1. INTRODUCTION

    This Privacy and Cookie Policy applies to Elegant Information Technologies Software and Hardware Joint Stock Company (hereinafter: Elegant).

    Elegant is committed to protecting the personal data of its website visitors, job applicants, employees, former employees, self-employed persons/paid employees deployed through Elegant and (potential) business connections. We only process personal data in accordance with this Privacy and Cookie Policy. We process and protect your personal data with care.

    Personal data are data that can be traced back to individual persons, such as a phone number, email or home address. We are transparent about the data that we collect, how we use them and for what purpose. In this Privacy and Cookie Policy, the following issues will be addressed:

    • Why do we collect your personal data?
    • What personal data do we collect?
    • With whom do we share your personal data?
    • How do we protect your personal data?
    • Do we process your personal data outside Europe?
    • How long do we keep your personal data?
    • What rights do you have with regard to the processing of your personal data?
    • What cookies do we use?
    • Changes to this Privacy and Cookie Policy
    • Privacy Officer and deputies

    2. WHY DO WE COLLECT PERSONAL DATA?

    Personal data will only be stored if the processing of your personal data is lawful. Elegant collects, processes and administers personal data for the following purposes:

    • For the purposes of a job application: to assess the suitability of the applicant for a position within Elegant.
    • For the purposes of an employment contract: to configure and administer the employee and payroll records, pension, mobility, absence and facilities. For the purposes of personal development: training, assessment and career counselling.
    • For the purposes of contacts with business connections: to make transparent and maintain contact with (potential) clients.
    • For the purposes of contracts with clients: the preparation, formation, execution and termination of contracts with clients for the deployment of employees and self-employed persons/paid employees deployed through Elegant.
    • For the purposes of contracts with suppliers/business partners: the preparation, formation, execution and termination of contracts.
    • For instance for the purposes of cooperation or the deployment of external candidates (self-employed persons or paid employees) at Elegant or through Elegant at its clients.
    • For the purposes of communication: to make an offer regarding the provision of services and other activities of Elegant and/or to provide and exchange information about these services and other activities.
    • For the purposes of the protection of Elegant: the registration of those present (paid employees, self-employed persons, employees of suppliers and visitors).

    3. WHAT PERSONAL DATA DO WE COLLECT?

    Elegant collects, processes and administers personal data of job applicants, employees and former employees, self-employed persons/paid employees deployed through Elegant and (potential) business connections.

    Business contracts are for example: clients, suppliers and subcontractors that provide services or execute assignments (processors) for or on behalf of Elegant and government agencies. The data that we collect depends on your relationship with Elegant or from the service within Elegant that you use. Job applicants (including unsuccessful applicants)

    • Name, address, city, date of birth, phone number and email address.
    • Curriculum vitae (cv), including photographs.
    • Result online assessment.
    • References and testimonials.

    Employees, former employees and self-employed persons/paid employees deployed through Elegant

    • Name, address, city, date of birth, phone number and email address.
    • Curriculum vitae (cv), including photographs.
    • Result online assessment.
    • References and testimonials. Data required for the employee, payroll and absence records.
    • Data about training courses or practical training completed or to be completed.
    • Data regarding the performance of the employee.
    • Data on the position and/or the termination thereof.
    • Other data the processing of which is necessary for the purposes mentioned above or required or necessary pursuant to a statutory provision.

    Visitors to Elegant

    • Name.
    • Where applicable: company name.

    (Potential) business connections

    • Company name and address.
    • Name, email address and/or telephone number of the contact person.
    • Job title.
    • Curriculum Vitae (cv) including photographs

    4. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

    In a number of cases, Elegant will supply your personal data (where necessary) to business connections. We only share your personal data with these third parties in accordance with the purposes you have been informed about. Furthermore, we may share your personal data with the government, law enforcement agencies and/or supervisory bodies if required by law.

    5. HOW DO WE PROTECT YOUR PERSONAL DATA?

    We treat personal data confidentially and with the greatest possible care. Elegant protects its systems – within reason – against the loss and/or any form of unlawful use or processing. It uses appropriate technical and organisational measures, taking into account the state of the art. Your data are properly secured in accordance with the applicable privacy laws and regulations. For more information, please refer to our Information Security Policy.

    6. DO WE PROCESS YOUR PERSONAL DATA OUTSIDE EUROPE?

    In some cases, we may transfer your personal data to third countries or organisations outside Europe. In that case, Elegant will ensure that proper measures are taken to guarantee a suitable protection level.

    7. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

    The retention periods that we use for your data depend on your relationship with Elegant.

    Job applicants (including unsuccessful applicants)

    • No longer than 2 year after the rejection (without permission).
    • No longer than 1 year after the rejection (with permission).

    Current employees, former employees and self-employed persons (deployed through Elegant)

    • Main rule: the personnel file including application file will be kept for no longer than 2 years after termination of the employment.
    • Exception 1: payroll tax statements, copy ID of employees and copy ID hired personnel with work permit will not be kept for longer than 5 years.
    • Exception 2: all documents that must be retained under tax legislation will not be kept for longer than 7 years.

    (Potential) business connections

    • The personal data that are processed for business relationship management purposes will be kept as long as the relationship exists and/or as required by law.
    • The personal data that are processed for the execution of work (projects and/or management) at clients will be kept in accordance with the agreements made with the client.

    Visitors to Elegant

    • No longer than 6 months after the right of access has expired.

    8. WHAT RIGHTS DO YOU HAVE WITH REGARD TO THE PROCESSING OF YOUR PERSONAL DATA?

    If you have questions about what data are collected about you and for what purpose, Elegant is always willing to provide you with information on this. You have the right of access to the personal data that we process about you and to have them corrected or removed; you also have the right to restrict the processing as well as to object to the processing and the right to data portability. Furthermore, you are entitled to withdraw the permission that you gave. If you have one of the requests mentioned above, you may submit it in writing to info@elegantyazilim.com. Finally, you are entitled to submit a complaint to the supervisory authority.

    9. WHAT COOKIES DO WE USE?

    Apart from personal data, Elegant uses ‘cookies’. A cookie is a small file that is saved on your hard disk by a server and that is only recognised by the server that saves the cookie. A cookie informs our server that you have returned to a certain page of our site. Cookies do not register any personal data, such as your name, address, phone number, email address or other data that can be traced back to you. We use cookies or similar means to gather information during your visit to our website, such as your IP address (a number that is assigned to your computer if you surf the Internet), the date and time of your visit to the site. If you wish, you can configure your browser in such a way that cookies are rejected or that you receive a warning when cookies are sent. The data that cookies collect can be used for statistics related to the site – anonymous and as a total number- to assess the use of the website. We feel that it is important to mention what cookies we use and for what purposes we use them. Below, you will find cookies and corresponding methods that are placed through our website.

    Analytical cookies

    Elegant uses analytical cookies to compile visitor statistics, such as the number of visitors and the duration of the visits. This provides us with a better understanding of the functioning of the website. The statistics that we gather cannot be traced back to individual persons. We use Google Analytics to gain an insight based on the data gathered. We always place the analytical cookies when you visit our website.

    Elegant reserves the right to make changes to this Privacy and Cookie Statement. Each substantive change will be published on this page. We recommend that you consult this Privacy and Cookie Policy regularly, so that you are always aware of the contents of the applicable Privacy and Cookie Policy.

    11. PRIVACY OFFICER AND DEPUTIES

    If you have any questions, comments or complaints about the protection of your personal data by Elegant, you may contact us by email using the following addresses: info@elegantyazilim.com