GDPR Policy

Eksedra (HRPeak)
PRIVACY NOTICE UNDER THE PERSONAL DATA PROTECTION LAW
Eksedra Information Technology Solutions (Eksedra) (HRPeak) demonstrates the same level of care and discipline in protecting personal data as it does in its business operations. In this regard, Eksedra Information Technology Solutions (HRPeak) collects, stores, and, when necessary, deletes personal data in full compliance with Article 20 of the Constitution, the Personal Data Protection Law No. 6698, and all general and specific legislation—including secondary regulations and circulars—governing personal data. Pursuant to Law No. 6698, Eksedra Information Systems (HRPeak) acts as the “Data Controller” in accordance with the guidelines set forth in the law and relevant regulations.

DEFINITIONS AND EXPLANATIONS:

• Personal data: Any information relating to an identified or identifiable natural person,
• Processing of Personal Data: Any operation performed on personal data, such as the collection, recording, storage, retention, alteration, reorganization, disclosure, transfer, acquisition, making available, classification, or restriction of use of such data—whether fully or partially automated or carried out by non-automated means as part of a data filing system—
• Authority : The Personal Data Protection Authority,
• Data processor: A natural or legal person who processes personal data on behalf of the data controller based on the authority granted by the data controller,
• Data recording system: A recording system in which personal data is processed according to specific criteria,
• Data controller: A natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data filing system,
• Recruitment and Placement Consulting: These are assessment systems designed to provide employers with suitable candidates for open positions.
• Personality Inventory Test – PiT®: This test, consisting of 80 questions, assesses 20 different traits related to professional life. It also determines which position the candidate is best suited for.

• HRWin – Smart Video Interview App: Candidates undergo a preliminary screening process using question sets tailored to the specific position and organization. It enables online assessment of candidates in remote locations without any geographical restrictions.
• Tests and Exams: C# and SQL adaptive exams include both multiple-choice questions and questions requiring candidates to write code manually. In addition, general knowledge and general aptitude tests are administered to candidates in accordance with Eksedran’s (HRPeak’s) requirements.

1-EKSEDRA (HRPeak) AS THE DATA CONTROLLER
Eksedra (HRPeak) operates from its headquarters at Emaar Square Plaza, 32nd Floor, Suite 3201, Üsküdar, Istanbul. As specified by law, Eksedra (HRPeak) is the “Data Controller.”

2- REASONS FOR COLLECTING PERSONAL DATA BY EKSEDRA (HRPeak)
The data controller is the company;

• Job creation,
• Managing the hiring process for partner organizations with which it has agreements, providing support, or preparing the necessary infrastructure,
• Providing services as an online career site,
• Evaluating personal resumes uploaded by users and forwarding them to suitable employers,
• By administering the assessment tests, aptitude tests, and language exams it has designed, to ensure that candidates are placed in the most suitable positions,
• Transferring the data of relevant candidates who have submitted their resumes to the organization to the institutions with which it has a contractual relationship,
• Bringing candidates and employers together online through an intelligent interview system,
• Placing individuals in suitable jobs through interviews and other assessment systems,
• Designing a corporate careers page,
• Sending messages such as emails and text messages,
• It collects the general and special categories of personal data of the relevant individuals for reasons such as using the applications it receives to develop the company’s human resources management and portfolio
  . Eksedra Information Technology Solutions (HRPeak) does not collect personal data in violation of the law, ethics, decency, or regulations. It does not share this information with unrelated organizations. It acts in accordance with the principles of integrity.

2- REASONS FOR EKSEDRA’S (HRPeak’s) DATA PROCESSING

Eksedra (HRPeak), which conducts various online activities to connect job seekers with employers, stores job seekers’ resumes in its own database and uses this data as needed, and collaborates with partner organizations, is required to store and process personal data in order to fulfill its legal obligations and provide the services it offers within its field of expertise. Your personal data is processed by Eksedra (HRPeak);

• Public Procurement Law No. 4734
• Law No. 4735 on Public Procurement Contracts
• Labor Code No. 4857
• Stamp Tax Law No. 488
• Law No. 492 on Fees
• Tax Procedure Law No. 213
• Turkish Penal Code No. 5232
• Criminal Procedure Code No. 5271
• Law No. 6563 on the Regulation of Electronic Commerce
• To fulfill our obligations as set forth in the Social Insurance and General Health Insurance Law No. 5510 and in the secondary regulations issued pursuant to this Law,
• Corporate Income Tax Law No. 5520
• Law No. 5651 on the Regulation of Publications Made on the Internet and the Fight Against Crimes Committed Through Such Publications
• Law No. 5809 on Electronic Communications
• Turkish Code of Obligations No. 6098
• Commercial Code No. 6102
• To fulfill our obligations set forth in the Occupational Health and Safety Law No. 6331 and in the secondary regulations issued pursuant to this Law,
  to comply with its provisions, and;

• To fulfill our obligations as set forth in the Labor Law No. 4857 and in the secondary regulations issued pursuant to this Law,
• To fulfill our obligations as set forth in the Social Insurance and General Health Insurance Law No. 5510 and in the secondary regulations issued pursuant to this Law,
• To fulfill our obligations as set forth in the Occupational Health and Safety Law No. 6331 and in the secondary regulations issued pursuant to this Law,
• To fulfill our obligations set forth in the Personal Data Protection Law No. 6698 and in the secondary regulations issued pursuant to this Law,
• Personal data is processed within the limits specified by law, in accordance with the law and the principles of good faith, and in a manner that is always relevant, limited, and proportionate to the purposes of providing the necessary information to the relevant public institutions and organizations, judicial or administrative courts, and law enforcement agencies when required,
•  

3- REASONS FOR EKSEDRA (HRPeak) TO TRANSFER PERSONAL DATA

Your personal data may be disclosed, within the scope of the purposes listed above and in accordance with the conditions set forth in Articles 8 and 9 of the Law, to natural and legal persons authorized by law; to other competent public institutions and organizations when necessary; to the relevant party with whom a contractual relationship has been established; to judicial and administrative courts; to law enforcement agencies; to institutions and organizations with which we have a business relationship; in cases where services are provided externally, to the relevant institution to which consulting services are provided or where employment is arranged; to companies or individuals with whom we have a contractual relationship and for whom we have prepared the infrastructure; and to the relevant employer regarding information obtained through interviews, exams, or any methods used in our evaluation systems, as well as to external consulting, technology, and training companies from which services are obtained.

4- HOW PERSONAL DATA IS COLLECTED AND THE LEGAL BASIS
Your personal data is collected by: is collected by Eksedra (HRPeak) itself or by authorized natural or legal persons acting as data processors, through both automated and non-automated methods—including verbally, in writing, or electronically—via channels such as email, telephone, the website, various contracts, and forms and records kept in paper form. For companies whose infrastructure is provided by Eksedra (HRPeak) Information Technology Solutions Industry and Trade Joint Stock Company (HRPeak), applications are submitted to that company. The company may use the data in human resources processes such as hiring and promotions. Personal data—both specific and general in nature—collected through systems such as the Personality Inventory Test and the Smart Interview system is collected and processed in accordance with the purposes specified above.

In this context;
APPLICANT : First and last name, ID, driver’s license, and passport information, gender, nationality, place of birth, date of birth, phone number, email address, address information, blood type, bank account information, marital status, military service information, education information, log records, IP information, ID photo, health information, certificates, work experience, references, information regarding your family status, smoking status, communities you belong to, hobbies, goals.

BUSINESS OWNER : Company name, tax ID number, signature, phone number, email address, passport-style photo, address information, bank account information.

Personal data of a special and general nature, as defined in Article 5, paragraphs 2/a, c, and ç -e-f, and paragraph 3 of Article 6 of the Law, provided that such processing does not infringe upon your fundamental rights and freedoms, and is based on the legitimate interests of Eksedra (HRPeak) and the legal grounds of existing or future contracts.

5- RIGHTS OF DATA SUBJECTS UNDER THE LAW

You may contact Eksedra (HRPeak) at any time to request that your personal data be:

• You may find out whether your personal data has been processed, the purpose of such processing, and whether it has been used in accordance with that purpose; and if it has been processed, you may request information regarding this,
• In accordance with the law, you may find out which third parties your information is shared with, both domestically and abroad,
• If you believe your information has been processed incompletely or incorrectly, you may request that it be corrected,
• You may request that your information be deleted or destroyed in accordance with the conditions set forth in Article 7 of the law,
• You may request that the third parties to whom your information has been disclosed be notified of your requests specified in subparagraphs (c) and (d) and that they take the same actions,
• You may object to a decision made against you as a result of the analysis of your data by automated systems, or if you believe your data has been recorded or used in violation of the law and you have suffered harm as a result, you may request compensation for such harm.

To exercise your rights under the law, you may submit your requests in writing to Eksedra (HRPeak); for more detailed information, please visit the Personal Data Protection Authority’s website.

In the request you submit to exercise your rights as a data subject, as outlined above, and which includes a statement specifying the right you wish to exercise, the matter you are requesting must be clear and understandable, and the subject of your request must pertain to you personally; if you are acting on behalf of another person, you must submit a special power of attorney certified by a notary public.

In your applications, it is mandatory under the “Communication on the Procedures and Principles for Applications to the Data Controller” to include your first and last name, signature, Turkish ID number, residential or business address, email address, and phone and fax numbers, as well as the subject of your request. Applications that do not include these elements will be rejected by Eksedra (HRPeak).

Eksedra (HRPeak) reserves the right to make changes to this privacy notice at any time for reasons arising from the Law, secondary regulations, and Board decisions. Any changes made to the privacy notice and the updated text will take effect immediately as of the date they are notified to you.

Eksedra Information Technology Solutions Ltd. (HRPeak)