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

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FlowQ Talent Management Systems Inc. ("FlowQ", "We" or "Company") takes maximum care to ensure the privacy of your personal data as our users. In order to conduct data processing activities in compliance with data protection legislation, including the Law No. 6698 on the Protection of Personal Data ("Law"), and to inform you about our personal data processing processes, we have prepared this privacy policy. As we provide human-focused services such as data-based psychometric services, personal data processing activities form the basis of our services. Therefore, we recommend that you read this Privacy Policy to be informed about how your personal data is processed, to whom it is transferred, the legal reasons for processing purposes, and the methods of collection.

 

FlowQ can process personal data of users of our services such as talent tests, personality inventories, visitors to our website, and representatives of companies that receive services from us (" data owner"), for the purposes of managing our business activities, providing our services with the desired quality, and managing our website, among others, without being limited to the mentioned purposes. You can find more detailed information about how we obtain your personal data, the parties to whom your personal data is transferred, and your rights arising from the Law below.

 

At this point, we would like to emphasize that our company retains control over the unanalyzed or uninterpreted data pertaining to the tests conducted by our company. However, once the reports based on these test results are transmitted to the company that requested the test, that company will become the data owner.

 

Which data of yours are we processing?

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"Personal data" refers to information that can identify or be used to identify an individual. In this context, some examples of personal data that can be processed by FlowQ are listed below:

• Identity and Contact Information: Name, surname, Turkish identification number, email address, mobile phone number, date of birth, nationality.

• Education and Employment Information: Undergraduate education information, after graduation work experience years, job and internship experience information, certifications.

• Test Results: Records of the questions answered by the user in online/offline tests and evaluation results, all assessments conducted, user's abilities, values, and psychological competencies, and all reporting related to this process.

• Visual Proctoring Records of Tests : Image recordings taken from the user's camera during online/offline tests for test security purposes.

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How do we obtain your personal data?

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Our company can obtain and transfer various personal data of data subjects who interact with our company, in accordance with Articles 5 and 6 of the Law, or with your explicit consent when necessary, through different channels and methods, both internal and external to the company. For example:

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• We can collect your personal data during online/offline tests prepared by our company. Prior to your participation in these tests, we can request you to fill out various forms, through which we can collect your personal data.

• During certain tests, the use of cameras can be necessary for purposes such as identifying the person taking the test and determining if there is anyone else present with them. Additionally, the use of cameras can be required for the purpose of conducting interviews or answering questions transmitted by the company you have applied to for a job. Visual and audio data can be collected from these camera recordings.

• Information related to the devices used during the collection of visual and audio data, such as computer, phone, and other devices (such as operating system and browser version), as well as IP address (which can be used to obtain general location information at a city or country level), can be collected.

• We can process your personal data as a result of the analyses conducted at the end of the tests. Through these analyses, we draw various inferences about your cognitive abilities, values, competencies, skills, and personality tendencies. As a result, we obtain your personal data through the analysis services we provide.

• As part of the human resources consulting services we provide, we conduct tests for candidates. Therefore, your personal data can be shared with us by the company you work for directly.

• The companies you have applied to can enter your information into their candidate management systems and create a profile for you. This profile can be accessible by the companies you have applied to in the future, with your consent.

• During your use of our website and mobile application, we can collect your personal data. For example, we can process your personal data through online technologies such as cookies, process identity and contact information you share with us through communication forms, or process data related to your requests through emails you send to us.

• We can obtain information related to representatives of companies who wish to benefit from our services. Such information can be obtained through channels such as documents, email, or phone calls as part of the contract process.

• If you give us your consent for commercial communication permission, we can process your identity (name, surname), statistics related to your use of FlowQ mobile applications, CV information, and contact information (phone number, email address) for the purpose of sending general or personalized campaigns, advantages, promotions, advertisements, notifications, marketing activities, and commercial communications (such as SMS, email, calls, etc.) related to our products and services, as well as customer satisfaction surveys, campaign, contest, invitation, opening, and other event invitations.

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Purposes of data processing

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As the data controller, we process personal data based on at least one of the legal data processing grounds defined in Turkish Law of Personal Data Protection Law (KVKK) Article 5 and Article 6 of the applicable data protection laws, or with your explicit consent when necessary, during inventory tests conducted by FlowQ via information collection channels and through various written, verbal, electronic means, either fully automated, partially automated, or non-automated methods. Therefore, when processing your personal data, we rely on at least one of the following data processing grounds:

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• Processing of personal data being necessary for the performance of a contract to which the data subject is a party or for taking steps at the request of the data subject prior to entering into a contract.

• Processing of personal data being necessary for compliance with a legal obligation to which the data controller is subject.

• Processing of personal data being necessary for the establishment, exercise, or defense of legal claims.

• Processing of personal data being necessary for the legitimate interests pursued by the data controller, provided that such processing does not harm the fundamental rights and freedoms of the data subject.

 

Within this scope, your personal data will be processed primarily for the purpose of providing our services adequately and conducting our business activities. The processing purposes of your personal data within this framework are as follows:

 

• In order to fulfill our obligations towards our customers, in connection with the relationship established for the purpose of using the applications with us; within this scope, processing of tests provided by us, conducting analysis on test results, evaluating test results, and transparently reporting on these results, including your identity and contact information, as well as your visual and auditory data, can be processed.

• In order to perform accurate psychometric measurement and reporting specifically for you (determining the correct norm group), your data can be processed.

• In order to manage requests and complaints, such as delivering price quotations for services requested from us, evaluating and responding to complaints submitted to us; your identity and contact information, <results, and data related to user registration can be processed.

• We can send promotional messages to introduce our new products and services, campaigns, events, or other products and services that can be of interest to you, and process your identity and contact information for this purpose.

• Your data can be processed for the purpose of sending updates and messages related to the services and products you have obtained from us, as well as communications related to the contract between you and us.

• We can process your personal data to improve and enhance our current products, potential products, website, and business activities. This can include conducting satisfaction surveys, sending forms to gather feedback from you, and processing your data based on the relevant results.

• Your data can be processed for the purpose of conducting accounting and financial processes after the tests are conducted.

• Your personal data can be processed for the purpose of exercising and protecting the rights owned by our company, including, for example, collection processes.

• We may process your personal data as stated in this Privacy Policy for the purpose of fulfilling our legal obligations, such as responding to information and document requests from authorized public authorities, and detecting unauthorized and fraudulent access, without harming your fundamental rights and freedoms.

 

The parties to whom the data is transferred and the reasons for the transfer

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We can transfer your personal data to third parties in compliance with the legislation in certain situations. However, we would like to emphasize that FlowQ does not sell, rent, or use any personal data, including psychometric assessments belonging to you, for unfair commercial gain.

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Instances where your personal data is transferred

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• We can share the results of the analytical services we provide with the relevant departments of the companies you work for, which receive services from us. In this case, the parties to whom the test results are transferred will be the data controllers for personal data processing activities related to test results.

• If you give your consent for your candidate information held by us to be visible to other companies you apply to in the future, we can share your information with these companies in accordance with your consent. In this context, we also inform you that the information shared after obtaining your consent can be processed within the organizations of other companies you will share it with in the future.

• We can share your data with technology supply companies due to outsourced IT services provided to our company.

• In accordance with our legal obligations, we can share your personal data with authorized institutions. For example, your information can be shared with public institutions or authorized private organizations in order to respond to information and document requests made by them, or we can share your information with tax offices in accordance with our tax obligations. Additionally, we can share your information with courts, law firms, or execution offices for the purpose of exercising and protecting the rights of our company.

• In order to comply with applicable laws and regulations, including responding to law enforcement or government agencies, we can share personal data in the context of current legal processes and procedures, or participate in them. We can also investigate or respond to potential violations of our Service Terms or policies, including situations that threaten public safety, and prevent or investigate potential fraud, abuse, or concerns related to safety and security. Additionally, we can fulfill our corporate and social responsibility commitments, protect our rights and property, and resolve disputes and enforce contracts by sharing personal data.

• In the event of our company being acquired, merged, or separated, your personal data can be transferred to the relevant parties involved in the transaction.

• Your personal data, including personality inventory, general aptitude tests, application forms, surveys, games, and other applications within FlowQ system, can be made accessible to other employers who are members of the FlowQ system for a limited period of time, with the purpose of providing you with opportunities for suitable job positions based on the information gathered. Upon giving your consent for such sharing, you are also notified that the shared information can be processed within other companies you share your information with in the future.

• Under this Agreement, the Personal Data and User Content obtained by FlowQ can be processed and stored by FlowQ, and as a result, your data can be transferred to any location within or outside of Turkey, including servers of service providers and business partners located abroad. The countries where we process data can have different legal regulations than your country, and these regulations can not be as protective as the regulations in your country.

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Data ownership rights

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According to Turkish Law of Personal Data Protection Law (KVKK) Article 11, you have the following rights regarding your personal data.

 

• To learn whether personal data is being processed or not,

• To request information if personal data has been processed,

• To learn the purpose of the processing of personal data and whether they are being used for their intended purpose,

• To know the third parties to whom personal data is transferred, whether domestically or abroad,

• To request the correction of incomplete or inaccurate personal data, and to request that such corrections be notified to third parties to whom your personal data has been transferred, in cases where applicable,

• To request the deletion or destruction of personal data in accordance with the conditions specified in Article 7 of the Law,

• To request that the processes performed for the correction, deletion or destruction of personal data be notified to third parties to whom personal data has been transferred, in cases where applicable,

• To object to the occurrence of a result against the person arising from the analysis of the processed data exclusively through automated systems,

• To demand compensation for damages in case of suffering damages due to the unlawful processing of personal data.

 

You can submit your requests regarding the rights listed above to the email address [email protected]. Depending on the nature of your request, your applications will be concluded free of charge as soon as possible and no later than thirty days; however, if the process requires an additional cost, you can be charged a fee according to the tariff determined by the Personal Data Protection Board.

 

According to the Communique on Principles and Procedures for Application to the Data Controller, it is mandatory for the Data Subject to provide the following information in their application: name, surname, signature if the application is in writing, T.C. identification number (passport number in case the applicant is a foreigner), residence or workplace address for notification, if available, the email address for electronic notification, phone number, and information regarding the subject of the request.

 

After your personal data is anonymized, it can be used within the scope of our statistical, analytical, and business development activities. When your personal data is anonymized, the relationship between your information and you is irreversibly severed, and the personal data nature of this information is eliminated. Your anonymized information can be used in creating norms for statistical calculations and contributing to the more accurate functioning of our system.

 

* In case of any conflict between the Agreement, the provisions of the Agreement shall prevail. In case of any conflict between the versions of the Agreement in different languages, the Turkish version prevail.

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Contact Information:

Email: [email protected]

Address: Altunizade Neighborhood. Kısıklı Street. 2 Floor 3 Üsküdar/İstanbul/Türkiye