Privacy Notice for Job and Internship Applicants

This is an English translation provided for information. In case of any discrepancy, the Turkish version of this notice prevails.

DBO BİLGİ TEKNOLOJİLERİ ANONİM ŞİRKETİ
CAREERS WEBSITE PRIVACY NOTICE ON THE PROCESSING OF PERSONAL DATA

Under Law No. 6698 on the Protection of Personal Data (“KVKK”), your personal data obtained in connection with your job and/or internship application is processed by DBO Bilgi Teknolojileri Anonim Şirketi (“DBO” or the “Company”), as data controller, within the scope explained below.

This Privacy Notice has been prepared under Article 10 of the KVKK and the Communiqué on the Procedures and Principles to Be Followed in Fulfilling the Obligation to Inform, in order to inform candidates applying for jobs and internships about the processing of their personal data.

1. Data controller

2. Personal data processed

Within the scope of the job or internship application you make through the Careers page on DBO’s website, the following personal data that you provide in the application form and/or in your curriculum vitae (“CV”) and other application documents may be processed:

• Identity data: first name, last name and, if you include them in your CV, date of birth and similar identity data.
• Contact data: phone number, e-mail address and, if you include it in your CV, address.
• Education, professional experience and competence data: education and graduation details, work and internship experience, foreign language skills, certificates, professional and technical qualifications and similar career information.
• Data on the job/internship application: the position or internship programme applied for, application date, cover letter, career preferences, information obtained during interviews and assessments, and assessment results.
• Visual data: your photograph, if you include one in your CV or application documents.
• Reference data: if you name references, information about the referees and their assessments.
• Transaction security data: date, time, IP address and similar technical records, where generated by information systems while you use the Careers page.

Unless it is necessary for the evaluation of a job or internship application, DBO does not request special categories of personal data from candidates. We therefore ask you not to include in your CV or other application documents any special categories of personal data that are not necessary for your application, such as health data, data relating to security measures, political opinion, religion or belief, membership of an association, foundation or trade union, or biometric or genetic data.

3. Purposes of processing

Your personal data is processed for the following purposes:

• Receiving, recording and evaluating your job and/or internship application,
• Assessing your education, experience, competences and qualifications for the position or internship programme you applied for,
• Planning and conducting interviews, tests and similar assessment processes,
• Communicating with you about the application process,
• Verifying, where necessary and appropriate, the information and references you provided,
• Carrying out and concluding human resources and recruitment/internship selection processes,
• Carrying out preparatory steps towards the conclusion of an employment contract,
• Establishing, exercising or protecting the Company’s legal rights.

The evaluation of your personal data for other job or internship positions that may open at DBO in the future, after your application is concluded, will be carried out on the basis of the explicit consent you may give separately and optionally for this purpose.

4. Method of collection and legal grounds

Your personal data is collected electronically by completing the application form on the Careers page of DBO’s websites www.dbo.com.tr and www.dbotech.uk and by uploading your CV or other application documents; and, if the recruitment process continues, electronically or physically through interviews, meetings, assessments and other information and documents you provide.

Depending on the nature of the application and the relevant processing activity, your personal data is processed on the following legal grounds set out in the second paragraph of Article 5 of the KVKK:

• Processing is necessary for the establishment, exercise or protection of a right (KVKK Art. 5/2-e),
• Processing is necessary for DBO’s legitimate interests, provided that it does not harm your fundamental rights and freedoms (KVKK Art. 5/2-f).

If, after your application is concluded, your personal data is kept in the candidate pool to be considered for positions or internship programmes that may open in the future, this processing activity will be carried out on the basis of the explicit consent you may give separately.

5. Transfer of personal data

To the extent necessary and proportionate for carrying out recruitment and human resources processes, your personal data may be accessed by the Human Resources department within DBO and by the authorised managers and employees concerned with the position applied for.

Limited to the purposes stated above and in accordance with the conditions set out in Article 8 of the KVKK, your personal data may, where necessary, be transferred to suppliers/data processors from whom we obtain information technology infrastructure, website and data hosting services, to legal advisers for the conduct of legal proceedings, and to authorised public institutions and organisations where required by law.

6. Retention period

Your personal data obtained in connection with job and internship applications is retained for as long as required by the relevant processing purposes and in accordance with DBO’s personal data retention and destruction practices.

Under DBO’s Personal Data Processing and Protection Policy in force, the personal data of job candidates is retained for 6 (six) months from the end of the application relationship; at the end of this period and the related periodic destruction period, it is deleted, destroyed or anonymised unless there is another legal ground requiring its processing.

If you choose to be included in the candidate pool to be considered for job or internship positions that may open in the future after your application is concluded, your personal data will be retained for this purpose for 6 (six) months on the basis of the explicit consent you give separately. You may withdraw your explicit consent at any time.

7. Your rights under the KVKK and how to apply

Under Article 11 of the KVKK, you may apply to DBO to exercise the following rights:

• To learn whether your personal data is processed,
• To request information if your personal data has been processed,
• To learn the purpose of processing and whether the data is used in line with that purpose,
• To know the third parties in Türkiye or abroad to whom your personal data is transferred,
• To request the correction of your personal data if it is incomplete or inaccurately processed, and to request that third parties to whom the data was transferred be notified of this,
• To request the deletion or destruction of your personal data under the conditions set out in Article 7 of the KVKK, and to request that third parties to whom the data was transferred be notified of this,
• To object to a result against you arising from the analysis of the processed data exclusively by automated systems,
• To request compensation for damages if you suffer loss due to unlawful processing of your personal data.

You may submit your requests under Article 11 of the KVKK, in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller, together with information and documents proving your identity and your request, in writing to DBO Bilgi Teknolojileri Anonim Şirketi at Koşuyolu Mah. Salih Omurtak Sok. No:78 Kadıköy / İstanbul, or by one of the other application methods provided for in the legislation.

Your applications will be concluded as soon as possible depending on the nature of the request, and in any case within the period set out in the KVKK.

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