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Personal Data Protection and Privacy Policy At “DERE INVEST”, we attach great importance to the security and confidentiality of your personal data. This document has been prepared to explain the scope, purposes, and legal bases of the processing of personal data for visitors to our website and for job applicants, the conditions of data transfer, and your rights as data subjects. Acting as the data controller, we commit to full compliance with all applicable legislation, notably the "Turkish Personal Data Protection Law No. 6698 (KVKK)" and the "European Union General Data Protection Regulation (GDPR)" . 1. Data Controller and Representative Your personal data is processed by DERE INVEST, acting as the data controller, whose details are provided below: "Company Title:" DERE INVEST LTD” 2. Categories of Personal Data Processed, Purposes, and Legal Bases Your personal data is processed for the purposes and based on the legal grounds specified below. a) For Website Visitors Data Category Purpose of Processing Legal Basis Identity Information (Name, surname) To respond to your requests and queries submitted via the contact form. Legitimate interests of the data controller (establishing communication), provided it does not harm the fundamental rights and freedoms of the data subject. Contact Information (Email, phone) To respond to your requests and queries; to send informational communications (e.g., newsletters, subject to consent). Explicit consent for contact forms; legitimate interests (communication within the scope of an existing or potential business relationship). Transaction Security Information (IP address, visit date/time, log records) To ensure the security of our website, prevent misuse, and improve the technical infrastructure. Legitimate interests of the data controller (security and system integrity). Marketing Information (Preferences collected via cookies) To analyze site usage, personalize content, and measure website performance. Explicit consent (for non-essential cookies). b) For Job Applicants "Data Category" "Purpose of Processing" "Legal Basis" "Identity Information" (Name, surname, Turkish ID number – where mandatory) To conduct the application process, evaluate the candidate, and perform identity verification. Explicitly provided for by law (e.g., Labor Law) or explicit consent. "Contact Information" (Email, phone, address) To send notifications regarding the application process and interview invitations. | Taking necessary steps at the request of the data subject prior to entering into a contract. "Professional Experience Information" (CV, cover letter, references, certificates, education details) To evaluate the candidate's suitability for the position, conduct reference checks, and analyze competencies. | Explicit consent; taking necessary steps at the request of the data subject prior to entering into a contract. "Visual/Audio Recordings" (Interview notes, video recordings if applicable) To document the interview process and ensure consistency in evaluation. | Explicit consent. "Special Categories of Personal Data" (Health information, criminal convictions – only when legally required) To fulfill legal obligations such as pre-employment health reports or security background checks. Explicitly provided for by law. 3. Transfer of Personal Data Your personal data may be transferred, limited to the purposes stated above: "Domestically:" To our "service providers" (acting as data processors) such as cloud service providers (server hosting), email service providers, lawyers acting as consultants, and audit firms. - ""Internationally:"" To cloud service providers based in the USA (e.g., for email infrastructure), ""only with your explicit consent"" or if the recipient country provides an adequate level of protection as per relevant regulations. During any transfer, all necessary technical and administrative measures are taken to ensure the security of your data, in compliance with "Articles 8 and 9 of the KVKK and Chapter V of the GDPR". 4. Method of Data Collection and Retention Period Your personal data is collected through: - "Our website" (contact forms, career page, cookies), - "Email" (messages you send to us), - "Job application platforms", - "Direct meetings" with you, using automated or non-automated methods. Your personal data is retained for the duration required by the purpose of processing. These periods are: - "Contact requests:" Maximum "1 year"" following the resolution of your request. - "Job applications:" For unsuccessful applications, "2 years" from the application date (based on consent, for potential legal disputes and consideration for future positions). For successful applications, data is transferred to the employee personnel file. - "Cookie records:" From the duration of the visit up to ""2 years"", depending on the cookie type. - "Log records:" Maximum "2 years". Upon the expiry of the relevant period, your personal data will be ""deleted, destroyed, or anonymized"" ex officio. 5. Rights of the Data Subject (Article 11 of the KVKK) Pursuant to Article 11 of the KVKK, as the data subject, you have the following rights: 1. To learn whether your personal data is being processed, 2. To request information if your data has been processed, 3. To learn the purpose of processing and whether it is used in accordance with its purpose, 4. To know the third parties to whom your data has been transferred, domestically or abroad, 5. To request rectification if your data is incomplete or incorrectly processed, 6. To request erasure or destruction of your data within the framework of the conditions set forth in Article 7 of the KVKK, 7. To request notification of the operations carried out pursuant to (5) and (6) to third parties to whom your data has been transferred, 8. To object to a result arising against you through the analysis of processed data exclusively by automated systems, 9. To claim compensation for damages arising from unlawful processing. 6. Method for Exercising Your Rights To exercise your rights mentioned above, you can submit your request, along with documents verifying your identity, via email to ""data.protection@dereinvest.com"" or by sending a signed written petition to our ""company's correspondence address"". Depending on the nature of your request, it will be concluded ""free of charge"" within a maximum of ""30 (thirty) days"". However, if the transaction requires an additional cost, a fee may be charged according to the tariff set by the ""Personal Data Protection Board"". 7. Data Security To ensure the security of your personal data, we implement: - ""Technical measures:"" Firewalls, encryption methods, authorization matrices, up-to-date antivirus systems, and penetration tests. - ""Administrative measures:"" Data security training for employees, confidentiality agreements, and regular internal audits. In this context, we apply the standards of ""ISO 27001 Information Security Management System"" and continuously carry out improvement activities. In the event of a data breach, we will immediately notify the relevant supervisory authorities and affected individuals, as required by legal obligations. 8. Cookies Our website uses cookies to improve user experience and analyze site traffic. Essential cookies, necessary for the website to function, do not require your consent. For non-essential cookies (analytical, performance, targeting), a cookie banner is presented upon your first visit to obtain your explicit consent. You can change your cookie preferences at any time through your browser settings. For more information, please visit our [Cookie Policy](cookie-policy-link). 9. Updates and Effective Date This policy was last updated on ""January 1, 2025"", and enters into effect on the date it is published on our website. In case of any changes, the updated text will be published on our website, and notification will be provided where necessary. A ""Sample KVKK Application Form"" can be provided upon request. Please do not hesitate to contact us for any questions, comments, or requests. I have read, approve, and agree.

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