# Candidate Privacy Notice

> This English translation is provided for information only. In the event of any conflict or inconsistency, the Turkish version prevails.

This Privacy Notice has been prepared under Article 10 of the Personal Data Protection Law No. 6698 ("KVKK" or the "Law"). It explains how the personal data of job applicants to Internetten Bilişim A.Ş. is processed. It applies equally to applications made through the careers form on https://internetten.com.tr (the "Site") and to applications sent by email.

## Data Controller

| Item | Details |
|---|---|
| Company name | Internetten Bilişim A.Ş. (the "Company") |
| Tax office and number | Uluçınar Tax Office, 4781003630 |
| Address | Sultan Orhan Mah. İlyasbey Cad. 1117 Sk. No:6, 41400 Gebze / Kocaeli, Türkiye |
| Email | satis@internetten.com.tr |
| Phone | 0850 650 0 500 |

If you apply through a group company's own website or channels, that group company is a separate data controller. Such applications are governed by that company's own privacy notice.

## Personal Data Processed

| Data category | Data |
|---|---|
| Identity | Full name |
| Contact | Email address, phone number, city of residence |
| Professional experience | Position applied for; education, work experience, skills and certifications in your CV; your cover letter; if you share them, your LinkedIn profile or portfolio link and the publicly available professional information at that link |
| Recruitment process | If the process moves forward, interview and assessment notes; information about the outcome of your application |
| Consent records | Your acknowledgement of this notice; your explicit consent record, if given; date and time of application |
| Transaction security | IP address; server access logs; browser and device signals processed by Cloudflare Turnstile |

Information and CV files (PDF, DOC or DOCX; up to 5 MB) sent through the careers form are not stored in a database on the Site. They are sent to the Company by email through Google LLC's Gmail SMTP email service.

## Special Categories of Data and Unnecessary Information

We do not ask for special categories of personal data during recruitment. Please do not include any of the following in your CV or cover letter:

- race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs,
- appearance and clothing,
- membership of associations, foundations or trade unions,
- health and sex life,
- criminal convictions and security measures,
- biometric and genetic data.

We do not need your photo to assess your application. Please also avoid sharing information we do not need to assess it, such as your Turkish ID number or marital status.

If your application contains such data, it will not be taken into account. Once identified, it will be deleted or made unreadable as soon as reasonably possible.

If your CV includes information about other people as references, you should inform them beforehand.

## Purposes and Legal Grounds

| Purpose | Legal ground (KVKK Art. 5) |
|---|---|
| Receiving your application; assessing your CV and qualifications for the position you applied for | Directly related to the conclusion of a contract (Art. 5(2)(c)) |
| Contacting you; scheduling and conducting interviews; informing you of the outcome | Directly related to the conclusion of a contract (Art. 5(2)(c)) |
| If you give explicit consent, considering your application for other suitable positions that may open during the retention period | Explicit consent (Art. 5(1)) |
| Protecting the careers form and the Site against bots and spam; ensuring information security | Legitimate interest (Art. 5(2)(f)) |
| Demonstrating that recruitment follows the law and the principle of equal treatment; protecting rights in potential disputes | Establishment, exercise or protection of a right (Art. 5(2)(e)) |
| Responding to requests from competent public authorities | Legal obligation (Art. 5(2)(ç)) |

If you are hired, your data will be transferred to your employee personnel file and you will be informed about this separately.

## Method of Collection

We collect your personal data:

- electronically, when you fill in the careers form on the Site or send your CV by email,
- automatically, through our servers and Cloudflare Turnstile when you visit the form page,
- orally, in writing or electronically, during in-person, phone or online interviews if the process moves forward.

## Transfers of Personal Data

### Transfers within Türkiye

| Recipient group | Purpose | Legal ground |
|---|---|---|
| Our group companies (Internetten Teknoloji San. Tic. Ltd. Şti., Cetvel Yazılım A.Ş., Sign Bilişim ve Sanayi A.Ş., Wislog Lojistik Ltd. Şti.) | If the position is at a group company, limited to the data needed to run the recruitment process | Art. 5(2)(c) |
| Competent public authorities, judicial and administrative bodies | Complying with legal obligations | Art. 5(2)(ç) |
| Lawyers and legal advisers | Protecting rights in potential disputes | Art. 5(2)(e) |

### Transfers abroad

When you apply, your personal data is transferred abroad through these service providers:

- **Google LLC (USA):** The careers form data and your CV file are delivered by email via Gmail SMTP.
- **Cloudflare, Inc. (USA):** Your IP address and browser and device signals are processed for form security through Cloudflare Turnstile.

These transfers comply with Article 9 of the Law, as amended by Law No. 7499, and with the Regulation on the Procedures and Principles for the Transfer of Personal Data Abroad:

- If there is an adequacy decision, the transfer relies on it.
- Without an adequacy decision, the Company relies primarily on the appropriate safeguards in Article 9(4) of the Law, above all the standard contract published by the Personal Data Protection Board. Standard contracts are notified to the Personal Data Protection Authority within five business days of signature.
- If appropriate safeguards cannot be provided and the transfer is only occasional, your explicit consent may be relied on under Article 9(6) of the Law. Where required, this consent is obtained through the consent checkbox on the careers form.

**Possible risks of transfers based on explicit consent:**

- The destination country may not offer a level of protection equivalent to Türkiye's.
- Authorities in that country may be able to access your data.
- It may be harder for you to exercise your rights.

You may withdraw your explicit consent at any time.

## Retention Period

Personal data relating to your application is kept for **1 year** from the date of application. This period takes into account:

- completing the recruitment process,
- if you consent, considering your application for suitable positions that open later,
- the need for evidence in potential disputes.

You may withdraw your consent or ask us to delete your data before this period ends. Your data will then be deleted. The only exception is data that must be kept for an ongoing recruitment process or to establish, exercise or protect a right.

At the end of the period, your data is deleted, destroyed or anonymised during periodic review in line with the Regulation on the Deletion, Destruction or Anonymisation of Personal Data.

## Your Rights and How to Apply

Under Article 11 of the Law, by applying to the Company you have the right to:

- learn whether your personal data is processed and, if so, request information about it,
- learn the purpose of processing and whether your data is used in line with that purpose,
- know the third parties in Türkiye or abroad to whom your data is transferred,
- request correction of incomplete or inaccurate data,
- request deletion or destruction of your data under the conditions in Article 7 of the Law,
- request that correction, deletion and destruction be notified to third parties to whom your data was transferred,
- object to a result against you that arises exclusively from automated analysis,
- claim compensation if you suffer damage from unlawful processing.

You can submit requests using one of these methods:

- hand-delivering or sending your signed (wet-ink) application to the address above,
- sending an application signed with a secure electronic signature or mobile signature to satis@internetten.com.tr,
- writing to satis@internetten.com.tr from an email address you have previously given to the Company and that is registered in our systems,
- using the [Data Subject Request](/en/data-subject-request) form on the Site.

We will conclude your request within **30 days** at the latest, free of charge. If the process involves an additional cost, a fee may be charged according to the tariff set by the Board. If your request is refused, you find our response insufficient, or we do not respond in time, you may file a complaint with the Personal Data Protection Board. Details of the application procedure are in our [Privacy Notice](/en/privacy-notice).

## Changes

We may update this notice to reflect changes in legislation or in our recruitment processes. The current version is published on the Site.

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Canonical: https://internetten.com.tr/en/candidate-privacy-notice