Employee/Intern Clarification Text

MOBİLİZ BİLGİ VE İLETİŞİM TEKNOLOJİLERİ A.Ş.
EMPLOYEE/TRAINEE CLARIFICATION TEXT

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?

  • Activity: Creating the personnel file, making minimum living allowance (AGİ) notifications, carrying out mandatory private pension (BES) transactions, making employment start and termination notifications and other notifications required by the Social Security Institution (SGK), carrying out processes relating to annual leave, overtime and payrolls, carrying out occupational health and safety trainings and activities, and making occupational accident notifications

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.

  • Activity: Carrying out processes relating to the employment contract and its annexes, making employee salary, severance and notice payments, approving and paying employee work advances and/or expenses, carrying out employee performance evaluations, planning the training calendar, recording and reporting trainings, and monitoring the development of employees as a result of the trainings they attend

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.

  • Activity: Providing employees with fringe and social benefits (providing meal cards, setting up health insurance, life insurance and an employer-contributed private pension plan, and allocating corporate phone lines)

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.

  • Activity: Allocating vehicles to employees and tracking vehicle location

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].

  • Activity: Providing overnight accommodation support to vehicle users travelling out of town for business purposes

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”.

  • Activity: Recourse to those responsible for expenses such as traffic fines and damages arising from traffic accidents relating to the vehicle allocated to the employee

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”.

  • Activity: Applying disciplinary sanctions in cases of non-compliance with the Company Vehicle Use Procedure

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”.

  • Activity: Keeping log records, regulating access authorisations and taking other related technical measures within the scope of information security processes; establishing and managing the information technology infrastructure, managing corporate e-mail accounts and ensuring business continuity

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.

  • Activity: Carrying out daily internal communication within the Company; being contacted by our Company, customers, suppliers or other persons and institutions within the scope of your job position

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.

  • Activity: Recording building entries and exits; obtaining your entry and exit records through the use of your cards, which are kept on Company computers, servers and backups and obtained digitally by automated means

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.

  • Activity: Archiving lawsuit processes and files and conducting legal affairs

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.

  • Activity: Obtaining health reports within the scope of pre-employment and periodic medical examinations and incapacity for work

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”.

  • Activity: Providing health insurance for employees

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:

  • Activity: Obtaining criminal records with regard to occupational health and safety and human resources processes

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.

  • Activity: Developing social relations among colleagues newly joining the Company and announcing them to their colleagues

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.

  • Activity: Showing the Mobiliz demo account screen to prospective customers in sales and promotional presentations

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:

  • Submission of the information and documents requested for creating the personnel file,
  • Submission of performance evaluations,
  • Submission by the Employee/Trainee,
  • Review of corporate user accounts,
  • Automatically through in-vehicle sensors in Company vehicles, by your written notification to the Company’s authorised units, and through registered mail with return receipt sent by official authorities.

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:

  • Your personnel data will be transferred to the management of Bilkent Cyberpark / Ankara Teknoloji Geliştirme Bölgesi Kurucu ve İşletici A.Ş. in order to fulfil our obligations arising from the Technology Development Zones Implementing Regulation under Law No. 4691.
  • Your personnel data will be shared with the financial advisory firm from which we receive support for payroll services, in order to fulfil our obligations arising from the Occupational Health and Safety Law No. 6331 and the Social Insurance and General Health Insurance Law No. 5510.
  • Your personal data will be shared with the firm from which we receive SGK consultancy on incentive payments, with the relevant public institution requesting documents where an incentive is obtained, and, for foreign employees, with the relevant public institution and consultancy firm for obtaining work permits.
  • Your personal data consisting of your identity, bank account information and salary/payment information will be shared with the bank that intermediates the payments to be made to you.
  • Your personal data consisting of your identity and contact information are transferred to the contracted insurance company in order to provide fringe and social benefits to employees.
  • Your personal data consisting of your identity, contact and professional experience information (name-surname, e-mail address and title) will be shared with the relevant organisation company for the purposes of carrying out training activities and participating in fairs, congresses and events.
  • Your personal data consisting of salary amount, title and fringe benefit information will be shared anonymously (based on title, without specifying your identity information) with the firms from which we receive consultancy on the effectiveness and analysis of remuneration policies, for the purposes of carrying out employee fringe benefit and perk processes and conducting the remuneration policy.
  • Your personal data consisting of your identity, contact and professional experience information (name-surname, e-mail address and title) will be shared with prospective suppliers and/or suppliers, limited to the conduct of commercial activities, for the purposes of carrying out goods and/or services procurement processes and contract processes.
  • Your personal data consisting of your identity, contact and professional experience information (name-surname, e-mail address and title) will be shared with potential customers and/or customers and with business and solution partners, limited to establishing and maintaining the commercial relationship, for the purposes of carrying out sales and marketing processes and customer relationship management processes.
  • If you are required to travel between cities or abroad due to assignments within the scope of the Company’s activities, your personal data such as your identity information, photograph, passport, SGK payroll, social security (SSK) statements and bank account statement will be shared, to the extent necessary, with the travel agency organising the trip and with the relevant travel/accommodation companies so that the travel arrangements can be made.
  • Your name-surname data will be shared with the company supplying the meal card so that a meal card can be provided to you.
  • Your identity information will be provided to the operator of the Company phone lines allocated for your use.
  • Your personal data will be shared with the relevant public institutions and organisations and with private institutions and organisations, where necessary or upon request, in order to fulfil legal obligations under the relevant legislation.
  • Your personal data may be shared with our attorneys, to the extent necessary and within the framework of their duty of confidentiality, in order to follow up legal processes.

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:

  • To learn whether your personal data are processed,
  • To request information if your personal data have been processed,
  • To learn the purpose of processing your personal data and whether they are used in accordance with their purpose,
  • To know the third parties and institutions to whom your personal data are transferred in Türkiye or abroad and to request detailed information on the matter,
  • To request the rectification of your personal data if they are incomplete or inaccurately processed, and to request that the operations carried out in this respect be notified to the third parties to whom your personal data have been transferred,
  • To request the erasure or destruction of your personal data if the reasons requiring their processing cease to exist, even though they have been processed in compliance with the PDPL and other applicable laws and legislation, and to request that the operations carried out in this respect be notified to the third parties to whom your personal data have been transferred,
  • To object to a result against you arising from the analysis of the processed data exclusively through automated systems,
  • To request compensation for the damage if you suffer damage due to the unlawful processing of your personal data.

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:

  • by visiting our Company in person at Mustafa Kemal Mah. 2127.Sok. No:42/1-2 Çankaya Ankara,
  • in writing through a notary public or by registered letter with return receipt, so that your identity can be verified and information is not disclosed to the wrong persons,
  • via our registered electronic mail (KEP) address [email protected],
  • by sending an e-mail to [email protected] from the e-mail address (if any) that you have previously notified to our Company and that is registered in our systems, or by other methods to be determined by the Board in the future.

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.

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