Effective date: June 11, 2019

EVAM (“us”, “we”, or “our”) operates the https://evam.com website (hereinafter referred to as the “Service”).

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://evam.com

Definitions

Service
Service is the https://evam.com website operated by EVAM

Personal Data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies
Cookies are small files stored on your device (computer or mobile device).

Data Controller
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Cookies and Usage Data

Usage Data
We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Location Data
We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customise our Service.

You can enable or disable location services when you use our Service at any time by way of your device settings.

Tracking Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

Use of Data
EVAM uses the collected data for various purposes:

  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
If you are from the European Economic Area (EEA), EVAM legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

EVAM may process your Personal Data because:

  • We need to perform a contract with you
  • You have given us permission to do so
  • The processing is in our legitimate interests and it is not overridden by your rights
  • To comply with the law

Retention of Data
EVAM will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

EVAM will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

Transfer of Data
Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside Turkey and choose to provide information to us, please note that we transfer the data, including Personal Data, to Turkey and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

EVAM will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Business Transaction
If EVAM is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement
Under certain circumstances, EVAM may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements
EVAM may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of EVAM
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. EVAM aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Data.

The right of restriction. You have the right to request that we restrict the processing of your personal information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where EVAM relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics
We may use third-party Service Providers to monitor and analyse the use of our Service.

Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy
Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us
If you have any questions about this Privacy Policy, please contact us:

  • By email: info@evam.com
  • By visiting this page on our website: https://evam.com
  • By phone number: +90 216 455 01 53

Clarification Text for Employee Candidates about Processing of Personal Data

We respect the personal data we process and the data subjects when we, as Evam Yazılım Danışmanlık A.Ş. ("Evam/Company"), carry out our services and activities, and we show maximum sensitivity to the safety of personal data within the scope of current legislation and universal values. In this regard, we, as EVAM, care about the safety and confidentiality of all personal data of natural persons who apply as Employee Candidates to our Company.

Evam carries out personal data processing activities in line with the regulations in the Personal Data Protection Law no. 6698 (the "PDPL").

Data Supervisor

Subparagraph (a) of paragraph 1 in Article 10 of PDPL, which is titled "Clarification Obligation of Data Supervisor", imposes the obligation of providing information on the data supervisor's identity. In subparagraph (ı) of paragraph 1 in Article 3 of PDPL, the data supervisor is defined as "natural or legal persons who determine the personal data processing objectives and tools, and are responsible for installing and managing the data recording system". Evam will be the "data supervisor" in terms of implementing PDPL. In this framework, the "identity of data supervisor" is Evam which was founded to operate in the area of information services in line with the laws of the Republic of Turkey and survives uninterruptedly as a resident at the address of Atatürk Mah. Ertuğrul Gazi Sk. Metropol İstanbul Sit. A Blok Apt. No: 2E/13 Ataşehir/Istanbul.

Processed Personal Data

Job application can be made via (i) Linkedin, (ii) Direct application in person (iii) job application form on https://evam.com/, (iv) and CV collection through Reference and your processed personal data consist of:

  • in case of application through LinkedIn; the existing information in your CV when you make an application, association membership information in case it is identified in your CV, your personality inventory test results -which is conducted by the Company- in case your application is found suitable and you are invited for an interview, your online images and visual data in the case that you are invited to an online interview and security footage and visual data related to you in case that you are invited to an interview physically.
  • Directly by You or During the Process of Collecting CV through Reference; your name, surname, birthplace, contact information, military service status, driving license, marital status, residential address, education information, foreign language information, computer use and skills information, photo, occupation of the spouse if you are married and the number of children if you have any, work experience, information on courses and seminars attended, diploma, professional competence certificates, references, hobbies, skills, information on membership to an association if stated, name-surname and telephone number of a relative to communicate in case you are not reachable, your online images and visual data in the case that you are invited to an online interview, your personality inventory test results -which is conducted by the Company- and the security footage and visual data related to you in case that you are invited to an interview physically.
  • During the application process through the Job Application Form on https://evam.com/; your name, surname, contact information, association membership information in case it is identified, information in your CV, your LinkedIn profile address, and your personality inventory test results -which is conducted by the Company- in case that your application is found suitable and you are invited for an interview, your online images and visual data in the case that you are invited to an online interview, and security footage and visual data related to you in case that you are invited to an interview physically. 

Purposes of Processing Personal Data

Personal data are processed by Evam based on one or several of the personal data processing terms specified in Article 5 of PDPL in compliance with the personal data processing principles defined in Article 4 of PDPL. Evam also acts in line with all of the relevant obligations stipulated in the legislation especially the PDPL, Labor Law No 4857, and Turkish Code of Obligations no 6098 in all of its personal data processing activities. The personal data are processed within the scope of personal data processing terms and purposes defined in Article 5 of PDPL for the following purposes:

  • evaluating your job application, the invitation for an interview, assessment for suitable positions, and knowing the employee candidate better with reference to the cause of action for drawing up or executing a contract;
  • performing the interview process preferably online and assessing if your personality is suitable for the relevant position and working at our Company, and re-evaluating your job application for suitable positions for 1 year in the case that your initial application results negatively with reference to the cause of action regarding your explicit consent;
  • ensuring the security at the workplace and of the physical space, resolving conflicts and civil suits, making legal claims or filing suit or advocating, and performing the responsibility to present proof in a possible conflict with reference to the cause of action that data processing is compulsory for establishing, exercising and protecting a right;
  • performing the legal obligations stated in Labor Law no 4857 and the Turkish Code of Obligations no 6098 with reference to the causes of action that legal obligation is performed and explicitly stipulated in the code;

on condition that the information which can be required for Evam to carry out activities does not harm your fundamental rights and freedoms.

To Whom and for What Purposes We Can Transfer the Processed Personal Data

Your personal data collected can be transferred by our Company to Google and Zoom companies as data processors that are resident abroad and provide infrastructure services of platforms including Zoom and Google Meet to organize online interviews with your express consent in cases that such interviews are made on these platforms with your express consent within the framework of the personal data processing terms defined in the Article 9 of PDPL and by paying regard to data security measures.

Your personal data can be shared with law enforcement officers and capable public enterprises as per their legal requests to perform the legal obligations, and by abiding by the data security measures within the personal data processing terms and purposes specified in Article 8 of PDPL.

Methods We Use to Collect Your Personal Data and the Causes of Action

Personal data are collected verbally, in written form, or electronically based on the causes of action given below on the condition that you apply from LinkedIn, apply directly, through references, or by filling in the Job Application Form on the career application field shared on the website to draw up and exercise a labor contract. Personal data are processed as per the causes of action given as part of each data processing stage under the Purposes of Processing Personal Data within the scope of terms and purposes of processing personal data specified in Article 5 of PDPL.

The Rights of the Data Subject Stated in Article 11 of PDPL:

You can send your requests regarding your rights as per the PDPL to us: kvkk@evam.com Evam will conclude the request within the shortest time and in 30 (thirty) days at the latest depending on the request type. In case the action necessitates an additional cost, the fee in the tariff determined by the Commission For Personal Data Protection will be charged by us. The rights of real persons as per Article 11 of PDPL whose personal data are processed are as follows:

  • Learning if personal data are processed or not,
  • Requesting information if personal data are processed,
  • Learning the purpose of personal data processing and if these are used relevantly,
  • Knowing the third parties to whom personal data are transferred in the country or abroad,
  • In case the personal data are processed incomplete or incorrect, requesting their correction and demanding to inform third parties to whom personal data are transferred about the relevant action concordantly,
  • Requesting that the personal data are deleted or removed if the reasons necessitating the processing of personal data do not exist anymore although they have been processed in line with PDPL and other relevant provisions, and demanding to inform third parties to whom personal data are transferred about the relevant action concordantly,
  • Objecting to any consequences against the person by analyzing the processed data exclusively through automatic systems,
  • In case of loss due to the unlawful processing of personal data, demanding the indemnification of such loss.
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