The Personal Data Protection Law (KVKK) was published in the Official Gazette dated April 7, 2016 and numbered 29677. KVKK is dedicated to protect the fundamental rights and freedoms of natural persons, including the privacy of private life, which are also protected by the Constitution, of natural persons whose personal data are processed, and to determine the obligations of natural and legal persons who process personal data. Purpose of this policy is to establish management instructions, procedural conditions and a technical policy in order to ensure that the personal data of the relevant persons are processed and protected by UPC Uzay Surface Treatment in accordance with the KVKK.

All rights of the www.upc-uzay.com website and its mobile applications (collectively, the “Site”) belong to UPC Uzay Surface Treatment (collectively, “UPC” for short). UPC aims to protect the membership information of all users in line with the principles of security and confidentiality. If UPC detects that the members are using the Site in violation of the Personal Data Protection and Data Policy below or the law, or if there is a request for a determination or investigation by the competent authorities, it has the right to inform the competent authorities about the relevant Member and the Company. It also has the right to take other measures stipulated in the Personal Data Protection and Data Policy in a similar situation. There is no absolute guarantee of the confidentiality of personal information transmitted over the Internet, and UPC recommends that users take the highest possible precautions while transmitting personal information on the Internet.

Definitions

Service/Services: Refers to the practices put forward by UPC in order to enable Members and Companies to carry out the work and transactions defined in the User Agreement.

User/Users: Natural and legal persons who access the Site with or without registration.

Site: Refers to the mobile applications and website that can be accessed from www.upc-uzay.com domain name and sub-domain names. Domain and applications belong to UPC.

Member: Students, who continue their university education and those who have graduated, vocational high school students who wants to receive education according to the Vocational Education Law numbered 3308 and the Ministry of Education Secondary Education Institutions Regulation published in the Official Gazette on 07.09.2013, accept the User Agreement along with the KVKK and Data Policy, and benefit from the content, applications and services on the Site, can become a member.

Company: Companies, foundations, associations and cooperatives, which have legal personality and are established and are existing in accordance with laws of Turkish Republic or foreign law, and accepts the User Agreement together with KVKK and Data Policy, and benefit from the content, applications and services on the Site, can have a Company account.

Personal Data Protection Law

Pursuant to the Personal Data Protection Law No. 6698 (“KVKK”), the personal information of the Members and Companies will be recorded, stored, updated, disclosed/transferred to third parties as permitted by the legislation, classified and processed in the ways listed in the KVKK, by UPC as described below.

Data Supervisor

In accordance with the Personal Data Protection Law No. 6698 (“Law No. 6698”), your personal data can be collected and processed within the scope described below, by UPC UZAY SURFACE TREATMENT (“UPC“) as the data supervisor.

For What Purposes Do We Collect and Process Your Information?

UPC will generally be able to collect and process data belonging to our users through the Site for the following purposes:

• To carry out our own employment agency intermediation activities such as finding a job and internship,
• To transfer the CVs and/or profiles of the Members to Member Companies that accept applications to job or internship announcements and events on the Site, with the Member’s own consent or the Automatic Matching system specified in the User Agreement,
• To transfer the personal videos of the Members to the Company, which were taken based on the video interview questions sent to the Members choosen among the applicants by the relevant Company, if needed,
• To transfer the personal responses of the Members to the Company based on the questions asked by the relevant Companiy during the receipt of the job applications,
• To carry out our consultancy services for human resources,
• To provide personalized services to users and to increase user satisfaction by making the user experience better,
• To contact with Companies, Members or visitors to the extent permitted by UPC, to inform them about services and opportunities,
• To monitor the technical functions of the Site, to make it work properly and to solve any problems that may arise,
• To use for advertising sales purposes so that Members or Visitors can use our Site for free, forever,
• To perform the services we offer in accordance with our User Agreement,
• To send a bulletin or to make promotions or notifications by e-mail,
• To send and conduct mass e-mails and/or SMS for events such as for Company, university student clubs, foundations and associations,
• To send promotions or notifications via SMS,
• To conduct direct marketing by member companies cooperating with UPC,
• To answer your appeals and respond to your support needs,
• To develop our existing and R&D applications and to market the product in the management process,
• To examine your UPC account in line with your request or in case of complaints on social media,
• To conclude the complaint, if there is a complaint about the services we provide,
• To use in various statistical evaluations, database creation and market research without revealing the identity of the User,
• To increase service sales for Companies, to provide marketing and customer satisfaction analysis.

UPC may have adopted other policies or procedures for the security, confidentiality, collection, etc. of data other than the Personal Data Protection and Data Policy. For this reason, we recommend that you also review other policy and legal texts.

To Whom and For What Purpose the Processed Personal Data Can Be Transferred

By accepting the Terms of Use, the Personal Data Protection and Data Policy, your personal data that you have consented to be shared with and collected by UPC, will be shared with business partners, shareholders, affiliates, affiliated group companies, domestic and/or foreign third parties with whom we have a contractual relationship, domestic/foreign individuals and institutions that we receive service for storing data in a cloud server environment, and companies that create profiles on the Site, within the scope of realization of the Purposes by UPC in accordance with the basic principles stipulated in the Law and within the personal data processing conditions specified in Articles 8 and 9 of the Law. In addition, this information will be shared is only in case of need and to the extent necessary, with third parties with whom we have a contractual relationship, who have the same legal and technical responsibilities with us regarding data protection and security, and who comply with the provisions of the relevant legislation, in order only to render the services to be provided to you perfectly, to deliver your possible shipments in a healthy way, to deliver our notifications on time by phone, sms and/or e-mail.

When and How Do We Collect Your Information?

Your personal data may be collected in written/physical or electronic environment when you use the Site, when you enter/apply for advertising or marketing postings, when you are a member or register, and with cookies.

Your Rights as per Article 11 of KVKK

1. Learning whether it has been processed,
2. Requesting information if processed,
3. Learning the purpose of processing and whether it is used appropriately,
4. To know the third parties to whom it is transferred at home/abroad,
5. Requesting correction if it is incomplete/incorrectly processed,
6. Requesting deletion/destruction within the framework of the conditions stipulated in Article 7 of the KVKK,
7. Requesting that the third parties to whom it is transferred be notified of the transactions carried out in accordance with the paragraphs (d) and (e) above,
8. Objecting to the emergence of a result against you because it is analyzed exclusively with automated systems,
9. If you suffer damage due to unlawful processing, you have the right to demand the compensation of the damage.

If you would like to know how your information is processed and/or transferred and/or related to the above conditions, you can write to info@upc-uzay.com.tr.

If you wish, you can send your petition/question/complaint along with your name and surname with wet signature to UPC, responsible for your data as a buyer, at address Demirtas Organized Ind. Zone (DOSAB) Mustafa Karaer Ave. No: 33 16245 Osmangazi/BURSA.

Your requests in your application will be concluded free of charge within thirty days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost for the Company, the fee specified by the Personal Data Protection Board may be charged.

How Do We Collect Your Personal Data?

1- Identity Information

By registering as a Member on the Site, information such as “Your Name,” “Surname”, “Date of Birth”, “Identity Number” (for the Turkish citizens), “Place of Birth”, “Your Nationality (Citizenship)”, “Gender” is shared with UPC by your own will.

By registering on the site as a Company, you share information such as “Your Name”, “Surname” and “E-mail address” to UPC by your own will.

It is possible to register or become a member without entering information such as name, surname, date of birth, e-mail address, through your Facebook, LinkedIn etc. social network accounts. If you choose to register or become a member of our services via social networks within the scope of this Personal Data Protection and Data Policy, you are giving UPC the authority to process, transfer and store the data sent to us by the said social networks.

2- Contact Information

With your registration on the site, you share information such as “E-Mail Address”, “Address”, “City and District You Live in” and “Mobile Phone Number” to UPC by your own will.

3- Educational Information

You share information such as “School”, “School Department”, “Starting and Ending/Possible Ending Date”, “Average Grade”, “Class”, “Foreign Language and Level”, “Course Information”, “Seminars Attended”, “University Student Club Information/Task/Working Time” with UPC by your own will.

4- Work and Other Information

You share information such as “Working Status and Title”, “Work Experience (Company Name, Department, Starting/Ending Date, City and Description” to UPC by your own will.

5- Visual and Audio Data

You share the interview video and audio recordings along with the pictures, that you upload voluntarily and/or the images uploaded to the site using other permitted social networks, to UPC by your own will.

6- Other Information

You share the statement written by the Member in the “About” field with his own consent, driver’s license data, internship or job search status, information about whether the insurance is covered by the school or not, sMatch (automatic matching) information (yes/no) and other similar information to UPC by your own will.

On the side of Members and Companies, in case you choose to disclose your information and data to the public and share those in a way that other members and companies can access and see, it is deemed disclosed by you and may be used for statistical, advertising or promotional purposes. UPC has no responsibility in cases where your personal data you have disclosed are used by third parties or other sites.

7- Information That Is Not Your Personal Data and We Collect Automatically

We can collect information such as login ID, IP address, log records and additional information requested by the Member Company, membership date, applications made, frequency/period of login to the site, ios/mobile site/website user, update date, last login date, first membership date, application deletion (yes/no), information on the usage of the applications (every action and selection made within the application) and similar technologies, to adapt the needs of our members, companies and visitors, to fix technical problems, and to audit our technical infrastructure. We may collect information about your click numbers, frequency of opening tabs or your behavior in the digital environment regarding the titles you are interested in, depending on your in-site usage through cookies or other programs and editions.

7.1. Device Info

We may collect data from your device that cannot be matched with you (such as location information) over the electronic devices you use (computer, laptop, tablets, smart phones, smart televisions, etc.). We can send push notifications through our mobile applications or website. If you do not want to receive these messages, you can reject these messages by changing the settings of your device or mobile application.

7.2. Cookies Information

Your usage information of the site can be obtained by using a technical communication file (Cookie). The mentioned technical communication files are small text files that a website sends to the user’s browser to be stored in the main memory. The technical communication file facilitates the use of the internet by storing the status and preferences about a website. The technical communication file helps to obtain statistical information about how many people use the Site, for what purpose, how many times a person visits the Site and how long they stay, and helps to dynamically generate content from user pages specially designed for users. The technical communication file is not designed to receive data or any other personal information from the main memory or e-mail. Most of the browsers are originally designed to accept the technical communication file, but users can change the settings so that the technical communication file is not accepted or a warning is given when the technical communication file is sent. Unless the Member and the Company change these settings, it is accepted that they give explicit consent to the use of cookies.

We may use cookie technology and place them on your device. If you do not accept cookies, the Site may not perform the expected functions or malfunctions may occur.

We can share the data collected through cookies with third parties for advertising purposes.

These personal data will be processed and stored in order to benefit from the advantages of using the Site, based on your explicit consent, and by taking information security measures, provided that they are not used outside the scope and purpose specified in the Privacy and Personal Data Protection Policy.

Links to 3rd Party Websites or Mobile Applications on the Site

We can provide links to third party websites, portals or mobile applications. However, we have no responsibility for the implementation of the privacy policies on these sites or to which third parties are subject. Privacy policies within the scope of third party websites or mobile applications may differ from this Personal Data Protection and Data Policy.

Retention Period of Your Information

UPC keeps the personal data processed pursuant to Article 7 of the KVK Law and Article 138 of the Turkish Penal Code only for the period stipulated in the relevant legislation or if a period is not stipulated in the legislation, for the period required by the purpose of personal data processing. The retained data will be deleted after the purpose of retention of the data ends, and although an average of 2 years is determined, the data, for which a longer period is legally foreseen, will continue to remain in the system as specified in the legislation.

For this reason, a different keeping period may apply for each personal data regarding the period stipulated in the relevant legislation or required for the purpose for which they are processed. For example, in accordance with Article 253 of the Tax Procedure Law, books and documents should be kept for 5 years. Another example is, in accordance with the Regulation on Commercial Communication and Commercial Electronic Messages, in cases where the consent of the subject is withdrawn regarding the use of personal data for marketing or promotional purposes, the records of personal data should be kept for 1 year from this date. The content of the commercial electronic message and any other records regarding the post will be kept for 3 years to be submitted to the relevant ministry when necessary.

On the other hand, data may be processed for more than one purpose, and in such a case, when all the reasons for the processing of the relevant data disappear, the relevant data is deleted, destroyed or anonymized and preserved.

Personal data processed in accordance with the provisions of the KVKK and other relevant laws must be deleted, destroyed or anonymized such that this data will not be used or retrieved in any way, by UPC ex officio or on the request of the person concerned, in the event that the reasons requiring their processing are eliminated. The procedures and principles regarding the legal destruction or anonymization of personal data will be fulfilled in accordance with the principles and rules specified in the KVK Regulation.

Security of Personal Data

UPC’s obligations regarding data security

Pursuant to Article 12 of the KVKK, the obligations of UPC as data supervisor regarding data security are as follows:

Personal data;

• Prevent to be illegally processed,
• Prevent to be illegally accessed,
• Ensure safety,

Take all kinds of technical and administrative measures for the above,

• Carry out the necessary inspections within the organization or have them done,
• Take the necessary measures to ensure that the persons who process personal data on behalf or the officials who work in their organs, even if they leave their duties, do not disclose the personal data they have learned during their duties to anyone in violation of the provisions of the law and use them for purposes other than processing,
• Notify the relevant person and the Board in case the processed personal data is illegally seized by others.

Measures taken by UPC regarding data security

In order to fulfill its obligations regarding the security of personal data and to act quickly in cases where security poses a risk, UPC takes the following measures:

• Technical and administrative measures taken to prevent illegal access to personal data.
  The technical and administrative measures to be taken in the relevant departments regarding the processing, transfer and preservation of personal data are listed. Although UPC is obliged to take these precautions completely and prevent illegal access, nevertheless, if third parties had illegal access to personal data, it takes all technical and administrative measures to prevent harm to those concerned, in accordance with the relevant legislation on the personal data protection and the decisions of the Board.
• Measures taken for personal data protection and their supervision.
  The fact that the data recording systems used within the company are established and used in accordance with the KVKK and the relevant legislation are periodically monitored and audited and reported to the authorized person or board.

UPC is also obliged to inform natural or legal persons who process personal data on behalf based on the authorization given and to raise awareness about the legal protection of personal data, and to determine provisions for the personal data protection in accordance with the law within the framework of contracts concluded with these persons.

Measures to be taken in case of unauthorized disclosure of personal data

UPC is obliged to take measures to prevent unauthorized disclosure of personal data and to create a related internal policy. In addition, in such cases, UPC, as the data supervisor, is obliged to inform the persons whose personal data have been disclosed unauthorized and the KVKK Board.

Users and/or Members (Natural Persons) and/or Member Companies (Legal Companies) accept the use of all information collected by UPC from them from the moment they start to use the Site, as described in this Personal Data Protection and Data Policy. Information on Users and/or Members (Natural Persons) and/or Member Companies (Legal Companies) is provided to UPC with their own free will. Users and/or Members (Natual Persons) and/or Member Companies (Legal Companies) are free to give this personal information to UPC or not. It is their responsibility to ensure that the information provided by the Users and/or Members (Natural Persons) and/or Member Companies (Legal Companies) is correct and complete. Users and/or Members (Natural Persons) and/or Member Companies (Legal Companies) should not provide false, misleading or incomplete information.

Age of Membership

We do not deliberately process data of users under the age of 18. It is forbidden for those under the age of 13 to register on the SITE. All of our departments, including the real and legal persons we cooperate with, are aware of the sensitivity of your children’s personal data and we take care of the protection of these data at the highest level. Sharing your child’s personal data with us is under the responsibility of the parent or legal representative.

If a parent realizes that his or her child has shared their personal information with us without their consent, they can delete this personal information through UPC or request it from us.

We recommend that parents take an active role in supervising their children’s online activities.

IF USERS OR MEMBERS HAVE DOUBT SUBMITTING INFORMATION TO UPC OR SHOWING THIS INFORMATION ON THE SITE OR THE USE OF THIS DATA UNDER CONDITIONS OF THIS PERSONAL DATA PROTECTION AND DATA POLICY AND TERMS OF USE, THEY SHOULD NOT BECOME USER AND/OR MEMBER, VISIT THE SITE, USE THE APPLICATIONS OR THE SERVICES, AND MEMBERS SHOULD TERMINATE THEIR MEMBERSHIP.

By becoming a member and creating a profile, the Members explicitly and willingly accept the terms and conditions of the User Agreement and also accept and approve the method of processing personal information by UPC as specified in this Personal Data Protection and Data Policy. Submitting information that is considered “sensitive” by applicable law is entirely dependent on the will of the Members and Companies. Members and Companies may withdraw or change their consent to the collection and processing of personal information they provide, by changing their account settings or profiles on the Site or by terminating their membership in the Site in accordance with the provisions of this Personal Data Protection and Data Policy and User Agreement.

UPC may change or renew this Personal Data Protection and Data Policy from time to time without notice for any reason. The provisions of the Personal Data Protection and Data Policy, which UPC has changed, enter into force on the date they are published on the Site. UPC may not be able to warn Members about the renewed rules. However, in this case, the updated version of Personal Data Protection and Data Policy reflecting the said changes will be uploaded to the Site. UPC recommends that Members be informed about the Personal Data Protection and Data Policy updated on the Site and review them periodically.

Except for the cases described in this Personal Data Protection and Data Policy, UPC does not rent or sell personal information of its Members and Companies. Except where necessary to fulfill instructions (such as processing payment information), or without the separate consent of Members and Companies, personal information not published in the profile of the Members and Companies (excluding publicly available information) or created due to the use of other services will not be disclosed. This is not valid if we believe disclosure of the information is reasonably necessary in our opinion in the following conditions:

1. To comply with legal requirements and processes, including but not limited to civil or criminal subpoenas, court orders, and other mandatory disclosures;
2. To enforce this Privacy and Personal Data Protection Policy or User Terms;
3. To respond to complaints about infringement of third parties’ rights;
4. To respond to member service requests, or
5. To protect the rights, property or security of UPC, Services, Members, Companies, Users or public.

Third parties (for example, your email service provider) may give you the option to upload information from your contacts saved with us to their services. If you choose to share your contacts in this way, you grant your third-party service provider the right to store and disclose that contact information, access and use it, as described in the third party’s terms and privacy policy.

UPC may disclose the personal information, profile information of Members and Companies or their activities as a Member, Company or User in the following cases:

1. To investigate, eliminate or interfere with suspected or de facto unlawful acts or assist official enforcement agencies;
2. To enforce the User Agreement, defend against appeals or claims of third parties, or protect the security or integrity of the Service; or
3. If it is believed that disclosure in good faith is necessary to protect or enforce the rights, property or safety of UPC, Members, Companies, UPC employees or other persons, or if necessary by a subpoena or other legal action.

UPC keeps the personal information provided to UPC as long as the memberships of the Members and Companies are active or in order to provide the Services when necessary. In cases where it is justifiably necessary to fulfill the legal obligations of the act of preserving information, to comply with the requirements of the legislation, to resolve disputes between Members and the Companies, to prevent fraud and abuse, and to apply this Personal Data Protection and Data Policy and User Agreement, information of the companies may be kept even if the membership ends and Personal. Upon request by the police, UPC stores personal information for a limited period of time.

UPC provides services such as sending publications, delivering newsletters, making notifications, providing information about products and services, sharing campaign information and similar services via e-mail/sms etc. obtained from personal information of the Members, Users and/or Companies.If Members and Companies do not want to receive these commercial electronic messages and short messages sent by UPC and do not approve to receive them, they should send an e-mail to info@upc-uzay.com or remove the necessary options from the settings page.

UPC may provide links to other websites within the Site, but this does not mean that UPC has any connection with these websites. UPC does not bear any responsibility for the privacy practices and contents of sites accessed via those links.

Validity

This data policy becomes effective on the date of publication and continues to be in effect until it is removed from the website.

Our Website Personal Data Protection and Data Policy is dated 27.07.2020. In case all or certain articles of the Policy are renewed, the effective date of the Policy will be updated.

Contact Information

UPC UZAY SURFACE TREATMENT
Contact Link: www.upc-uzay.com
Address: Demirtaş Org. Ind. Zone, Lale Str. No: 8 Osmangazi / BURSA / TURKEY

TR: Herhangi bir sorunuz varsa veya bizimle iletişime geçmeniz gerekiyorsa, info@upc-uzay.com adresinden bize ulaşabilirsiniz.
EN: If you have any questions or need to contact us, we recommend you reach out to info@upc-uzay.com
FR: Si vous avez des questions ou avez besoin de nous contacter, nous vous recommandons de contacter info@upc-uzay.com