a) Data Controller
As MOBİLİZ BİLGİ VE İLETİŞİM TEKNOLOJİLERİ A.Ş. (hereinafter referred to as the “Company”), we hereby inform you that we process your personal data in our capacity as data controller within the scope of the Personal Data Protection Law No. 6698 (hereinafter referred to as the “PDPL”) and other applicable legislation.
b) What Categories of Your Personal Data Are Processed?
In accordance with the PDPL and other applicable legislation, your personal data in the categories of identity, contact, professional experience, personnel information, financial information, visual and audio records, military service status and sensitive personal data (health information, criminal convictions and security measures) will be processed for the purposes and on the legal grounds set out in this Employee/Trainee Clarification Text.
c) In Which Activities, on Which Legal Grounds and for What Purposes Will Your Personal Data Be Processed?
Your personal data obtained within the scope of the above activities are processed on the legal ground of “being expressly provided for by the laws” for the purposes of fulfilling our obligations arising from the employment contract and the legislation (in particular the Labour Law, the Occupational Health and Safety Law, the Social Security Law and other relevant legislation), carrying out occupational health and safety activities, and ensuring that activities are carried out in compliance with the legislation.
Your personal data obtained within the scope of the above activities are processed on the legal grounds of “being necessary for the establishment and performance of a contract” and “being necessary for the data controller to fulfil its legal obligations” for the purposes of fulfilling our obligations arising from the employment contract and the legislation, planning human resources processes, and carrying out finance and accounting operations.
Your personal data obtained within the scope of the above activities are processed on the legal ground of “data processing being necessary for the establishment, exercise or protection of a right” for the purposes of carrying out employee satisfaction and loyalty processes and carrying out fringe benefit and perk processes for employees.
***With regard to the personal and sensitive personal data of your relatives that you provide so that they can benefit from private health insurance, you are responsible for informing the persons concerned and, where necessary, obtaining their explicit consent, and you must be authorised to transfer this information to us and to the relevant institutions and organisations. Otherwise, the responsibility lies with you.
This activity, carried out under the Company Vehicle Use Procedure, aims to carry out and supervise our business activities, determine the location of the vehicle in the event of theft, and provide fuel support for the vehicles. Throughout the process, your personal data are processed on the legal grounds of “processing of the personal data of the parties to a contract being necessary, provided that it is directly related to the establishment or performance of the contract” and “data processing being necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject”.
For vehicle location tracking, you may also review the Vehicle Location Tracking Clarification Text posted in the Company’s common areas. If you cannot access that text, you may request it from [email protected].
This activity, carried out under the Company Vehicle Use Procedure, aims to carry out and supervise our business activities and to ensure occupational safety. Throughout the process, your personal data are processed on the legal ground of “processing of the personal data of the parties to a contract being necessary, provided that it is directly related to the establishment or performance of the contract”.
This activity, carried out under the Company Vehicle Use Procedure, aims to carry out and supervise business activities, ensure occupational safety, follow up and conduct legal affairs, and carry out contract processes. Throughout the process, your personal data are processed on the legal ground of “processing of the personal data of the parties to a contract being necessary, provided that it is directly related to the establishment or performance of the contract”.
During the use of Company vehicles, we need to make sure that your safety and the safety of the persons travelling in your vehicle are not endangered. This activity, carried out under the Company Vehicle Use Procedure, aims to carry out and supervise business activities, ensure occupational safety, follow up and conduct legal affairs, and carry out contract processes. Throughout the process, your personal data are processed on the legal grounds of “processing of the personal data of the parties to a contract being necessary, provided that it is directly related to the establishment or performance of the contract” and “being necessary for the establishment, exercise or protection of a right”.
Using Company vehicles under the influence of alcohol, medication or other substances is prohibited. If such a situation is detected, personal data relating to your health will be processed on the legal ground of “being necessary for the establishment, exercise or protection of a right”.
Your personal data obtained within the scope of the above activities are processed on the legal grounds of “being expressly provided for by the laws” and “being necessary for the data controller to fulfil its legal obligations” for the purposes of carrying out information security processes, managing access authorisations, ensuring the security of data controller operations, carrying out and supervising business activities, and providing information to authorised persons, institutions and organisations.
Since your personal data obtained through the operations you perform on the computer and corporate e-mail accounts allocated for your use may be processed for the purpose of carrying out information security processes, the Company computer and your corporate e-mail accounts should not be used for personal matters. We hereby inform you that, if situations violating the employee’s duty of loyalty are found in the corporate e-mail flow and content, these may be used against the employee, and that, if you leave the Company, work-related correspondence in your corporate e-mail account may be transferred, to the extent necessary and with manager approval, to the authorised employee taking over your duties in order to ensure the continuity of business processes.
Monitoring, auditing, tracking and backup activities carried out by MOBİLİZ through the corporate systems, applications, e-mail accounts, data storage areas, phone lines, vehicles and equipment, and camera systems used by employees are carried out in a manner that is relevant, limited and proportionate to their purposes.
Your personal data obtained within the scope of the above activities are processed on the legal grounds of “being necessary for the establishment and performance of a contract” and “the legitimate interest of the data controller” for the purposes of carrying out communication activities and ensuring business continuity.
Your personal data obtained within the scope of the above activities are processed on the legal ground of “the legitimate interest of the data controller” for the purposes of ensuring the physical security of the premises and ensuring the security of data controller operations.
Within the scope of the above activities, your personal data contained in lawsuit files and in documents received from judicial authorities, which are kept on Company computers, servers and backups and obtained by non-automated means from judicial authorities in physical or digital form, are processed on the legal ground of “data processing being necessary for the establishment, exercise or protection of a right” for the purposes of fulfilling obligations arising from the employment contract and the legislation for employees, ensuring that activities are carried out in compliance with the legislation, and following up and conducting legal affairs.
Your sensitive personal data (health status information) will be processed, in a manner that is relevant, limited and proportionate to the purposes of carrying out occupational health and safety processes and fulfilling our obligations arising from the employment contract and the legislation, on the legal ground of “being mandatory for the fulfilment of legal obligations in the fields of employment, occupational health and safety, social security, social services and social assistance”.
Your sensitive personal data (health status information) will be processed for the purpose of providing fringe benefits to employees on the legal ground of “being mandatory for the fulfilment of legal obligations in the fields of employment, occupational health and safety, social security, social services and social assistance” and will be shared with the contracted company providing the private health insurance service.
Your personal data within the scope of the activities listed below will be processed with your explicit consent:
Your sensitive personal data (criminal record) will be processed on the legal ground of your explicit consent, in a manner that is relevant, limited and proportionate to the purposes of carrying out occupational health and safety processes and planning human resources processes.
Your personal data (name-surname, department and passport photo) will be processed on the legal ground of your explicit consent for the purpose of developing social relations among colleagues newly joining the Company and announcing new colleagues.
Vehicle tracking system and camera records may be shown to customers for promotional purposes during sales meetings with prospective customers. This is done by obtaining the explicit consent of the relevant employee.
d) What Is the Method of Collecting Your Personal Data?
Your personal data will be obtained verbally, in writing or electronically through the automated or non-automated methods listed below, based on the legal grounds set out in Articles 5 and 6 of the PDPL, in order to fulfil the purposes set out in paragraph (c) of this text:
e) To Whom and for What Purposes May Your Processed Personal Data Be Transferred?
Your personal data will be transferred without seeking the explicit consent of the personnel, for the purposes set out below and pursuant to Article 8 (2) (a) of the PDPL:
f) In Which Cases Are Your Personal Data Transferred Abroad?
The Company uses Microsoft enterprise services in the conduct of its general business activities. The infrastructure and databases of these services are located abroad. For personal data transfers abroad, the standard contract signing and notification procedures have been completed in accordance with Article 9 of the PDPL.
g) What Are Your Rights as the Data Subject?
Under Article 11 of the Personal Data Protection Law No. 6698 (hereinafter referred to as the “PDPL”), personal data owners defined as “data subjects” (hereinafter referred to as the “Applicant”) are granted the following rights:
In addition to the rights set out in Article 11 of the PDPL, if you give explicit consent to the processing of your personal data, you have the right to withdraw such explicit consent at any time.
You may submit your requests regarding the rights listed above:
Your application must include: a) your name, surname and, if the application is made in writing, your signature; b) for citizens of the Republic of Türkiye, your T.R. identity number, and for foreigners, your nationality, passport number or, if any, identity number; c) your residential or workplace address for notification; d) if any, your e-mail address, telephone and fax number for notification; e) the subject of your request. You must also attach the relevant information and documents to your application.