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PRIVACY AND PERSONAL DATA PROTECTION POLICY​

1. Introduction

Bu Gizlilik ve Kişisel Verilerin Korunması Politikası (“Politika”), veri sorumlusu sıfatıyla hareket eden HR Effect İnsan Kaynakları Hizmet ve Danışmanlık Tic. Ltd. Şti.’nin (“HR Effect” veya “Şirket”) yürüttüğü faaliyetler kapsamında, This Privacy and Personal Data Protection Policy (the “Policy”) sets out the principles governing the processing of personal data collected through the website www.hreffect.com.tr (the “Website”) (HR Effect)

HR Effect undertakes to process, store, and safeguard personal data in accordance with Turkish Personal Data Protection Law No. 6698 (“KVKK”), as well as applicable secondary legislation and generally accepted data protection principles.

This Policy applies to all individuals (“Data Subjects”), including, without limitation, visitors to the Website, individuals submitting contact or quotation forms, job applicants, participants in events or campaigns, existing and prospective clients, and their respective employees, officers, and authorised representatives.

2. Data Controller

​Data Controller: HR Effect İnsan Kaynakları Hizmet ve Danışmanlık Tic. Ltd. Şti. (“HR Effect”) 

Registered Address: Beştepe Mah. 31 Sok. 2/B No: 104 Kollektif House, Yenimahalle, Ankara, Türkiye 

Telephone: +90 538 313 06 60 

Email: hello@hreffect.com.tr 

The Company operates as a licensed private employment agency under the supervision of the Turkish Employment Agency (İŞKUR) and holds licence number 18856451 dated 11 August 2025.

HR Effect İnsan Kaynakları Hizmet ve Danışmanlık Tic. Ltd. Şti. (HR Effect)

Adres: Beştepe Mah. 31 Sok. 2/B No: 104 Kollektif House, Yenimahalle / Ankara, Türkiye (HR Effect)

Telefon: +90 538 313 06 60

E-posta: hello@hreffect.com.tr (HR Effect)

Şirketimiz, İŞKUR’un denetiminde özel istihdam bürosu olarak faaliyet göstermekte olup 11.08.2025 tarihli 18856451 numaralı lisansa sahiptir. (HR Effect)

3. Categories of Personal Data Processed

Subject to the nature of the relevant activity, the Company may process the following categories of personal data:

  • Identification Data: Full name, national identification number (where legally required), date and place of birth, nationality, and similar identifiers.
  • Contact Data: Postal address, telephone number, email address, corporate title, and job position.
  • Professional and Educational Data: Curriculum vitae details including education, employment history, certifications, language skills, references, competencies, and areas of expertise.
  • Recruitment and Assessment Data: Interview notes, assessment outcomes, test and inventory results, reference check outcomes, and salary expectations.
  • Client and Supplier Relationship Data: Details of contractual counterparties, authorised signatories and representatives, and financial data necessary for invoicing and payment processes (including bank account details).
  • Legal and Compliance Data: Records relating to claims, complaints, regulatory correspondence, litigation, and enforcement proceedings.
  • Website and Technical Data: IP address, device identifiers, browser type, access timestamps, pages visited, cookies, and similar tracking technologies (as further described in the Cookie Policy).HR Effect)

4. Purposes of Processing

Personal data are processed for the following purposes:

  • Recruitment, selection, and placement services, including receipt and evaluation of applications, scheduling and conducting interviews, reference checks, candidate shortlisting, submission of candidate profiles to client employers, and monitoring placements during probationary or guarantee periods.​
    • Adayların başvurularının alınması, değerlendirilmesi, mülakat süreçlerinin planlanması ve yürütülmesi, referans araştırmalarının yapılması, aday-shortlist çalışmalarının gerçekleştirilmesi, aday profillerinin danışmanlık verilen işverenlere sunulması, 3 ay deneme süresi garantisi kapsamında süreçlerin takibi.
  • Provision of professional services, including HR organisational development, performance and evaluation systems, management consultancy, payroll-related technical services, social security and work permit consultancy for foreign personnel, start-up finance advisory, and other consultancy services offered by the Company.
  • Contractual and commercial management, including the negotiation, execution, and performance of contracts, management of client and supplier relationships, invoicing, and collection activities.
  • Communications and stakeholder engagement, including responding to enquiries, complaints, and requests, and organising meetings, events, and professional activities.
  • Marketing and business development activities, including the distribution of newsletters, announcements, invitations, offers, and promotional communications, subject to applicable consent requirements.
  • Compliance with legal and regulatory obligations, including obligations arising under employment law, social security legislation, tax law, and regulations applicable to licensed private employment agencies.
  • Information security and operational integrity, including ensuring the security of IT systems, maintaining audit trails and logs, and preventing or detecting cyber security incidents.

5. Legal Bases and Methods of Processing

Personal data may be collected by automated or non-automated means, including through online platforms, electronic communications, telephone calls, face-to-face interactions, CV submissions, references, event registrations, and contractual documentation.

Processing is carried out on the legal bases set out in Articles 5 and 6 of the KVKK, including where processing is:​

  • Explicitly provided for in the laws,
  • Being directly related to the establishment or performance of a contract,
  • Necessary to comply with a legal obligation to which the Company is subject;
  • Necessary for the establishment, exercise, or defence of legal claims;
  • Necessary for the purposes of the Company’s legitimate interests, except where such interests are overridden by the rights and freedoms of the data subject;
  • Based on the data subject’s explicit consent, where required.

Special category personal data are processed only where the statutory conditions are satisfied and appropriate technical and organisational safeguards are implemented

6. Disclosure and Transfer of Personal Data

Personal data may be disclosed or transferred, strictly on a need-to-know basis and in accordance with applicable law, to:

  • Client employers receiving recruitment or personnel-related services, for the purpose of candidate evaluation and placement;
  • The Company’s business partners, service providers, suppliers, professional advisers, and independent auditors;
  • Competent public authorities, regulatory bodies, courts, and İŞKUR, as required under applicable legislation;
  • Domestic and, where necessary, international IT, cloud computing, communication, and infrastructure service providers.

It can be transferred in accordance with the conditions stipulated in Articles 8 and 9 of the KVKK.

Where personal data are transferred outside Türkiye, such transfers are carried out in accordance with cross-border data transfer requirements under the KVKK, including adequacy decisions, standard contractual commitments, or explicit consent where required.

7. Cookies and Similar Technologies

Information regarding the use of cookies and similar tracking technologies on the Website is provided in the Cookie Policy.HR Effect)

This Policy should be read in conjunction with the Cookie Policy.

8. Retention Period of Personal Data

Personal data are retained only for as long as necessary to fulfil the purposes for which they were collected or to comply with applicable legal and regulatory requirements.

For example;

  • Recruitment-related data may be retained in a candidate database for a reasonable period (e.g. two (2) years);
  • Contractual, accounting, and financial records are retained for statutory retention periods under applicable commercial and tax legislation.​

9. Your Rights Under the KVKK

In accordance with Article 11 of the KVKK, data subjects have the right to::

  1. Obtain confirmation as to whether personal data concerning them are being processed;
  2. Request access to personal data and related information;
  3. Obtain information on the purposes of processing and whether personal data are processed in line with such purposes;
  4. Be informed of the recipients or categories of recipients to whom personal data have been disclosed, domestically or internationally;
  5. Request rectification of inaccurate or incomplete personal data;​
  6. Despite being processed in accordance with the KVKK and other relevant legal provisions, the right to request deletion or destruction in the event that the reasons for processing no longer exist,
  7. Request notification of rectification or erasure to third parties to whom personal data have been disclosed;
  8. Object to decisions based solely on automated processing which produce legal or similarly significant effects;
  9. Seek compensation for damages arising from unlawful processing of personal data.​

haklarına sahipsiniz.

10. How to Exercise Your Rights

Requests relating to data subject rights may be submitted to the Company:

  • In writing, by signed notice sent to the registered address above;
  • By registered electronic mail (KEP), secure electronic signature, or mobile signature;
  • Through other methods permitted under applicable data protection legislation.

You can contact HR Effect.

Requests will be handled free of charge and responded to within thirty (30) days, unless the nature of the request requires a fee as determined by the Personal Data Protection Board.

11. Amendments to the Policy

The Company reserves the right to amend this Policy from time to time to reflect changes in legislation, regulatory guidance, or internal practices. The most up-to-date version of the Policy will always be made available at www.hreffect.com.tr​ This Privacy and Personal Data Protection Policy (the “Policy”) sets out the principles governing the processing of personal data collected through the website www.hreffect.com.tr (the “Website”) adresinde yayımlanır.