NART INSURANCE AND REINSURANCE BROKERAGE INC.

CANDIDATE PRIVACY NOTICE UNDER THE LAW ON THE PROTECTION OF PERSONAL DATA

This Privacy Notice is prepared by NART Insurance and Reinsurance Brokerage Inc. (“NART” or the “Company”) to inform you about NART’s identity (Article 10.a of the Law on the Protection of Personal Data), the purposes for which your personal data may be processed (Article 10.b), the recipients and purposes of data transfer (Article 10.c), the methods and legal grounds for data collection (Article 10.ç), and your rights (Article 10.d) regarding the personal data you may share with us.

1. Identity of the Data Controller (Article 10.a)

Your personal data will be processed, stored, and protected by NART Insurance and Reinsurance Brokerage Inc. in its capacity as the data controller.

2. Purpose of Processing Your Personal Data (Article 10.b), Methods of Data Collection, and Legal Grounds (Article 10.ç)

Candidates who wish to work at NART can submit their resumes and/or application forms via our email addresses or in person. Additionally, candidates may apply by registering their information on employment platforms such as LinkedIn, Kariyer.net, and Hireflix (“employment platforms”) and submitting their resumes. Moreover, resumes of candidates may also be shared with NART by İş-Kur customer representatives.

2.1 Resume, Job Application Form, Employment Platform

Upon applying through any of the above channels, your personal data included in your resume, job application form, and/or employment platform are processed for the purposes of evaluating your application, checking for the most suitable open positions, and determining the most appropriate candidate for the job. This processing is conducted based on the legal grounds of “the data subject having made the data public” and, following your application, “the necessity of processing for the performance of a contract to which the data subject is party” and “compliance with a legal obligation to which the data controller is subject.” If your application is successful, your personal data will be processed based on “the necessity for the establishment, exercise, or defense of legal claims.” The processing of your resume or job application form is carried out automatically, in whole or in part, when submitted via email or through intermediary institutions’ online pages; if submitted in person at NART, the processing is carried out non-automatically. Please note that since a standard form is not used for resumes, any additional personal data you include in your resume, which is not covered in our application forms, will also be processed by us. Additionally, your contact details may be processed to communicate with you for interview purposes during the recruitment process.

2.2 Technical and Oral Interview

If you are interviewed, the personal data you provide during the technical and oral interview, as well as our assessments of your technical knowledge and personality, may be processed. The purpose of this processing is to evaluate your suitability for our work environment and principles, as well as your social characteristics, and to determine whether your qualifications and experience align with the open position. Your personal data included in your resume, job application form, and/or employment platform will be processed based on the legal grounds of “the data subject having made the data public” and, following your application, “the necessity of processing for the performance of a contract to which the data subject is party” and “compliance with a legal obligation to which the data controller is subject.” If your application is successful, your personal data will be processed based on “the necessity for the establishment, exercise, or defense of legal claims.” The processing is carried out both automatically and non-automatically.

2.3 Reference Checks

The personal data obtained as a result of contacting the individuals you have provided as references may include assessments of your technical knowledge, team compatibility, work principles, compatibility with colleagues, adherence to work schedules, work discipline, and loyalty to the workplace. These personal data are processed to evaluate your suitability for the job and position, based on the legal grounds of “the data subject having made the data public” and “the necessity of processing for the performance of a contract to which the data subject is party.” If your application is successful, the processing is also based on “the necessity for the establishment, exercise, or defense of legal claims.” The processing is carried out both automatically and non-automatically.

If a decision is made to hire you, the resume, job application form, personal data obtained during the interview, and information obtained from your references will be stored in your personnel file. This is done to maintain transparency in the recruitment process, to ensure that the information you provided before hiring can be reviewed and verified, and because this information forms the basis of the employment contract.

3. Transfer and Purpose of Transferring Your Personal Data (Article 10.c)

Before your employment, the personal data you may share with us as a candidate will not be shared with or transferred to any third parties, either domestically or internationally.

4. Your Legal Rights (Article 10.d)

Your rights, as specified in Article 11 of the Law on the Protection of Personal Data, are as follows:

a) To learn whether your personal data is being processed; b) To request information if your personal data has been processed; c) To learn the purpose of processing your personal data and whether they are used in accordance with that purpose; ç) To know the third parties to whom your personal data is transferred, domestically or internationally; d) To request the correction of your personal data if it is incomplete or inaccurate; e) To request the deletion or destruction of your personal data under the conditions set forth in Article 7 of the Law; f) To request notification of the actions taken regarding the correction, deletion, or destruction of your personal data to third parties to whom your data has been transferred; g) To object to any unfavorable outcome resulting from the automated processing of your personal data; ğ) To seek compensation for damages resulting from the unlawful processing of your personal data.

You can submit your requests regarding your rights to NART Insurance and Reinsurance Brokerage Inc. by following the procedures and principles outlined in the Communiqué on the Procedures and Principles of Application to the Data Controller. You may also use the KVKK Request Form, which we have prepared for you.

This Privacy Notice may be updated in line with changes and innovations in legislation, as well as decisions and statements made by the Personal Data Protection Board, to ensure that data security and confidentiality are fully maintained, legal obligations are properly and completely fulfilled, and any potential loss of rights is prevented. In such cases, the updated Privacy Notice will be communicated to you via email and/or announced on our website.

Publication Date: 30.09.2019