Sabancı Üniversitesi Inovent Fikri Mülkiyet Hakları Yönetim Ticaret Ve Yatırım Anonim Şirketi (“Company”) acting in its capacity as data controller, and primarily in accordance with the principle of protecting the privacy of private life, shall record, classify, retain and update the personal data of data subjects in compliance with Law No. 6698 on the Protection of Personal Data (“Law”), process such personal data within the framework of the processing conditions set forth under the Law, and transfer such personal data to third parties where and to the extent permitted by applicable legislation.
This Clarification Text has been prepared in accordance with the applicable legislation in force, particularly the Law, as well as the rules set forth in the regulations, communiqués, decisions and guidelines published by the Board. If, following the publication date of the Clarification Text, the Law or any other relevant legislation is amended and the Clarification Text becomes inconsistent with such amendment, the amended provisions and rules shall apply. All communiqués, decisions and guidelines published by the Board are monitored by me/us, and the rules stipulated under the Clarification Text are kept up to date.
1. DATA SUBJECT/RELEVANT PERSON
The data subjects/relevant persons within the scope of this Clarification Text are natural persons who apply to participate in the Master SuCool – Inovation Master Class training programs organized by the Company.
2. IDENTITY OF THE DATA CONTROLLER AND ITS REPRESENTATIVE
Pursuant to the Law, your personal data may be collected and processed by the data controller within the scope set out below. For any questions regarding the processing of your personal data, you may contact the Company Contact Person via the e-mail address info@inovent.com.tr.
3. PURPOSES OF PROCESSING PERSONAL DATA, LEGAL BASES FOR PROCESSING AND METHODS OF COLLECTION
The Company may record, retain, update, transfer to third parties, classify and otherwise process your personal data to the extent and in accordance with the conditions specified under the heading “conditions for processing personal data” in Articles 5 and 6 of the Law. The Company clearly sets out the purposes for which personal data are processed and processes personal data, in line with its business activities, for purposes connected with such activities.
Your personal data collected through the channels and methods specified in this Clarification Text are processed by the Company for the purposes and on the legal bases set out below:
DATA PROCESSING ACTIVITY: MANAGEMENT OF PROGRAM APPLICATION PROCESSES |
Personal Data Processed Identity Data: Name, Surname Contact Data: E-Mail Address, Telephone Number Program and Participation Data*: Program Participation Status, Selected Trainings/Sessions, Attendance and Absence Information, Requests, Questions, Explanations and Notes Submitted within the Scope of the Program, Work Performed within the Scope of the Training, Evaluations, Assessments, Instructor Feedback Visual and Audio Recording Data*: Photographs, Video and Audio Recordings Relating to the Program Other Data: Reference Information, Institution Registration Code Profile Data (optional): Gender, Date of Birth, Profile Photo, Profile Headline Purposes of Processing Personal Data Management of Program Application and Registration Processes, Evaluation and Finalization of Applications, Evaluation of Participants’ Eligibility for the Program, Planning, Organization and Conduct of the Training Program, Monitoring Participant Registration and Attendance Status*, Provision of Training Content and Program Materials*, Conduct of Communication Processes Between Instructors and Participants*, Providing Participants with Information Regarding the Program and Schedules*, Conduct of Measurement, Evaluation and Feedback Processes within the Scope of the Training*, Maintenance of Records Relating to Program Processes*, Conduct of Retention and Archiving Activities, Ensuring that Activities Are Conducted in Compliance with Applicable Legislation and Program Rules, Fulfillment of Legal Obligations, Provision of Information to Authorized Persons, Institutions and Organizations |
Legal Bases for Processing Personal Data Your personal data are processed by the Company for the purposes specified above on the legal bases of “Processing being mandatory for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not prejudiced”, “Processing of personal data belonging to the parties to a contract being necessary, provided that such processing is directly related to the establishment or performance of a contract” and “Explicit consent.” |
Methods of Collection of Personal Data The personal data specified above are collected electronically / physically, by partially or fully automated means, through the Company’s website, electronic application forms, information and documents submitted by you through such forms and during the Program concerning the training process*, and automatic and/or manual photographic, video and audio recording devices* during online training sessions to be conducted within the scope of the Program. |
Transfer of Personal Data Your personal data provided to us for the purposes specified above may, where requested within the scope of Article 28 of the Law, be transferred to the relevant authorities without being subject to the obligation to provide clarification and without obtaining your explicit consent. Furthermore, in unforeseen circumstances, where expressly provided for by law and upon request, your personal data may be transferred to public institutions specified by law (including Ministries, judicial authorities and administrative authorities such as law enforcement authorities), within the purposes and limitations prescribed by the relevant legislation. Your personal data may be shared with program partners, business partners, instructors and other service providers involved in the conduct of the Program, particularly Sabancı University, for the purposes of conducting application, registration, evaluation and participation processes relating to the Program, planning and organizing training activities, communicating with applicants/participants, and conducting training and evaluation processes. In addition, your personal data may be shared with suppliers and service providers engaged in these areas for the purposes of creating, hosting and managing electronic forms, conducting online training sessions, and providing website, information technology, server, cloud, e-mail, communication, archiving and analytics services. Furthermore, if your application is evaluated positively and you acquire the status of a “Participant” and participate in training sessions conducted online or physically, your visual and audio personal data consisting of photographs, video and audio recordings may, subject to your explicit consent, be shared with the public by being published on the website, through press and media outlets and on social media platforms for the purposes of conducting announcement and promotional activities relating to the Program and carrying out corporate communication activities. Your personal data may be transferred abroad in accordance with the conditions and appropriate safeguards stipulated under Article 9 of the Law, where the information technology, cloud, e-mail and similar services procured by the Company and social media platforms are provided through service providers or data centers located abroad. |
DATA PROCESSING ACTIVITY: MANAGEMENT OF INFORMATION SECURITY PROCESSES |
Personal Data Processed Transaction Security Data: Cookies, IP Address, User-Agent (Browser/Operating System), Request Time, Requested Resource, HTTP Status Code and Referrer Address, IP-Based Geolocation, Page View Data, Session Information, Device and Traffic Source Data Purposes of Processing Personal Data Creation and Monitoring of Website Visitor and Access Logs, Analysis of Website Usage and Visitor Traffic, Provision of Video Content and Monitoring of Viewing Data, Improvement of User Experience and Website Performance, Management of Information Security Processes, Detection and Prevention of Unauthorized Access and Security Breaches, Conduct of Activities in Compliance with Applicable Legislation, Conduct of Retention and Archiving Activities, and Provision of Information to Authorized Persons, Institutions and Organizations |
Legal Bases for Processing Personal Data Your personal data are processed by the Company for the purposes specified below on the legal bases of “Being expressly provided for by law”, “Processing being mandatory for the data controller to fulfill its legal obligations”, “Processing being mandatory for the legitimate interests of the data controller, provided that the fundamental rights of the data subject are not prejudiced” and “Explicit consent.” |
Methods of Collection of Personal Data The personal data specified above are collected through automated logging software programs and servers during your visit to the Company’s website, completion of electronic forms and delivery of training videos*. |
Transfer of Personal Data Your personal data provided to us for the purposes specified above may, where requested within the scope of Article 28 of the Law, be transferred to the relevant authorities without being subject to the obligation to provide clarification and without obtaining your explicit consent. Furthermore, in unforeseen circumstances, where expressly provided for by law and upon request, your personal data may be transferred to public institutions specified by law (including Ministries, judicial authorities and administrative authorities such as law enforcement authorities), within the purposes and limitations prescribed by the relevant legislation. In addition, your personal data may be shared with suppliers and service providers engaged in these areas for the purposes of creating, hosting and managing electronic forms, providing and managing video content*, and providing website, information technology, server, cloud, e-mail, communication, archiving and analytics services. Your personal data may be transferred abroad in accordance with the conditions and appropriate safeguards stipulated under Article 9 of the Law, where the information technology, cloud, e-mail and similar services procured by the Company are provided through service providers or data centers located abroad. |
4. 4. YOUR RIGHTS UNDER THE LAW
As personal data subjects, if you submit your requests regarding your rights through the Data Subject Application Form published at mastersucool.sabanciuniv.edu, or by using the methods specified in the Communiqué on the Procedures and Principles of Application to the Data Controller, the Company shall process and conclude your request free of charge, depending on the nature of the request, as soon as possible and in any event within thirty days at the latest. Within this scope, personal data subjects have the right to:
- learn whether their personal data are being processed;
- request information if their personal data have been processed;
- learn the purpose of the processing of their personal data and whether such personal data are used in accordance with the relevant purpose;
- know the third parties to whom their personal data are transferred, whether domestically or abroad;
- request correction of their personal data where such data have been processed incompletely or inaccurately, and request that the relevant correction be notified to third parties to whom the personal data have been transferred;
- request the deletion or destruction of their personal data where the reasons requiring their processing no longer exist, even though such personal data have been processed in accordance with the Law and other applicable legislation, and request that the relevant action be notified to third parties to whom the personal data have been transferred;
- object to the occurrence of a result against the data subject arising from the analysis of processed personal data exclusively through automated systems; and
- claim compensation for damages suffered as a result of the unlawful processing of personal data.
Our Website contains links to websites operated by third parties. The Company has no involvement in, or responsibility for, the policies and procedures applied by such third parties in relation to the processing of personal data.
- The personal data and processing activities marked with “*” in this Text shall apply if your application to the program is evaluated positively and you acquire the status of a “Participant”.
Data Controller | Sabancı Üniversitesi Inovent Fikri Mülkiyet Hakları Yönetim Ticaret ve Yatırım A.Ş. (Tax Identification No: 4650296747) |
Address | Sabancı Üniversitesi Yerleşkesi, Orta Mahalle, Üniversite Caddesi, Rektörlük Binası No: 27 P/1, 34956 Tuzla / İstanbul |
Contact |