Comprehensive Privacy Policy for Employee Candidates

Mobiversite Yazılım Bilişim Reklam ve Danışmanlık Hiz. San. Tic. Ltd. Şti.

To Our Candidates,
As Mobiversite Yazılım Bilişim Reklam ve Danışmanlık Hiz. San. Tic. Ltd. Şti. ("Mobiversite"/"we"/"our"/"us"/"our company"), we are committed to processing the personal data of job applicants in full compliance with the Personal Data Protection Law ("PDPL") No. 6698, which entered into force on 7 April 2016, and all other applicable legal requirements.

This Comprehensive Privacy Policy for Employee Candidates ("Policy") explains how Mobiversite, acting as the data controller, collects, processes, stores, and protects your personal information throughout your job application process and potential employment relationship with our company.

Please read this Policy carefully and review all provisions regarding personal data processed by Mobiversite throughout the recruitment procedure. Your personal data will be processed by Mobiversite as the data controller within the scope described below.

Definitions

Terms used in this Policy shall have the following meanings:

Employee Candidate(s): Candidates who have made a job application to be an employee in Mobiversite's official records
Data Subject: Natural person whose personal data are processed
Personal Data: Any information relating to an identified or identifiable natural person
Processing of Personal Data: Any operation performed upon personal data such as collection, recording, storage, preservation, alteration, adaptation, disclosure, transfer, retrieval, making available for collection, categorization, or blocking its use by wholly or partly automatic means or otherwise than by automatic means which form part of a filing system
Data Controller: Natural or legal person who determines the purposes and means of the processing of personal data, and who is responsible for the establishment and management of the filing system

1. What Personal Information Do We Collect?

We collect and process the following categories of personal data during our recruitment process:

1.1 Data Categories and Types

Category	Data Types	Collection Method
Identity Information	Full name, nationality, date of birth, age, gender, identification information from CV	CV, Application forms, Identity documents
Contact Information	Home address, email address, telephone/phone number, LinkedIn profile, social media platform information	CV, Application forms, Direct communication
Personnel Information	Work permit/visa information, military service status, driving license information	CV, Application forms, Supporting documents
Professional Experience	Employment history, educational qualifications, diplomas, academic background, professional certifications, language skills, computer skills, work experience, courses/seminars/certificates/awards, reference information, professional background, cover letter, portfolio	CV, Application forms, Educational certificates, Professional references
Visual and Audio Records	Photographs (if shared with CV), interview recordings (when applicable)	CV submissions, Interview sessions
Interview Assessment	Interview details, outcomes, assessment results, salary expectations, interviewer notes, communication records	Interview sessions, Assessment exercises, Internal evaluations
Special Categories	Health conditions, special needs, accommodation requests (only if voluntarily disclosed)	Voluntary disclosure during recruitment
Referral Information	Information provided by individuals who refer candidates to our company	Third-party referrals

1.2 Information Sources

We collect personal data through various channels:

Company website and online application portals
LinkedIn, Indeed, Kariyer.net, and other job platforms
Email communications and direct applications
Physical document submissions
Online interviews via Google Meet and similar platforms
Professional references and background checks
Notifications from administrative and judicial authorities
Other communication channels when necessary

Important Note: Some information is mandatory under applicable law or essential for processing your application. Upon demand, we will share with you which information is mandatory or essential.

2. Legal Basis for Processing

We process your personal data in accordance with the conditions specified in Articles 5 and 6 of the PDPL, based on the following legal grounds:

Contractual Necessity: Processing is necessary to evaluate your application and potentially establish an employment relationship
Legitimate Interest: Processing is necessary for Mobiversite's legitimate business interests in recruitment and human resources management, provided that your fundamental rights and freedoms are not compromised
Legal Obligation: Processing is required to comply with applicable laws and regulations
Explicit Consent: Where required by law or when processing special categories of personal data

3. Purposes of Personal Data Processing

We process your personal data for the following legitimate business purposes, in compliance with Article 4 of the PDPL:

3.1 Primary Recruitment Purposes

Receiving, reviewing, and responding to job applications
Verifying the accuracy of information provided
Evaluating qualifications for specific positions and other suitable roles
Coordinating interviews and recruitment activities
Preparing employment offers for successful candidates
Conducting candidate selection and positioning processes

3.2 Communication and Engagement

Maintaining ongoing communication with candidates
Informing candidates about current and future job opportunities
Inviting candidates to company events or industry gatherings
Sending job alerts and career recommendations
Requesting updates to professional information

You may opt out of these communications at any time.

3.3 Business Operations and Compliance

Enhancing our recruitment processes and career portal
Conducting internal reporting and analytics on recruitment effectiveness
Meeting legal and regulatory reporting requirements
Planning human resources processes
Conducting talent and career development activities
Performing background verification for candidates who receive conditional offers
Conducting retention and archive activities
Supervising business activities in accordance with legislation

4. Data Sharing and International Transfers

4.1 Domestic Data Sharing

We may share your personal data domestically with:

Our affiliated companies and group entities
Business partners and service providers
Legal, financial, and tax advisory services
Consultants and audit firms
Regulatory and supervisory institutions authorized to request personal data
Courts and enforcement offices when legally required
Professional references

4.2 International Data Transfers

Your personal data may be transferred internationally in the following circumstances:

Third-Party Platforms: When you apply through LinkedIn, Indeed, or similar international platforms, your data may be transferred abroad as these are foreign-origin services. We recommend reviewing the privacy policies of these platforms.
Cloud Infrastructure: Our company operates on cloud-based system infrastructure, which means your data may be transferred internationally for data storage and backup services, email and communication systems, and system maintenance and security.
Service Providers: We utilize multinational cloud and service providers with adequate security measures for data processing, storage, and backup services.

All international transfers comply with PDPL Articles 8 and 9 and include appropriate security safeguards.

5. Data Retention Period

We retain your personal data for the duration necessary to:

Fulfill our legal obligations
Resolve any disputes
Enforce our contractual agreements
Achieve the purposes for which the data was collected

Specific Retention Practices:

If you are successfully hired, the information collected during your application process becomes part of your permanent employee record
If you are not selected, we may retain your data for consideration for future positions (you may opt out at any time)
Background verification and reference check data are retained in accordance with legal requirements

Future Position Considerations: If you would not like your resume to be retained for consideration for future positions, please indicate this request in your resume or via email.

6. Security Measures

Mobiversite implements comprehensive security measures to protect candidate data, including:

6.1 Technical Safeguards

Preventive controls against unauthorized access, accidental data loss, intentional deletion, or data corruption
Secure cloud infrastructure with adequate protection measures
Regular system monitoring and maintenance
Data encryption for sensitive information

6.2 Organizational Measures

Designated personnel responsible for managing recruitment-related data processing
Regular review and limitation of employee access rights
Physical security controls to restrict data access to authorized individuals only
Implementation of audit trails and access monitoring systems
Regular review of access logs and investigation procedures for unauthorized access
Employee training on data protection practices

6.3 Access Controls

Role-based access to ensure only authorized personnel can access candidate information
Regular review of access permissions
Removal or limitation of unnecessary access rights
Prevention of unnecessarily broad authority assignments

7. Your Data Protection Rights

Under Article 11 of the PDPL, you have the following comprehensive rights regarding your personal data:

7.1 Information Rights

To learn whether your personal data is being processed
To request information about which of your personal data has been processed
To understand the purpose of personal data processing and whether the data is used in accordance with that purpose
To identify third parties to whom your personal data has been transferred domestically or internationally

7.2 Correction and Deletion Rights

To request correction of incomplete or inaccurate data
To request deletion or destruction of personal data under the conditions specified in Article 7
To request notification of corrections or deletions to third parties who received your personal data

7.3 Objection and Compensation Rights

To object to automated decision-making that produces results affecting you
To claim compensation for damages arising from unlawful processing of personal data

8. How to Exercise Your Rights

8.1 Application Methods

You may submit requests to exercise your rights through the following methods:

Written Application:

In person or via notary public to our company address
By secure electronic signature or mobile signature

Electronic Application:

Via registered email address to our designated contact email
Through our Data Subject Application Form (if available on our website)

8.2 Required Information

Your application must include:

Full name and signature
For Turkish citizens: TR Identity Number
For foreign nationals: nationality and passport number or identity number if available
Residential or business address for notification
Email address, telephone, or fax number for contact
Clear explanation of the right you wish to exercise
Supporting information and documents related to your request
Indication of application method

8.3 Application Requirements

Requests must be clear, explicit, and comprehensible
Requests must concern your own personal data (or you must be specially authorized with certified authority for third-party requests)
Applications must fulfill minimum conditions stipulated in the Communiqué on Procedures and Principles of Application to the Data Controller

8.4 Response Timeline

Mobiversite will respond to your request within 30 days of receipt. Depending on the complexity of your request, we will either:

Fulfill your request
Provide a written explanation if the request is denied
Communicate any applicable fees (based on tariffs determined by the Personal Data Protection Authority)

Note: We may charge a fee equivalent to the cost of recording media (such as CD or flash drive) only when it is mandatory to provide responses in such formats.

9. Special Procedures

9.1 Background Verification

Background checks and reference verification procedures may be conducted on the information you have provided.

9.2 Interview Process

Interview details, assessments, and outcomes are recorded and processed for evaluation purposes. You will be informed of any recording during interview sessions.

9.3 Accommodation Requests

Information about special needs or health conditions is processed only when voluntarily disclosed and solely for the purpose of providing reasonable accommodations during the recruitment process.

10. Updates to This Policy

Mobiversite reserves the right to modify this Privacy Policy due to:

Changes in applicable law
New procedures established by the Personal Data Protection Board
Updates to our business practices or technology infrastructure

We will notify you of any material changes to this Policy through appropriate communication channels.

11. Contact Information

For questions about this Privacy Policy or to exercise your data protection rights, please contact us:

Company Name: Mobiversite Yazılım Bilişim Reklam ve Danışmanlık Hiz. San. Tic. Ltd. Şti.
Address: Üniversiteler Mahallesi Şehit Mustafa Tayyarcan Cad. Tepe Binası Apt. No:5/Z14 06800 Çankaya/Ankara
Contact Email: [email protected]

Declaration of Understanding

By proceeding with your job application, you acknowledge that:

You have read this Privacy Policy thoroughly and completely
You understand how your personal data will be collected, processed, and protected
You consent to the processing of your personal data as described in this Policy
You understand your rights as a data subject and how to exercise them
You may withdraw your consent at any time where processing is based on consent

This Policy is effective as of 03 June 2025 and supersedes all previous versions.
For the Turkish version of this Policy, please visit www.mobiversite.com/aday-aydinlatma-metni or contact us directly.