone number

Your Location Data: Location details

Your Process Security Data: IP Address, traffic data, website/mobile application login/logout details

Your Risk Management Data: IP address

Your Professional Experience Data: Educations received, certificates, foreign language knowledge, references, technical information, information set forth in the curriculum vitae

  1. PURPOSES AND LEGAL REASONS FOR PROCESSING YOUR PERSONAL DATA:

We kindly submit for your information the details regarding for which purposes and based on which legal reasons we process your personal data: 

  1. Capacity of contacting with the users for carrier purpose

Personal Data Processed: Identity, Communication, Location, Process Security Data, Risk Management Data, Professional Experience Data 

Legal Reasons:

  1. It is expressly stipulated by the Laws,
  2. Processing of the personal data belonging to the parties to the contract is required provided that it is directly related to the execution or performance of the contract,
  3. It is mandatory for the fulfillment of the legal obligations by the data controller,
  4. Processing of data is mandatory for the establishment, exercise or protection of any right and
  5. Obligation to process data for the legitimate interests of the data controller provided that it will not prejudice to the fundamental rights and freedoms of the relevant person,
  6. Explicit consent
  1. Issuance of all records and documents to be based on process in electronic environment (internet/mobile etc.) or as hard copy

Personal Data Processed: Identity, Communication, Location, Process Security Data, Risk Management Data, Professional Experience Data

Legal Reasons:

  1. It is expressly stipulated by the Laws,
  2. Processing of the personal data belonging to the parties to the contract is required provided that it is directly related to the execution or performance of the contract,
  3. It is mandatory for the fulfillment of the legal obligations by the data controller,
  4. Processing of data is mandatory for the establishment, exercise or protection of any right and
  5. Obligation to process data for the legitimate interests of the data controller provided that it will not prejudice to the fundamental rights and freedoms of the relevant person,
  6. Explicit consent
  1. Responding to the information requests from the competent authorities

Personal Data Processed: Identity, Communication, Location, Process Security Data, Risk Management Data, Professional Experience Data

Legal Reasons:

  1. It is expressly stipulated by the Laws,
  2. It is mandatory for the fulfillment of the legal obligations by the data controller
  3. Processing of data is mandatory for the establishment, exercise or protection of any right and
  4. Obligation to process data for the legitimate interests of the data controller provided that it will not prejudice to the fundamental rights and freedoms of the relevant person,
  5. Explicit consent
  1. Ensuring the information and process security

Personal Data Processed: Identity, Communication, Location, Process Security Data, Risk Management Data, Professional Experience Data

Legal Reasons:

  1. It is expressly stipulated by the Laws,
  2. Processing of the personal data belonging to the parties to the contract is required provided that it is directly related to the execution or performance of the contract,
  3. It is mandatory for the fulfillment of the legal obligations by the data controller,
  4. Processing of data is mandatory for the establishment, exercise or protection of any right and
  5. Obligation to process data for the legitimate interests of the data controller provided that it will not prejudice to the fundamental rights and freedoms of the relevant person.
  1. Following up and executing the legal affairs

Personal Data Processed: Identity, Communication, Location, Process Security Data, Risk Management Data, Professional Experience Data

Legal Reasons:

  1. It is expressly stipulated by the Laws,
  2. Processing of the personal data belonging to the parties to the contract is required provided that it is directly related to the execution or performance of the contract,
  3. It is mandatory for the fulfillment of the legal obligations by the data controller,
  4. Processing of data is mandatory for the establishment, exercise or protection of any right and
  5. Obligation to process data for the legitimate interests of the data controller provided that it will not prejudice to the fundamental rights and freedoms of the relevant person
  1. Fulfillment of our legal obligations and capacity of exercising our rights arising from the legislation in force

Personal Data Processed: Identity, Communication, Location, Process Security Data, Risk Management Data, Professional Experience Data

Legal Reasons:

  1. It is expressly stipulated by the Laws,
  2. Processing of the personal data belonging to the parties to the contract is required provided that it is directly related to the execution or performance of the contract,
  3. It is mandatory for the fulfillment of the legal obligations by the data controller,
  4. Processing of data is mandatory for the establishment, exercise or protection of any right and
  5. Obligation to process data for the legitimate interests of the data controller provided that it will not prejudice to the fundamental rights and freedoms of the relevant person
  1. PARTIES TO WHOM YOUR PERSONAL DATA IS TRANSFERRED AND PURPOSES OF TRANSFER

Your personal data can be transferred to the receivers in the country and in both in compliance with the Law for the purpose of achieving the purposes stated below:

  • to relevant persons for the purpose of responding to the carrier applications of the users
  • to various third persons residing in the country and in abroad within the scope of the marketing activities in order to improve the user experience and ensure the user satisfaction
  • to the service provider companies in order to provide the statistical and technical services
  • to the shareholders, executives and affiliates of Clockwork for the purpose of executing the corporate management processes and the statistical working and reporting processes
  • to the corporations which are the partners of the program and the social networking sites located in the country and in abroad and with which we cooperate in order to carry out our operations and business development processes
  • to our business partners residing in the country and in abroad and from whom we purchase the service for the storage of the personal data in the cloud environment
  • to the service provider companies located in the country and in abroad and from which technological infrastructure, server service, e-mail service and cookie service are purchased for the website
  • to the audit companies, lawyers, authorized institutions and organizations for the purpose of fulfilling our legal obligations
  1. RIGHTS OF THE RELEVANT PERSON

The users can forward their requests under the article 11, “regulating the rights of the relevant person”, of the PDPL to the address of [[email protected]].

If you forward your requests to Clockwork, Clockwork shall conclude your request within no later than 30 (thirty) days as free of charge. However, if any separate cost arises, Clockwork reserves the right to claim fee from you according to the tariff to be determined by the Personal Data Protection Board.

Furthermore, you can contact with us at any time via the e-mail address [[email protected]] for all kind of your queries and opinions related to your personal data.

  1. AMENDMENTS TO BE MADE IN THE CLARIFICATION TEXT WITH REGARD TO THE PROTECTION OF THE PERSONAL DATA:

Clockwork reserves the right to update this Clarification Text at any and all times. The amendments to be made by Clockwork shall become valid immediately upon the publication of the Clarification Text at the website.