Personal Data Protection and Processing Policy for Employees

The purpose of this Personal Data Protection and Processing Policy ("Policy") is to determine the terms and conditions regarding the use of personal data obtained from the employees of the Company who will benefit from the Human Resources and Personnel Management System ("Platform") provided through the website www.kolayik.com owned by Kolay Yazılım A.Ş. ("Kolay İK"), who have approved the Employee User Agreement.

Which Data is Processed?

Which Data is Processed?Under this heading, it is stated which data is considered personal data according to the Personal Data Protection Law No. 6698 ("Law") and which is provided by the Employee to Kolay İK and/or obtained from the Employees during the use of the Platform. Unless explicitly stated otherwise, the term "personal data" within the scope of the Policy will refer to the information listed below.

Kolay İK collects the following data provided by the Employee in digital form when creating an account.

Kolay İK can obtain information about the Employee's use of the Site and Platform through cookies, which are technical communication files, to detect access and usage habits for the services offered on the Platform. IP information is collected through cookies for the purpose of accessing and determining the usage habits of the services provided on the Platform.
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In accordance with Articles 3 and 7 of the Law, data that is irreversibly anonymized will not be considered as personal data under the provisions of the mentioned law, and processing activities related to this data will be carried out independently of the provisions of this Policy.

For What Purposes are the Data Used?

Kolay İK will use the personal data provided by employees for the purpose of opening the employee's Platform account and providing services related to the Platform. Kolay İK may also process the mentioned personal data for the improvement of its services, development of services, informing the Company or employees as necessary, and fulfilling obligations arising from the nature of the services it provides.
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The personal information in question may be used to establish contact with the Company or the employee, improve the Company's and employees' experience on the Platform (such as improving existing services, creating new services, and providing personalized services). Additionally, Kolay İK may use this information for reporting and business development activities, conducting various statistical evaluations without disclosing the employee's identity, creating a database, and conducting market research. With the employee's consent, this information may also be processed, stored, shared with third parties, and used to communicate with the employee for the purpose of direct marketing of various applications, products, and services.
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Additionally, Kolay İK may process and share data with third parties without obtaining separate consent from employees in accordance with Articles 5 and 8 of the Law and/or the presence of conditions specified in relevant legislation.

As mentioned above, Kolay İK may use cookies and, in this context, may transmit data to third parties only to the extent required by the analysis services provided by these third parties. These technical communication files are small text files sent to the browser to be stored in the main memory. Technical communication files facilitate the use of the internet by storing status and preference settings for a website. They are designed to obtain statistical information about how many people use internet sites, how many times a person visits a website, and how long they stay, as well as to help generate dynamic advertising and content specifically designed for the user's pages. Technical communication files are not designed to collect any personal data from the main memory. Most browsers are initially designed to accept technical communication files, but employees can always change their browser settings to prevent the arrival of technical communication files or to receive a warning when technical communication files are sent. Kolay İK also has the right to associate employees' behavior on the Site and Platform with a cookie in the browser for online behavioral advertising and marketing purposes, as well as to define remarketing lists based on metrics such as the number of pages viewed, visit duration, and goal completion.

Who Can Access the Data?

Kolay İK may transfer the personal data of employees and any new data obtained using this personal data to third parties who benefit from Kolay İK's services, for the purpose of fulfilling the obligations pledged to the Company and employees in providing these services, within the scope of providing these services.
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Kolay İK may share data with third parties such as external service providers, hosting service providers, law firms, research companies, call centers, etc., for the purposes of improving the employee experience (including improvement and personalization), ensuring the security of the Company and employees, detecting fraudulent or unauthorized use, conducting operational evaluation research, rectifying errors related to the Site, Platform, or Kolay İK services, and achieving any of the purposes stated in this Policy.
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The employee acknowledges and consents in advance that, subject to the limited purposes mentioned above, these third parties may store the personal data of employees on servers located anywhere in the world.

Access Rights and Correction Requests Regarding Data:

Employees can send their requests as described above in writing to the following address: Mesa Koz Sahrayıcedit Mah. Atatürk Cad. N:69 K:5 D:81 Kadıköy / İstanbul / Türkiye

Kolay İK may respond to the requests mentioned above, whether positively or negatively, with a reasoned response in written or digital form. No fees shall be charged for processing these requests as a general principle. However, in case the processing incurs costs, it may be possible to request a fee in accordance with the tariff determined by the Personal Data Protection Board, as per Article 13 of the Law.
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The employee commits to ensuring that the information covered by this Policy is complete, accurate, and up to date, and to immediately update this information in case of any changes. Kolay İK shall not be responsible for any inaccuracies or outdated information provided by the employee.
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The employee commits to ensuring that the information covered by this Policy is complete, accurate, and up to date, and to immediately update this information in case of any changes. Kolay İK shall not be responsible for any inaccuracies or outdated information provided by the employee.

The Retention Period for Personal Data

Kolay İK, the personal data provided by employees will be retained for the duration specified in this Policy and in the Human Resources and Personnel Management System User Agreement, for the purpose of enabling the Company and employees to benefit from the Platform and the services provided through the Platform, and for fulfilling the obligations arising from the nature of the Platform and related services. Additionally, Kolay İK may retain personal data for a limited period, as required, in case of any disputes that may arise between the Company and/or the employee, for the purpose of conducting necessary defenses within the scope of the dispute, and in accordance with the statute of limitations periods determined by relevant legislation.

Kolay İK commits to not disclosing the personal data obtained about employees to third parties or using it for purposes other than those specified in this Policy and in accordance with the provisions of the Law.
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In cases where links to other applications are provided through the Site and Platform, Kolay İK does not assume any responsibility for the privacy policies and content of these applications.

Policy Changes:

Kolay İK reserves the right to change the provisions of this Policy at any time. The updated Policy becomes effective on the date it is presented to the Company and/or the Employee through any means.