HG ACADEMY DANIŞMANLIK EĞİTİM TERCÜMANLIK TURİZM SAĞLIK HİZMETLERİ DIŞ TİCARET LTD. ŞTİ.
PRIVACY AND PERSONAL DATA PROTECTION POLICY
1. Purpose of the Privacy and Personal Data Protection Policy
The purpose of this Privacy and Personal Data Protection Policy (“Policy”) is to provide information on the personal data processing activities and the methods adopted for the protection of personal data carried out in accordance with the Personal Data Protection Law No. 6698 (“Law”) and relevant regulations by HG Academy Consulting Education Tercümanlık Turizm Sağlık Hizmetleri Dış Ticaret Limited Şirketi (“HG Academy”) as the “data controller”. In this regard, it is aimed to inform the natural persons whose personal data are processed (“Data Subjects”), particularly our customers and service users, employees, employee candidates, shareholders and officials of the suppliers and institutions we cooperate with as well as other third parties.
2. Principles on the Processing of Personal Data
All personal data processed by HG Academy are processed in accordance with the regulations stipulated in the Law. In this respect, personal data are,
a. Processed in accordance with the law and in good faith,
b. Ensured to be accurate and up-to-date when necessary,
c. Processed for particular, explicit and legitimate purposes,
d. Used and disclosed in connection with the legal purpose for which they are processed in a limited and measured way.
e. Stored for the period required by the relevant legislation or for the duration of the purpose for which they are processed.
3. Purpose of Processing Personal Data
HG Academy undertakes to process personal data in accordance with the principles set forth in Article 4 of the Law, the personal data processing conditions specified in Articles 5 and 6 of the Law for the following purposes:
a) Regarding the natural and legal persons that we provide services, as well as our suppliers and business partners:
a. Fulfilment of all kinds of service delivery and performance be provided
b. Share or exchange of relevant information necessary for potential services and business activities
c. Fulfilment of additional services (consulting, communication, etc.) for the fulfilment of commercial and business activities
d. Improving and developing the services offered, determining and implementing commercial activities and business strategies
e. Management and follow-up of customer requests and complaints,
f. Planning information security processes, creating and managing infrastructures for information technologies,
g. Follow-up and execution of legal processes and required communications with public institutions and authorities,
b) Regarding our employees:
a. Exercising the rights arising from the relevant legislation and fulfilling the obligations provided therein, including the subjects of occupational health and safety, social security, tax, etc.
b. Resolution of disputes arising from employment contracts,
c. Development of corporate planning and management,
d. Ensuring order, control, safety, management and compliance within the workplace,
e. Conducting recruitment processes,
f. For any purpose serving the legitimate interests of HG Academy where data processing is mandatorily required, on the condition that such processing does not harm the fundamental rights and freedoms of the data subject concerned.
4. Methods of Collecting Personal Data
Personal data can be collected by HG Academy verbally, in writing or electronically, with automatic or non-automatic methods and similar means. These processes are carried out in line with the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law and the legal reasons specified in this Policy. Where the explicit consent of the Data Subjects are required as per Law, it is obtained with the clarification text informed to and the explicit written consent given by the Data Subject. In this context, HG Academy may collect personal data by,
a. Obtaining personal data of natural persons or legal persons’ shareholders, members of the board of directors, representatives, signatories and employees during the execution of commercial transactions, negotiations and contracts for the purpose of conducting its commercial activities,
b. Collecting general and special categories of personal data obtained during the interviews with the employee candidates in order to meet the employment needs,
c. Negotiating and signing employment contract with the employee and obtaining general and special personal data during the performance of the employment contract,
d. In addition, by obtaining personal data through notifications from administrative and judicial authorities and other communication channels,
e. Information-sharing, communication and correspondence carried out on the internet or via our e-mail address,
f. Channels of any verbal, written, physical or electronic means, including but not limited to, information, application and registration forms, job application and notification forms or petitions delivered personally or by third parties to HG Academy
5. Permission to Process and Transfer Personal Data
The processing of personal data within the country and its transfer to third parties by HG Academy is possible with the explicit consent of the Data Subject. Under the Article 5 of the Law, in the absence of explicit consent, on the ground of one of the conditions laid down below, personal data may be processed if:
a. It is expressly provided for by law,
b. It is necessary for the protection of the life or bodily integrity of the person himself or someone else, who is unable to express his consent due to actual impossibility or whose consent is not legally valid,
c. It is directly related to the formation or performance of a contract and the processing of the personal data of the parties to the contract is required,
d. It is necessary for HG Academy to fulfill its legal or statutory obligations,
e. Personal data is made public by the Data Subject,
f. It is necessary for the establishment, exercise or protection of a right,
g. It is compulsory for the legitimate interests of HG Academy, provided that it does not harm the fundamental rights and freedoms of the Data Subject concerned.
Data regarding race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and dress, membership in associations, foundations or unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data are of special category of personal data. The processing and transfer of such data by HG Academy is possible with the express consent of the Data Subjects. If there is no express consent,
a. Special categories of personal data not related to health and sexual life may be processed without seeking the explicit consent of the Data Subject in cases stipulated by the laws.
b. Personal data related to health and sexual life can only be processed by persons who are under the obligation of confidentiality or by authorized institutions and organizations for the purposes of protecting public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services.
The processing of personal data abroad and its transfer to third parties abroad is possible with the explicit consent of the Data Subjects. In cases where there is no explicit consent, personal data can be transferred in the presence of one of the conditions in the provisions of Article 5/2 and 6/3, with the additional fulfilment of the following conditions:
a. Providing adequate protection for personal data as determined and announced by the Personal Data Protection Board (“Board”)
b. In the absence of adequate protection, upon the Board’ permission, commitment in writing by data controllers in Turkey or in the relevant foreign country to provide adequate protection.
In cases where the interests of the Republic of Turkey or the Data Subject may be seriously harmed, without prejudice to the provisions of the international conventions, personal data can be transferred abroad, only with the permission of the Board and after obtaining the opinion of the relevant public institution or organization.
6. Observation of the Rights of the Data Subject
Data Subjects have the rights regarding their personal data to:
a. Be informed whether personal data about them is processed,
b. If personal data is processed, be informed of what data is processed and what the purpose of data processing is and whether they are used in accordance with their purpose,
c. Learn the purpose of processing personal data and whether they are used in accordance with the purpose,
d. Learn about the third parties to whom personal data is transferred within the country or abroad,
e. Request the correction of incomplete or incorrectly processed personal data and the notification of such circumstance to third parties to whom personal data is transferred,
f. Request the deletion or destruction of personal data and the notification of the situation to third parties to whom personal data is transferred, in case the reasons requiring the processing of such data cease to exist within the framework of Article 7 of the Law,
g. Object to the emergence of a result against their interest due to the analysis of the processed data exclusively through automated systems,
h. Demand compensation for the damages, in case of loss incurred due to unlawful processing of personal data.
In order to exercise the above-mentioned rights, Data Subjects can direct their requests to HG Academy through the following communication channels:
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Application Method |
Application Address |
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With a written petition signed by your handwriting and personally delivered with valid ID document or by a notary public |
Fidanlık Mah. Ziya Gokalp Cad. Sener Onar Business Center Apt. No: 23/6 Çankaya / ANKARA |
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With an electronic petition with secured electronic signature or mobile signature, via your e-mail address or by using your e-mail address previously notified by you and registered in our system |
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In accordance with the Communiqué on the Application Procedures and Principles to the Data Controller, the following information must be included in your application: i. Name, surname and signature, ii. National ID for the citizens of the Republic of Turkey and for foreigners, their nationality and passport number or identification number, iii. Domicile or workplace address for notification, iv. E-mail address, telephone and fax number for notification, (if available) v. Subject of Request
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7. Measures Regarding Accurate and Up-to-Date Storage, Security and Protection of Personal Data
HG Academy undertakes the necessary administrative and technical measures in line with the Personal Data Security Guide published by the Personal Data Protection Authority (“Authority”) in order to keep personal data accurate and up-to-date, to store them in secure environments and to prevent their loss, alteration or unlawful use.
Employees will not disclose the personal data they have learned to others in violation of the provisions of the Law and will not use them for purposes other than the relevant processing purpose within this Policy. This obligation of secrecy and confidentiality shall continue indefinitely after the period of their employment.
In case the processed personal data is retrieved obtained by others unlawfully, HG Academy will notify the Data Subject and the Board as soon as possible so that necessary measures can be taken.
8. Deletion, Destruction or Anonymization of Personal Data
Personal data processed for the purposes specified in this Policy will be deleted in accordance with the principles and methods in the Guide to Deletion, Destruction or Anonymization of Personal Data published by the Institution, when the purpose that requires the processing is no more existent, when the retention periods determined by HG Academy have passed or when the periods determined by the legislation have passed. Personal data may reasonably and measurably continue to be used by being anonymized if deemed necessary.
9. Changes to the Personal Data Protection Policy
HG Academy may make changes in the Policy to the extent required by its activities or when legal or statutory requirements may arise. The said changes become valid with the publication of the revised text of the Privacy and Personal Data Protection Policy on the website www.hirmizygroup.com. In addition, employees shall be notified of the changes to be made by e-mail or by adequate announcement and notification means at the workplace.