Clarification Text on the Processing of Personal Data

As Sola Koçluk Eğitim Dan. Hiz. A.Ş. ("Sola" or "Company"), we process your personal data as the data controller. This Clarification Text has been prepared to inform you about how we process personal data via CE Project Platform ("Platform"). Through the platform, we provide services that help our customers measure and increase employee engagement and help our customers obtain information from their employees on the issues they have determined. In this context, we allow actions to be carried out through the Platform, including; - Creating surveys to obtain information from their employees; sending surveys to employees, - Filling out the questionnaires and checking the answers given, - Analyzing, visualizing, and reporting of survey responses, - Collecting employees’ feedback through social interaction areas on the Platform. We process your personal data in accordance with this clarification text in accordance with the transactions performed within the scope of the platform.

Purposes of Processing Personal Data and Legal Reasons

Personal data of people who are members of the platform are processed in the following scope:

While your personal data is processed for the purposes of protecting and exercising our rights in case of a possible legal dispute and executing legal processes, Personal Data Protection Law ("Law") art. It is based on the legal reason "data processing is mandatory for the establishment, exercise or protection of a right" specified in 5/2-e.

While your personal data is processed for the purposes of conducting information security processes within the scope of your use of the Platform, operating and developing our business processes and the Platform, performing controls and analyzes within the scope of exam/interview applications, and examining and auditing our business activities, the Law art. It is based on the legal reason "data processing is compulsory for our legitimate interests, provided that it does not harm the fundamental rights and freedoms of the data subject" specified in 5/2-f.

The personal data of authorized persons who contact us or use the platform to use the platform are processed within the following scope:

While your personal data is processed for the purposes of creating your Platform registration and user account, protecting and exercising our rights in case of a possible legal dispute, and executing legal processes, Law on Protection of Personal Data ("Law") art. It is based on the legal reason that "data processing is mandatory for the establishment, exercise or protection of a right" specified in 5/2-e.
Your personal data, contacting you, receiving and finalizing your requests-complaints, operational processes regarding the use of the Platform While processing for the purposes of carrying out processes (for example, performing client/coach matching transactions via the Platform, scoring) and examining and supervising our business activities, the Law art. It is based on the legal reason that "data processing is compulsory for our legitimate interests, provided that it does not harm the fundamental rights and freedoms of the data subject" specified in 5/2-f. It will be processed in order to inform about opportunities and promotions.
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Sharing Personal Data with Third Parties

Your personal data is shared with the parties, business partners and Sola group companies that we provide and receive services at home and abroad, based on the stated legal reasons, in order to fulfill the purposes under the heading " Purposes of Processing Personal Data and Legal Reasons ". Your personal data will also be shared with authorized institutions and organizations in case of the need to provide information to authorized institutions and organizations (for example, to share with legal authorities due to a conflict). While sharing your personal data with third parties, compliance with the rules specified in Articles 8 and 9 of the Law is ensured.

Methods of Collecting Personal Data and Legal Reasons

Your personal data is collected on digital media by automatic and partially automatic methods. While processing your data, fulfillment of our legal obligations specified in Article 5 of the Law, establishment, use or protection of a right, and the fact that data processing is mandatory for our legitimate interests are acting on the basis of legal reasons. If at least one of the legal reasons specified in the Law is not available for the processing of your personal data, your explicit consent is required to process your data.

Related Person Rights

Article 11 of the Law on the Protection of Personal Data regulates the rights of data subjects. Under this article you have the following rights: - Learning whether your personal data is being processed, - Requesting information if your personal data has been processed, - Learning the purpose of processing your personal data and whether they are used appropriately for their purpose, - Knowing the third parties in the country or abroad to whom your personal data has been transferred, - To request correction of your personal data if it is incomplete or incorrectly processed, and to request notification of the transaction made within this scope to third parties to whom your personal data has been transferred, - To request the deletion or destruction of your personal data in the event that the reasons requiring its processing disappear, despite the fact that it has been processed in accordance with the provisions of the law and other relevant laws, and within this scope, and in case your personal data are processed incompletely or incorrectly, to request notification of the transactions made to third parties to whom your personal data has been transferred, - Objection to the emergence of a result against you by analyzing your processed data exclusively through automated systems, - To request the compensation of the damage if your personal data is damaged due to unlawful processing. To use your rights, Saray Mah. Ahmet Tevfik İleri Cad. Onur Ofis Park İş Merkezi Sit. A1 Blok Apt. You can send a mail with your requests to the address No.10 B / 1 Ümraniye / İstanbul. You can also apply to the Data Controller by using other methods specified in the Communiqué on Application Procedures and Principles.