Disclosure Text

PEOPLEIN Human Resources and Consulting Limited Company

Personal Data Protection and Processing Policy

INTRODUCTION
Protection of personal data is among the most important priorities of PEOPLEIN Human Resources and Consulting Limited Company (“PEOPLEIN” or “Company”). This Personal Data Protection and Processing Policy (“Policy”) has been prepared to explain the principles adopted in the execution of personal data processing activities carried out by our Company and their compliance with the Personal Data Protection Law No. 6698 (“Law”). Our Company provides the necessary transparency by informing personal data owners and processes and protects your data within the framework of this Policy.

SCOPE
This Policy is related to all personal data of persons other than PEOPLEIN employees processed automatically or non-automatically provided that it is part of any data recording system. For detailed information regarding the personal data owners in question, the document ANNEX 2- Personal Data Owners of the Policy can be consulted.

IMPLEMENTATION OF THE POLICY AND RELATED LEGISLATION
The legislation in force regarding the processing and protection of personal data will primarily be applied. In the event of any inconsistency between the legislation and the Policy, PEOPLEIN will act in accordance with the legislation in force.

ENFORCEMENT OF THE POLICY
This Policy entered into force as of 21.08.2024. In the event of an update to the Policy, the effective date will be renewed and the current version will be published on our Company’s website.

SECTION 2 – ISSUES RELATED TO THE PROTECTION OF PERSONAL DATA

2.1. Ensuring the Security of Personal Data
PEOPLEIN takes the necessary technical and administrative measures to prevent the unlawful disclosure, access and transfer of personal data in accordance with Article 12 of the Law. Our Company conducts and has the necessary inspections conducted to ensure the level of security in accordance with the guidelines published by the Personal Data Protection Board.

2.2. Protection of Special Personal Data
Special personal data is protected with special importance under the Law due to the risk of causing victimization or discrimination to individuals when processed unlawfully. This data consists of sensitive data such as race, ethnic origin, political opinion, religious belief, health status. Our Company takes special measures for the processing and protection of such data.

2.3. Awareness and Audit
PEOPLEIN carries out regular training and information activities in order to increase the awareness of its employees on personal data security and offers new trainings in accordance with the changes in the legislation.

SECTION 3 – ISSUES RELATED TO THE PROCESSING OF PERSONAL DATA

3.1. Principles of Processing in Accordance with Legislation
Our company processes personal data in accordance with the following principles:

• Compliance with the law and rules of honesty,
• Ensuring accuracy and up-to-dateness,
• Processing for specific, clear and legitimate purposes,
• Being connected, limited and proportionate to the purpose for which they are processed,
• Storing for the period stipulated in the relevant legislation or necessary for the purpose for which they are processed.

3.2. Conditions for Processing Personal Data
Personal data is processed with the explicit consent of the data owner or within the framework of the conditions specified in Articles 5 and 6 of the Law.

3.3. Processing of Special Personal Data
Data related to health and sexual life can only be processed for legal requirements such as the protection of public health and the management of health services.

3.4. Transfer of Personal Data
Personal data may be transferred to third parties in accordance with Articles 8 and 9 of the Law. In this context, transfer occurs only in the following cases:

• Explicitly provided for in the law,
• To fulfill legal obligations,
• It is necessary for the establishment or performance of a contract,
• The data owner shares the data for the purpose of publicization.

SECTION 4 – STORAGE AND DESTRUCTION OF PERSONAL DATA

PEOPLEIN stores personal data for the period necessary for the purpose for which they are processed. In the event of expiration of the storage periods, the data will be deleted, destroyed or anonymized in accordance with periodic destruction processes.

SECTION 5 – RIGHTS AND APPLICATION METHODS OF PERSONAL DATA OWNERS

Personal data owners have the following rights in accordance with Article 11 of the Law:

• To learn whether personal data has been processed,
• To request information about it if it has been processed,
• To learn the purpose of processing,
• To know the third parties to whom the data is transferred,
• To request correction of data if it is processed incompletely or incorrectly,
• To request deletion if the reasons requiring processing are eliminated,
• To object to the analysis of processed data,
• To request compensation for damages suffered due to unlawful processing.

You can send your applications via e-mail to info@peoplein.com.tr or in writing to the address Zühtüpaşa Mah. Güleç Çıkmazı Sk. No: 1-3 İç Kapı No: 6 Kadıköy/İstanbul.

This Policy has been prepared by PEOPLEIN Human Resources and Consulting Limited Company to regulate the protection and processing of personal data. Please visit our website regularly for updates.

Best Regards,
PEOPLEIN Human Resources and Consulting Limited Company