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(Intern Clarification Text)

As Boss Governance Services Joint Stock Company (“Company”), we prioritize the security of your personal data with the utmost care. With this awareness, we place great importance on the processing, storage, and deletion of both special and general categories of personal data belonging to all interns within the Company, in compliance with Law No. 6698 on the Protection of Personal Data (“Law” or “KVKK”), secondary regulations (regulations, communiqués, circulars) issued or to be issued under the Law, and binding decisions of the Personal Data Protection Board. In full awareness of this responsibility, we process your personal data within the scope of creating personnel files and related processes, in the manner described below and within the limits prescribed by legislation, as a “Data Controller” as defined under the Law.

1. Information on the Data Controller

In accordance with the Law, Boss Governance Services Joint Stock Company, registered with the Istanbul Trade Registry Office under tax identification number 1800379183 and located at “Esentepe Mahallesi Büyükdere Cad. Astoria Sit. No: 127 B/8 Şişli/İstanbul,” serves as the Data Controller.

2. Categories and Types of Processed Personal Data

Data Category	Types
Identity Information	Name, Surname, Gender, Age, Signature, National ID Number (TCKN), Gender, Identity details, Country information, Other details on the identity document.
Contact Information	Phone number, Email address, Residential address
Transaction Security and Risk Management	IP address information, information obtained during the tracking process of the work computer, entry-exit logs
Academic Information	Name of the last graduated school and graduation certificate
Physical Space Security Data	CCTV records, Entry and exit times
Criminal Convictions	Judicial record.
Other Information	Military service status.

3. Methods of Collecting Personal Data and Relevant Activities

As a Company, we collect your personal data through automatic means and/or non-automatic means as part of an automatic data recording system.

Data Categories and Collection Activities

Data Category	Collection Activity
Identity Information	• Electronic and physical forms, documents, and any type of material declared by you during the internship application process. • Electronic forms provided through platforms such as Kariyer.net, Pera Kariyer, LinkedIn, or other recruitment channels you use and transfer data to the Company. • Forms, documents, and any materials used during recruitment. • Forms, documents, and any materials used throughout the employment relationship.
Contact Information	• Electronic and physical forms, documents, and any type of material declared by you during the internship application process. • Electronic forms provided through platforms such as Kariyer.net, Pera Kariyer, LinkedIn, or other recruitment channels you use and transfer data to the Company. • Forms, documents, and any materials used during recruitment. • Forms, documents, and any materials used throughout the employment relationship.
Transaction Security and Risk Management	• Electronic systems.
Academic Information	• Electronic and physical forms, documents, and any type of material declared by you during the internship application process. • Electronic forms provided through platforms such as Kariyer.net, Pera Kariyer, LinkedIn, or other recruitment channels you use and transfer data to the Company. • Forms, documents, and any materials used during recruitment. • Forms, documents, and any materials used throughout the employment relationship.
Physical Space Security Data	• CCTV.
Other Information	• Forms, documents, and any materials used throughout the employment relationship.
Criminal Convictions	• Forms, documents, and any materials used during recruitment.

4. Purposes and Legal Basis for the Processing of Personal Data

As a Company, we process your personal data in accordance with the purposes and legal grounds outlined below, adhering to the boundaries specified by the Law. This is done in compliance with legal and ethical principles, ensuring that data processing is always relevant, limited, and proportional to these purposes.

Personal Data	Purposes of Processing	Legal Basis
Identity Information	• Fulfillment of obligations under the Personal Data Protection Law No. 6698 and its associated secondary regulations. • Compliance with obligations under Occupational Health and Safety Law No. 6331 and related secondary regulations. • Provision of necessary information to relevant/authorized public institutions, judicial or administrative authorities, and law enforcement when required. • Development and maintenance of human resources policies. • Facilitation of training, seminars, and similar activities for employee development. • Analysis of performance and productivity metrics, preparation of performance reports, and promotion of performance improvements. • Planning and execution of career and achievement development processes within the workplace. • Ensuring employee satisfaction and addressing their needs. • Implementation of workplace security measures and prevention of disruptions in the work environment. • Management of emergency situations. • Conduct of audits and ethical activities. • Organization of professional training activities. • Management and execution of legal affairs. • Facilitation of business activities and continuity. • Management of occupational health and safety activities. • Collection and evaluation of recommendations for process improvements. • Organization and event management.	KVKK Article 5/2(c)-(ç)-(f): • (c) Processing is necessary for the establishment or performance of a contract to which the data subject is a party. • (ç) Processing is mandatory for the data controller to fulfill legal obligations. • (f) Processing is necessary for the legitimate interests of the data controller, provided it does not harm the fundamental rights and freedoms of the data subject.
Contact Information	• Development and maintenance of human resources policies. • Organization and event management. • Provision of information to authorized individuals, institutions, and organizations. • Facilitation and supervision of business activities. • Conduct of communication activities. • Management of candidate/intern/student selection and placement processes. • Communication with parents or guardians if the data subject is under 18.	KVKK Article 5/2(c)-(ç)-(f): • (c) Processing is necessary for the establishment or performance of a contract to which the data subject is a party. • (ç) Processing is mandatory for the data controller to fulfill legal obligations. • (f) Processing is necessary for the legitimate interests of the data controller, provided it does not harm the fundamental rights and freedoms of the data subject.
Transaction Security and Risk Management	• Provision of necessary information to relevant/authorized institutions, judicial or administrative authorities, and law enforcement when required. • Management of information security processes. • Supervision of business activities. • Ensuring the security of data controller operations. • Management of access rights.	KVKK Article 5/2(f): • (f) Processing is necessary for the legitimate interests of the data controller, provided it does not harm the fundamental rights and freedoms of the data subject.
Academic Information	• Development and maintenance of human resources policies. • Planning and execution of career and achievement development processes within the workplace.	KVKK Article 5/2(f): • (f) Processing is necessary for the legitimate interests of the data controller, provided it does not harm the fundamental rights and freedoms of the data subject.
Physical Space Security Data	• Provision of necessary information to relevant/authorized institutions, judicial or administrative authorities, and law enforcement when required. • Ensuring the security of physical spaces.	KVKK Article 5/2(f): • (f) Processing is necessary for the legitimate interests of the data controller, provided it does not harm the fundamental rights and freedoms of the data subject.
Other Information	• Development and maintenance of human resources policies. • Ensuring the security of data controller operations.	KVKK Article 5/2(f): • (f) Processing is necessary for the legitimate interests of the data controller, provided it does not harm the fundamental rights and freedoms of the data subject.
Criminal Convictions	• Provision of necessary information to relevant/authorized institutions, judicial or administrative authorities, and law enforcement when required. • Ensuring workplace security.	KVKK Article 6/3(a): • Processing is based on the explicit consent of the data subject.

5. Transfer Of Personal Data

Recipients/Organizations	Purpose of Transfer	Legal Basis
Group Companies	Coordination of human resources and intercompany operations. Execution of group company projects. Adherence to group company procedures.	Legal Basis: KVKK Article 8/2(a): Processing is necessary for the establishment or performance of a contract. Processing is necessary for the legitimate interests of the data controller, provided it does not harm the fundamental rights and freedoms of the data subject.
International Platforms	(e.g., Outlook, Google Mail, One Drive, Atlassian Servers, Microsoft Lists) Digital storage of your information. Maintenance of company archive records.	Legal Basis: KVKK Article 9/1: Processing requires your explicit consent.
Domestic Software and Secure Folders	(e.g., Informasoft, Bordromat) Digital storage of your information. Maintenance of archive records. Coordination between departments for process execution.	Legal Basis: KVKK Article 8/2(a): Processing is necessary for the legitimate interests of the data controller, provided it does not harm the fundamental rights and freedoms of the data subject.
Authorized Public Institutions and Judicial Authorities	Legal reporting, regulatory and audit activities, complaint management, and legal processes. Ensuring the security of data controller operations.	Legal Basis: KVKK Article 8/2(a): Processing is mandatory for the fulfillment of legal obligations. Processing is necessary for the legitimate interests of the data controller, provided it does not harm the fundamental rights and freedoms of the data subject.
Other Departments and Group Companies	Planning human resources processes. Providing information to authorized individuals and institutions. Conducting training and career development activities. Ensuring physical and organizational security. Managing financial and accounting processes.	Legal Basis: KVKK Article 8/2(a): Processing is necessary for the establishment or performance of a contract. Processing is necessary for the legitimate interests of the data controller, provided it does not harm the fundamental rights and freedoms of the data subject.

6. Rights Of The Data Subject

You may contact the Company at any time to exercise your rights under Article 11 of the Personal Data Protection Law (“Law”), including:

Learning whether your personal data is processed or not.
Requesting information regarding the processing of your personal data, if processed.
Learning the purpose of processing and whether your personal data is used in accordance with its purpose.
Knowing the third parties, both domestic and abroad, to whom your personal data has been transferred.
Requesting correction of incomplete or incorrect data, if any.
Requesting deletion or destruction of your personal data under the conditions specified in Article 7 of the Law.
Requesting notification to third parties to whom your personal data has been transferred regarding the actions taken pursuant to (5) and (6).
Objecting to any result against you that arises from analysis of your processed data exclusively through automated systems.
Claiming compensation for damages incurred due to unlawful processing of your personal data.

You can exercise your rights related to the Law and its implementation by completing the application form available at www.boss.com.tr or obtained directly from the Company and submitting it using one of the following methods:

Sending an email to This email address is being protected from spambots. You need JavaScript enabled to view it. using a registered electronic mail (KEP) address assigned to you.
Completing and signing the application form and submitting it via a notary public, registered mail, or in person to “Esentepe Mahallesi Büyükdere Cad. Astoria Sit. No: 127 B/8 Şişli/İstanbul”.
Sending an email to This email address is being protected from spambots. You need JavaScript enabled to view it. using the email address you provided to the Company and registered in the Company’s system.

The Company will respond to your requests in writing without charge for up to ten pages; for each page exceeding ten, a fee of 1 Turkish Lira per page will be charged. If the response is provided on a recording medium such as a CD or flash drive, the fee will not exceed the cost of the medium.

For your application to be valid and processed, it must include your name, surname, signature, Turkish ID number, residential or workplace address, email address, phone and fax number, and a clear explanation of your request. Applications that do not comply with these requirements will be rejected or redirected to valid application channels under the "Communiqué on the Procedures and Principles of Application to the Data Controller."

The Company reserves the right to amend this clarification text due to changes in the Law, secondary regulations, or decisions by the Personal Data Protection Board. Changes will take effect immediately upon notification of the updated text.

EXPLICIT CONSENT DECLARATION – TRANSFER OF PERSONAL DATA ABROAD

I confirm that I have read and understood the Clarification Text on the Protection and Processing of Personal Data within the Scope of Creating Personnel Files for Interns. I acknowledge that my personal data may be processed in connection with the purposes outlined in the Clarification Text, in a limited and proportional manner, in compliance with Article 9/1 of the Personal Data Protection Law No. 6698 (“Law”), which requires explicit consent for the transfer of personal data abroad. My personal data may be processed through automatic or non-automatic means as part of or not part of an automated data recording system. I have been informed of the technical and administrative measures taken to ensure data security and the rights listed in Article 11 of the Law. I am aware that I can withdraw my explicit consent at any time.

I provide my explicit consent for the transfer of my personal data, limited to the purposes stated in the Clarification Text, to platforms located abroad (such as Outlook, Google Mail, One Drive, Atlassian Servers, Microsoft Lists) for communication and process management.

EXPLICIT CONSENT DECLARATION – RETENTION OF CRIMINAL RECORD DATA

I confirm that I have read and understood the Clarification Text on the Protection and Processing of Personal Data within the Scope of Creating Personnel Files for Interns. I acknowledge that my personal data, including criminal record data, may be processed in connection with the purposes outlined in the Clarification Text, in a limited and proportional manner, in compliance with Article 6/2 of the Personal Data Protection Law No. 6698, which requires explicit consent for the processing of special categories of personal data. My personal data may be processed through automatic or non-automatic means as part of or not part of an automated data recording system. I have been informed of the technical and administrative measures taken to ensure data security and the rights listed in Article 11 of the Law. I am aware that I can withdraw my explicit consent at any time.

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