KVKK

KVKK

POLICY FOR EMPLOYEES AND CANDIDATES REGARDING THE PROTECTION OF PERSONAL INFORMATION IN ACCORDANCE WITH LAW NUMBER 6698 ON THE PROTECTION OF PERSONAL DATA (“KVKK”)

We at OBSS TEKNOLOJİ A.Ş. (“OBSS”), located in Türkiye, represent the data controller for your business relationship with our company, which may be as employee, candidate, trainee, or CodeMaster participant. As such, we declare that all data will be processed adhering to the conditions stipulated by the KVKK, provided that necessary and adequate precautions are taken as described below. If such precautions are not explained, then you will be informed at another time in the process and this will be transferred, assigned, classified, and processed as outlined in the KVKK to other institutions with which we maintain contracts, to suppliers, and to business partners. This all takes place within a framework requiring that your personal data be processed when requested by OBSS and/or that you have otherwise shared with us, in line with the reasons you shared it and to a measured and limited degree.

PERSONAL DATA COLLECTED BY OBSS TECHNOLOGY

OBSS can legally process personal data provided by employees and candidates themselves or provided by the company from open or public sources.
Personal data that may be processed is listed below:

Information Related to Identity

Name, surname, date of birth, gender, identity number, nationality and any other identifying information included in the CV by the employee or candidate
Names and surnames of references

Communication Information

Home and personal mobile phone number, street address information, personal e-mail address.
Telephone number and e-mail addresses of references.

Special Categories of Personal Information

Disability status/definition/percentage if you are a disabled employee or candidate.
Association/foundation memberships or Blood Type, if disclosed by you in your resume, although not requested by us.

Personnel Information

Military information.
Driver’s license.
Areas of interest.
CV.

Education Information

Educational status, certificates and diplomas, foreign languages, education and skills, computer knowledge, courses taken, information regarding the dates of education and other education data in the CV.

Visual and Audio Information

Photographs of real people, video recordings.

Work Information

Department and position, title, last date of employment, previous employment/exit dates, flexible hours working status, travel status,
The reasons for leaving the workplace, the names of the companies worked for;
Number of working days, projects worked, notice period. Salary and fringe benefits at the last place of employment.
Internship information.

Purposes of Processing Your Personal Data

Your personal data will be processed by OBSS in order to provide products/services related to the activities of our company, to increase the quality of these products/services, to comply with how information is stored, reported and obligations regarding disclosure of information.
Your personal data will be retained for the maximum period specified in the relevant legislation or required for the purpose for which they are processed, and possibly for the legal statute of limitations.
The following are the purposes of processing your personal data:

The fulfillment of the main activities of the company:

To allow for job interviews by anonymously sharing candidates’ CVs with clients in order to direct resources to clients with which OBSS works,
Reviews of job interviews with clients,
To ensure communication with candidates,

To ensure security within the company:

To ensure workplace safety,
To maintain control over entrances and exits in controlled areas with cameras and visitor cards.
To request identification information by the building and/or OBSS reception for entrance into company headquarters.

The administration of the company, how business is conducted, and how company policies are enforced:

Identifying and inputting candidate information into the Human Resources system,
Ensuring that candidate data is kept up-to-date on the system,
Saving documents collected during the job applications and interviews of candidates,
Providing communication for company events,
Ensuring quality control,
Ensuring information is secure,
Communicating with relevant people in the case of an emergency,
Analyzing job interviews.

Collection Methods of Your Personal Data and Legal Reasoning

OBSS obtains personal data through electronic media such as e-mail, the internet, and other online platforms. The reasons for obtaining your personal data are as follows:
OBSS’s legitimate interest in selecting candidates who fit the company’s culture and position
OBSS’s fulfillment of its obligations within the scope of work and occupational health and safety, including but not limited to Labor Laws, Occupational Health and Safety Laws, Social Insurance and General Health Insurance Laws, and undertaking all obligations required by such legislation
If the data you share with us includes sensitive personal data and we do not need to process this data, it is obtained if you give your explicit consent.

Protecting Your Personal Data and Sharing it with Third Parties in Türkiye

OBSS personal data may be shared in order to meet procedural and legal requests from public legal entities such as the Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu), the Information Technologies and Communication Authority (Bilgi Teknolojileri ve İletişim Kurumu), and Technoparks where the institution is located. It may be shared with other institutions and organizations to fulfill all occupational health/safety obligations as well as legal obligations as required under the Law on Protection of Personal Data No. 6698, Labor Laws, Occupational Health and Safety Laws, Social Insurance and General Health Insurance Laws, the Turkish Commercial Code, and the Regulation of Publications Made on the Internet and Fighting Against Crimes Committed Through These Publications. Sharing may be done to the extent required by all legislation including, but not limited to, the regulations listed above.

Other that this, your personal data may be shared with OBSS’s domestic clients and business partners in a limited and measured manner for the purposes specified in this document and in accordance with the specific activities undertaken by OBSS as provided below.

Fulfillment of the company’s defined goals and purpose:

Information shared by the candidate may be processed and saved in various in-house software programs in order to carry out processes such as candidate identification, technical and Human Resources meetings, and client interviews. This information is stored in the applications’ own data recording platform and OBSS devices.
Since the references shared by the candidate are required for the purpose of research, information may be shared with the relevant company/person in the reference.
If the company employs the candidate for a client’s project, your candidate data may be shared with the relevant authorities of said client.

Fulfilling our legal obligations:

In order for us to exercise our right to defend ourselves from legal wrongdoing, information may be shared with our lawyers and relevant institutions within the framework of our obligation to fulfill legal requests, such as a court decision or a request for evidence, provided that it is in accordance with the law and all forms of common procedure.

Administration of the company, the conduct of the business, and enforcement of company policies:

We may forward your requisite personal information to companies we work with for reasons such as transportation, accommodation, or vehicle supply.

Sharing Your Personal Data with Third Parties Abroad

Your personal information may be shared and transferred abroad in a limited and measured manner, provided you have given your explicit consent, using overseas-bulk e-mail delivery providers and potential customers with whom the eligible employee or candidate may be able to work with. The potential reasons that the personal information of eligible candidates may be provided to third parties abroad include, but are not limited to: providing training/seminars, setting up job interviews with customers/business partners, providing communication for international travel and organization thereof, including to travel agencies based abroad and to companies that provide services for organizing travel, and to sending bulk e-mails.

Your Rights Enumerated in Article 11 of KVKK

By applying to our company, you have the right to do the following regarding your personal information:
a) to learn whether it has been processed,
b) to request information regarding how it has been processed,
c) to learn why it has been processed and whether it has been used in accordance with the company’s aims and goals,
d) to learn whether it has been transferred to third parties either in Türkiye or outside of it,
e) to request a correction if it has been incorrectly processed or if it is incomplete,
f) to request it be deleted or destroyed within the framework of the conditions stipulated in Article 7 of the KVKK,
g) to request notification of the transactions made in accordance with subparagraphs (e) and (f) above, to the third parties to whom it has been transferred,
h) to object to a rejection notice or any other negative result against you personally due to an automated analysis with no human or subjective input,
i) you have the right to demand compensation for damages if you suffer legally qualifying damage due to unlawful processing.
You can always contact us by sending an e-mail to kisiselveri@obss.com.tr to exercise your rights set forth in article 11 of Law No. 6698. You can also use other communication methods stipulated in Article 5 of the Communiqué on Application Procedures and Principles to the Data Controller (Veri Sorumlusuna Başvuru Usul ve Esasları Hakkında).
If you suffer damages due to the unlawful processing of your personal data, you may request compensation for those damages.
Requests made will be concluded free of charge within thirty days at the latest, depending on the nature of the request. However, if the transaction requires a separate cost for OBSS, it is possible that a fee in the tariff as determined by the Personal Data Protection Board may be charged.

CONTACT INFORMATION

OBSS TEKNOLOJİ A.Ş.

Mersis No: 0633087578400001
Contact Address: İstanbul Sanayi Mah.Teknopark Bulvarı No:1/8a Blk.3.Kat 8301 Kapı No 34906 Pendik/İstanbul
Contact Link: https://obss.tech/ , kisiselveri@obss.com.tr Telefon : +90 216 688 3436

Express Written Consent – Processing Personal Information

If you are an OBSS employee, candidate, or trainee candidate, OBSS Teknoloji A.Ş., located at İstanbul Sanayi Mah.Teknopark Bulvarı No:1/8a Blk.3.Kat 8301 Gate No 34906 Pendik/İstanbul. (“OBSS”), has prepared this Express Written Consent Form in order to obtain your consent to forward your personal information abroad.
 
This form has been prepared within the framework of the Policy Regarding the Protection of Personal Information (“Policy Text“). We would like to warn you not to sign this form without reading the Policy Text.
 
When you give your personal information either verbally, written or electronically, you are entitled to participate in activities such as training/seminars to be held outside of Türkiye, and to be managed as a candidate/trainee/CodeMaster participant by OBSS. If you are eligible, your data may be shared with customers, business partners, or service providers abroad so that you can have business meetings with OBSS’s customers and business partners abroad, and your data may be shared with foreign-based e-mail delivery providers so that e-mails can be sent to you.
 
If you choose not to allow your information to be passed on, you will not be eligible for projects related to customers outside of Türkiye, and you will not be able to benefit from overseas education opportunities or be able to receive e-mails from us.
All potentially sensitive information will be processed in line with the purposes outlined and the limits specified in the OBSS Policy Text. This information may include, but is not limited to, data regarding any association or foundation memberships you may disclose or may legally be required to disclose, any health information you provide including blood type, and any photographs you provide that may contain sensitive information.
 
If you choose not to allow this type of information to be processed in line with the law, we may not be able to hire you as a candidate or to process the relevant information.

Retention of Data After the Job Interview Process – Express Written Consent

If you are an OBSS employee, candidate, or trainee candidate, OBSS Teknoloji A.Ş., located at İstanbul Sanayi Mah.Teknopark Bulvarı No:1/8a Blk.3.Kat 8301 Gate No 34906 Pendik/İstanbul. (“OBSS”), has prepared this Express Written Consent Form in order to obtain your consent to forward your personal information abroad.
 
This form has been prepared within the framework of the Policy Regarding the Protection of Personal Information (“Policy Text“). We would like to warn you not to sign this form without reading the Policy Text.
 
If your are not hired in any capacity following the job interview process, then the purpose of processing your information is no longer valid and your personal information may only be stored for the maximum allowed period as stipulated under the Law on the Protection of Personal Data No. 6698. For this reason, your consent is requisite in this form in order for OBSS to continue to store your personal information for the purpose of contacting you should a suitable position arise.
I have read the above forms and understand them in their entirety.
 
Should the job interview process result in me not be hired in any capacity, my personal data may be stored by OBSS in the case that a new position may arise and that they are able to contact me using the information I provide. I give my express written consent for OBSS to store my personal information for this explicit purpose.

This Privacy Policy Regarding the Processing of Personal Data for Remote Online Exams (“Privacy Policy”) has been prepared by OBSS Teknoloji A.Ş (“OBSS”). OBSS has prepared this Privacy Policy to provide information regarding how data is collected, processed and transferred during any exam which may be held online, and regarding the Remote Monitoring application for this exam (“Application”). The protection of your personal data and confidentiality are of utmost importance to OBSS. OBSS will do its utmost to keep your personal data confidential, and to take all necessary technical and administrative measures and to show due diligence for ensuring confidentiality and security.
 
The collection, use and sharing of personal data within the framework of the services provided by OBSS or its affiliates are subject to this Privacy Policy and its updates.
OBSS will not transmit or make your personal information available to third parties, except in the case of the explicit exceptions listed in this Privacy Policy.
 
In the processing of your Personal Data, OBSS acts in accordance with any and all data processing principles and obligations set forth in the relevant legislation, in particular those listed in the Constitution of the Republic of Türkiye, as well as any international agreements to which Türkiye is a party, and the Law on the Protection of Personal Data No. 6698 (“KVKK”).
 
This Privacy Policy relates exclusively to Remote Monitoring. Please read the Privacy Policy for how personal information is processed.
 
1. How Personal Information is Obtained

For both remote monitoring and providing this exam remotely, we process the following data:
1.1. Identity Information: Your name and surname
1.2. Exam Monitoring Data may include: Photographs of the setting in which the exam is taken along with people who take the exam, audio recordings, video recordings, movements of a computer mouse, internet sites opened (ie web traffic), system requirements, screen recordings to ensure that each candidate is tested and evaluated under equal conditions.
1.3. Exam Result: Your answers to exam questions and their results.
(All of the data listed above will be referred to as “Personal Data” in the text.)
 
2. Methods of Obtaining Your Personal Data and the Legal Reasoning Underpinning Them

Once you have provided your express written consent through the Remote Monitoring Application, then your personal data will be instantly obtained. This remote monitoring is requisite to ensure that the examination is undertaken in the proper circumstances, with equal chances for all participants and for the subsequent potential for recruitment to continue without discrimination. You may not take the online exam without consenting to the Remote Monitoring application. However, if you have problems, requests or questions regarding Remote Monitoring or your participation in the exam, you may reach us by sending an e-mail to OBSS hr@obss.com.tr and you can take a supervised online exam instead at OBSS headquarters in Istanbul with a computer provided by OBSS. You may request it to be done on a day and time determined by you.
 
Your exam results may be obtained following our assessment of whether you have the necessary competencies for recruitment. The examination will necessarily have been conducted in accordance with our legitimate interest in hiring an employee based on our criteria, which may or may not be reflected in the overall exam results.
 
3. Purposes for Processing Your Personal Data

The Personal Data that you may provide within the scope of the application will be used in order:
3.1. To prevent cheating in the exam and to ensure exam security
3.2. To ensure that every candidate competes on equal terms
3.3. To identify the qualifications required for recruitment 
 
4. The Transfer of Your Personal Data

Your personal data will be seen and processed by a limited number of authorized OBSS employees and will not be transferred to third parties. However, if cheating is detected in the exam, detailed information may be provided to people involved in the employment process regarding your job application. Likewise, in the event that a legal process begins following any form of alleged fraud or deception, detailed information may be shared with our lawyers and legal advisors and relevant legal institutions so that our right of defense may be appropriately exercised.   
 
5. Processing Time for Your Personal Data

Video and sound recordings taken during exam monitoring will be destroyed within one (1) month. Other Exam Monitoring Information will be kept inactive so that it may only be accessed by the system administrator when necessary, and will not be accessed or processed by anyone except in the even that it is legally obligatory. All data will be destroyed when the statute of limitations for legal disputes that may arise regarding said recruitment process expires.
The results of your exam will be retained for the minimum period required for employee data in the event that you are hired. If you are not hired, it will be retained until the statute of limitations no longer applies in order to preserve our right to defend ourselves in the event of legal action.
Pursuant to the Law on the Protection of Personal Data, when you request that your personal data be deleted or erased, the legal purpose of processing Personal Data must no longer be applicable, the legal retention periods must have expired, or the relevant statute of limitations must have passed in order for this request to be fulfilled. Your request may not be fulfilled in the event that none of these periods have expired.
 
6. Data Security
Remote Monitoring data will be stored encrypted and may only be accessed and analyzed by a limited number of people. This data is stored and processed using technical and administrative measures at the highest security levels used in OBSS’s systems, and makes full use of risk assessment studies, as well as privacy-by-design or by default studies as they relate to Remote Monitoring data.
Your exam results are protected by a full range of technical and administrative measures taken by OBSS within the framework of its security policies, many of which are required by law.
 
7. Your Rights as a Data Owner under KVKK
You have the legal right to discover the following regarding your Personal Data by asking OBSS:
7.1. To learn whether it has been processed or not,
7.2. To request information regarding how it has been processed,
7.3. To learn why it was processed and whether it was used in line with the legally stated purpose for acquiring it,
7.4. To learn whether and to which third parties any data has been transferred to, both inside Türkiye and out of the country,
7.5. To request that incorrect information is corrected if it is either incomplete or if it has been improperly processed,
7.6. To request that information be deleted or destroyed within the framework of the conditions stipulated in accordance with the legislation on the protection of personal data,
7.7. To request notification of any and all transactions made pursuant to subparagraphs (7.5) and (7.6) above, to the third parties to which any data may have been transferred,
7.8. To object to the emergence of a purely objective automated result you deem to be incorrect, and
7.9. You reserve the right to demand compensation for damages in the event that you suffer damages due to the unlawful processing of data. 
 
8. Changes to Our Privacy Policy
OBSS reserves the right to review and amend this Privacy Policy at any time. If the Privacy Policy changes, the edited policy will be uploaded to the Application.  
 
9. Questions
If you have any questions, complaints or comments within the scope of the Privacy Policy or the Application, or if you want to remove yourself from the communication network, you can contact us via the contact information listed below.
OBSS Teknoloji A.Ş
Sanayi Mahallesi Teknopark İstanbul No:1/8A Blok 3. Kat 8301 Kapı No Pendik/İstanbul
+90 (216) 688 34 36
hr@obss.com.tr 

Candidates can log in to the exam system, which they can access by clicking this link, using the username and password provided to them. In order to use the system, they must use the browser Google Chrome 72 and above. It is not possible to start the exam using a browser other than Google Chrome, including Firefox, Internet Explorer, Edge or Safari.
Before starting the exam, candidates are required to install the necessary Google Chrome plug-in as directed by the exam system and accept the permissions requested by the plug-in. Before the exam, you may check whether the requirements for the plugin have been met or not. In case of problems with the plugin, support can be obtained through this link.
The exam will take place over two sessions, the first session is for measuring the technical knowledge of the candidate, and the second session is for measuring the general ability and knowledge of the candidate. In the first session, there are 45 questions given over 37 minutes allocated to complete them. In the second session, there are 10 questions and 23 minutes allocated to complete them. Each session’s results will be evaluated separately and both sessions are expected to be completed within the time allowed for the candidate. The candidate may take a break between the two sessions, provided that he/she has completed both sessions within the specified time. However, the sessions may not be broken up and no breaks are allowed during a session.
During the exam sessions, a set of activities undertaken on a computer may be recorded, including movements of the computer mouse, keyboard, camera images, and sound from the microphone. This is done in order to ensure that the exam is undertaken in accordance with the rules, and analyses can be made automatically and/or manually using this recorded data. Candidates are deemed to have accepted the collection and storage of such data collected during the exam for the purpose of checking the validity of the exam.
The computer upon which the exam is taken must have a working camera and microphone. In order to avoid any connection problems during the exam, we recommend an internet connection with a minimum download speed of 8 Mbps and an upload speed of 1 Mbps.
Considerations and rules to be followed during each session of the exam are listed below. OBSS has the right to invalidate the exams of the candidates who are found to not comply with any of these rules.

Considerations and Rules to Be Followed During the Exam


a) Each session of the exam must be completed within the allotted time, and unanswered questions or incorrectly answered questions will not otherwise have any effect on the scoring. Candidates may skip any question that they do not want to answer during the session, and then return to this question to be answered later during the session. Questions that are skipped without being answered during the session do not automatically count as a wrong answer in the exam’s interface.

b) Each session of the exam must be completed within the allotted time without interruption. Necessary precautions should be taken before the exam session for preventable situations such as running out of computer battery. In the event that the exam session ends due to unforeseen reasons (power cuts, etc.), this should be reported to OBSS Human Resources.

c) The setting of the online exam should be a quiet, calm and closed area with no other people. During the exam, no other people or pets should enter or leave the environment where the exam is being taken.

d) Music should not be playing using either headphones or speakers during the exam. Television or other sound-producing electronic devices must be turned off completely before the exam.

e) No food or drink should be consumed, including gum, during the exam.

f) Cell phones should not be used for any reason during the exam, and candidates should not talk to anyone in the environment or to themselves outloud.

g) Other than the browser window used to access the exam itself, all other applications should be closed, and no window or tabs should be open other than the browser window from which the exam system is accessed during the exam. In addition, if there are applications running in the background and using an internet connection, these too should be closed.

h) No printed or digital information sources are to be used during the exam.

i) Sit directly in front of the computer monitor from which the exam system is accessed. If an external camera is used, this camera should be positioned in the middle and above the monitor on which the exam is displayed so that the candidate may be seen clearly and recognizably. During the exam, as much as possible, candidates should not look beyond the monitor from which they are accessing the exam.

j) While the exam session is in progress, candidates should not leave the monitor for any reason.
The environment during the exam should be bright enough that the candidate’s face and movements can be clearly seen on the camera.

k) During the exam, candidates should not take screenshots or record images of the exam system from their computer.

l) In the event of an unexpected problem during the exam, support is available by e-mailing hr@obss.com.tr.

The OBSS Remote Monitoring system will record your session for potential review. These records will be encrypted and only authorized users will be able to access these records. The recording types listed below will only begin after we identify your system and environment.
 
The OBSS Remote Monitoring system will activate the following applications for security measures.
 
For more information, please see our Privacy Policy.
 
Remote monitoring is necessary to ensure equality in examination and recruitment and to prevent discrimination. You may take the online exam without consenting to the Remote Monitoring application. However, if you have a problem with Remote Monitoring and participation in the exam, you may e-mail us at hr@obss.com.tr and you may take your online exam in the Istanbul headquarters of OBSS with an in-person supervisor present, on a computer provided by OBSS. You may request this for a specified day and time of your choosing.
 
I understand and accept the exam rules and consent to the processing of my above-mentioned data in the manner and for the purposes set out in the Privacy Policy, and to the processing and transfer of it to overseas servers, including Amazon, at the Company’s discretion. This consent is valid only for the data specified in the table above, it does not cover the processing of any other data not mentioned above, nor does it cover other data categories such as exam results or the identity information in the Privacy Policy.