​You can find the Turkish version of this privacy notice here. 

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Data Controller

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FlowQ Yetenek Yönetim Sistemleri Anonim Şirketi ("FlowQ", "We" or the "Company") takes utmost care to ensure the privacy of our users’ personal data. We have drafted this privacy notice to conduct data processing activities in accordance with the data protection legislation, particularly the Personal Data Protection Law No. 6698 (the “Law”) and to inform you about our personal data processing processes. Since we offer people-oriented services such as data-based psychometric services, personal data processing activities constitute the basis of our services. Therefore, we recommend you read this privacy notice to be informed about how your personal data is processed.

 

FlowQ, will process the personal data of:

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• users of the services we provide such as ability or value tests;

• of our website’s visitors and

• of representatives of companies receiving services from us ("data subjects")

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for the purposes such as management of our business activities, to provide our services in highest quality possible, and management of our website. You can find detailed information on the purpose of our data processing activities, how we collect your personal data, the parties to which your personal data is transferred to and your rights arising from the Law, below.

Importantly, we would like to point out that the raw data collected through personality tests we have conducted which have not yet been analyzed or interpreted are under our Company’s control. However, at the point where the reports generated as a result of the tests are forwarded to the companies requesting the test, the data controller would be the company which have received the finalized test results.

 

How we Collect Your Personal Data?

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We may collect various personal data of data subjects who interact with our Company through different channels:

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• We may collect your personal data during the online / offline tests prepared by us. We ask you to fill out various forms before you participate in these tests, we may collect your personal data via these forms.

• During some tests, it may be necessary to use the camera for purposes such as to determine the identity of the test subject and whether someone else is with you or not. In addition, it may be necessary to use a camera to attend interviews organized by the company you apply for a job or answer questions to be submitted by aforementioned company. Your visual and audio data might be collected via these camera records.

• We may process your personal data as a result of the analysis carried out at the end of the tests. As a result of these analyses, we reach various conclusions about your abilities, values, and psychological competencies. Consequently, we collect your personal data by means of analysis services we offer.

• Since we conduct tests aimed at employees within the framework of the human resources consultancy services that we offer, your personal data might be shared with us directly by the company you work for.

• The companies to which you have applied enter your information to the candidate management systems and create a profile of yours. Based on your prior consent, this profile could become accessible by companies you have applied for in the future.

• We may collect your personal data during your use of our website. For example, we may process your personal data via online technologies such as cookies, we may process your information such as identity, contact information that you share with us via contact forms, or we may process your data regarding your requests you send to us via e-mails.

• We may collect the information of the representatives of companies which want to use our services. Such information might be collected through channels such as printed documents, e-mail correspondence or telephone calls within the contract processes.

 

As a data controller, we may process personal data only in cases where one of the legal conditions for processing data defined in the Law exists. Therefore, we rely on at least one of the following data processing conditions when we process your personal data:

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• Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract.

• It is necessary for compliance with a legal obligation to which the data controller is subject.

• Data processing is necessary for the establishment, exercise, or protection of any right.

• Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.

• Explicit consent of the data subject.

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Data processing purposes

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Under this heading, information on the purposes of processing your personal data is provided. Your personal data will be processed primarily for the purpose of providing our services properly and conducting business activities. Within this framework, the purposes of processing your personal data are as follows;

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• Your data may be processed for the performance of our obligations to our customers who have entered into a contractual relationship with us; carrying out the tests provided by us in this context, performing analysis of test results, the evaluation of test results and reporting of these results to our customers,

• Your data may be processed in order to make accurate psychometric measurement and reporting (determining the right norm group) specifically for you,

• Your data may be processed for the purpose of managing possible request and complaints, for example, for the delivery of price offers for the services requested from us, for the evaluation and response of complaints submitted to us,

• If you have consented, we may send you promotional messages about our new products and services, campaigns, events or new products and services that will attract your attention,

• Your data may be processed for the purpose of sending updates about the services and products you have already procured from us, and messages regarding our contract with you,

• We may process your personal data to develop and improve our current or potential products, website and business activities, in this context, we may conduct satisfaction surveys and submit forms to get feedback from you,

• Your data may be processed to carry out accounting and finance processes,

• Your personal data may be processed in order to exercise and protect the rights of our Company, in this context, for example, for debt collection processes,

• We may process your personal data to fulfill the legal obligations we are subject to, for example, to respond to requests for information and documents submitted to us by authorized public authorities.

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After your personal data is anonymized, it can be used within the scope of our statistics, analysis, and business development activities. When your personal data is anonymized, the relationship of your information with you is irreversibly removed and the personal data nature of this information is eliminated. Your anonymous information can be used in norms creation to make statistical calculations and contribute to the more accurate operation of our system.

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Recipient parties and purposes for transferring personal data

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In certain cases, we may transfer your personal data to third parties. However, first, we would like to state that FlowQ does not sell, rent, or use it to obtain an unfair commercial gain any personal data, including your psychometric evaluations. The situations where your personal data is transferred;

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• We may share the results of the analytical services we offer with the relevant departments of the companies that get services from us and that you work with. From this point on, the data controller in the personal data processing activities related to the test outputs will be the parties to whom the test results are transferred.

• If you approve that your candidate information held by us can be visible to other companies you apply for in the future, we may share your information with these companies in accordance with your consent.

• We may share your data with technology supply companies due to the external service purchases that our company makes regarding information technology systems.

• We may share your personal data with authorized institutions within the framework of our legal obligations. For example, your information may be shared with these institutions in order to respond to information and document requests made by public institutions or authorized private institutions or in accordance with our tax obligations, we may share your information with tax authorities. We may also share your information with courts, law offices, or enforcement offices to exercise and protect the rights of our Company.

• In case our company is taken over, merged or separated, your personal data may be transferred to the parties of the relevant transaction.

• Provided that you have given your explicit consent, your personal data and your reports based on a personality inventory that you fill in via FlowQ applications, general ability test, application form, questionnaire, game and other applications that are not mentioned here can be made available for a limited time to other employers who are members of the FlowQ system so that you can benefit from suitable job positions that we think will be appropriate for you in line with this information.

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Data subjects' rights

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As personal data subjects, we hereby declare that you are entitled to the following rights, set forth under Article 11 of the Law.

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• To learn whether your personal data are being processed,

• To request information if your personal data have been processed,

• To learn the purpose of the processing of your personal data and whether they have been used accordingly,

• To learn which third parties domestic or abroad your personal data has been transferred to,

• To request rectification in case your personal data has been processed incompletely or inaccurately,

• To demand the erasure or destruction of your personal data,

• In case your personal data are rectified, deleted, or destructed, to demand the operations in this regard be reported to third parties your personal data has been transferred to,

• To object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems,

• To demand compensation for the damages that you have suffered as a result of unlawful processing of your personal data.

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You can send your applications regarding your rights listed above to [email protected]. Depending on the nature of your request, your application will be concluded as soon as possible, within 30 days at the latest and free of charge; however, if the process requires additional costs, a fee may be demanded from you according to the tariff determined by the Personal Data Protection Board.

 

Our contact details:

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E-mail: [email protected]

Mail: Altunizade Mah. Kısıklı Cad. 2 Kat 3 Üsküdar/İstanbul