Legal document
Data Subject Request
How to file a request in order to exercise your rights under Article 11 of the KVKK (Turkish Data Protection Law), which information it must carry and how long it takes to be concluded.
This text is a translation provided for information; the binding version is the one in Turkish.
1. The rights you can exercise
Article 11 of Personal Data Protection Law No. 6698 (KVKK, the Turkish Data Protection Law) gives you nine separate rights. All of them are set out below, in the order of the Law and in everyday English.
- To learn whether your personal data is being processed.
- To request information about it if it has been processed.
- To learn the purpose of the processing and whether your data is used in line with that purpose.
- To know the third parties in Türkiye and abroad to whom your data has been transferred.
- To request correction of your data if it has been processed incompletely or incorrectly.
- To request deletion or destruction of your data when the conditions in Article 7 of the Law are met.
- To request that correction and deletion be notified to the third parties to whom your data was transferred.
- To object to an analysis carried out exclusively by automated systems producing a result to your detriment.
- To ask for compensation if you have suffered loss because your data was processed unlawfully.
The third parties data is transferred to
The answer to the fourth right is already published; we do not wait for you to ask.
The full list of the providers that touch your data is published in the sub-processor list, and that list is the first place updated when it changes.
On that list, providers are identified by the work they do and the place of processing, not by their trade name. If you want to learn the trade name, ask and we will tell you: writing to [email protected] is enough, and that request is answered within the same 30 day period. Whether the transfer goes abroad is already stated next to each provider on the list.
The limit of a deletion request
A deletion request does not produce the same result for every record. Records that the Law obliges us to keep cannot be deleted on request.
Your data is kept for the duration of the relationship between us and throughout the limitation periods set out in the legislation. Payment and invoice records are kept for 10 years under Article 82 of the Turkish Commercial Code (at least 5 years under Article 253 of the Tax Procedure Law); even if you delete your account, these records are held for that period and are then anonymised by severing the links to you.
Objecting to an automated assessment
GoTeam is recruitment software and it uses AI in CV analysis. The right of objection in Article 11 is therefore not a clause that stays on paper here, it is a right that is genuinely used.
The assessment is AI assisted. The score is produced against a fixed, evidence based rubric, and the final decision always belongs to a person. If you believe that an exclusively automated analysis has produced a result to your detriment, you may object under Article 11 of Law No. 6698 (KVKK, the Turkish Data Protection Law).
When you send us an objection, we explain the criteria the analysis was produced with. The decision itself sits with the human resources team of the company you applied to, and we pass your objection on to that company as well. What the AI does and does not do is set out on the AI Transparency Notice page.
2. How to file the request
Under Article 5 of the Communiqué on the Procedures and Principles of Application to the Data Controller, the request is made in Turkish and in writing. We have two channels.
- By post or in person. Send your signed petition addressed to Motivex Intelligence Bilişim Yazılım Robotik Sanayi ve Ticaret Anonim Şirketi at Muradiye Mah. Celal Bayar Üniversitesi Kampüsü Küme Evleri Teknokent No: 22 Ofis No: Z-27, 45140 Yunusemre / Manisa.
- From your registered e-mail address. Write to [email protected] from the e-mail address you have previously given us and that is on file in our systems. Writing "Kişisel Veri Başvurusu" in the subject line helps your request reach the right queue faster.
Why we verify identity
The content of the answer we give to your request is personal data. Giving that answer to the wrong person is itself a breach of the data we are obliged to protect. That is the only reason we cannot answer before verifying your identity.
This is why we expect an e-mail request to come from the address on file in our systems. For a request from an address we do not recognise, we ask you to confirm from your registered address or to send a signed petition. If doubt remains about identity, we may ask for further information; what we ask for is only as much as is needed to verify who you are.
A phone call does not take the place of a request. You can call 0551 406 11 90 to ask where the process stands, but the request itself is made through one of the two channels above.
3. Information the request must carry
Article 5 of the Communiqué lists one by one the information a request must carry. We do not turn an incomplete request away, we tell you what is missing; but that exchange makes the process longer.
If you have information or documents that support your request, attach them. In a request about a recruitment process, writing which company and which posting you applied to helps us find your record faster.
- Your name and surname. If the request arrives by post, your signature at the bottom of the petition.
- Your Turkish national ID number. If you are not a citizen of the Republic of Türkiye, your nationality, your passport number and, if you have one, your identity number.
- Your residential or business address for service.
- If you have them, your e-mail address, phone number and fax number for notification.
- The subject of the request. Write which right you are exercising and exactly what you are asking for.
4. Response time and fees
Your request is concluded within 30 days at the latest from the date it reaches us (Article 13/2 of the Law). If your request is accepted we notify you of the action taken, and if it is refused we notify you of the reason, in writing or electronically.
If the answer is to be given in writing, no fee is charged for up to 10 pages. Article 7 of the Communiqué allows a processing fee of 1 Turkish lira for each page above ten. If the answer is given on a recording medium such as a CD or a flash drive, the fee requested cannot exceed the cost of that medium.
We prefer to send the answer electronically, and no page fee arises on that route. If a situation that creates a fee arises, we write the amount to you before sending the answer.
5. We are not always the right recipient
If you applied to a job posting, the data controller for your CV is the company that opened the posting. That company decides for which purpose the data is processed; GoTeam is the data processor working on that company's instructions. The division of duties is set out clause by clause on the Data Processing Agreement page.
The practical consequence for you is this: requests such as deleting or correcting your CV, or asking for the reasoning behind an assessment, are addressed to the company you applied to. You will find that company's name and contact details on the posting page you applied to and in the e-mails you received.
If your request still comes to us, we do not turn it away. We pass your request on to the company concerned and write to you telling you which company we sent it to and when. In that case the thirty day period is that company's response period.
If you bought the CV Analysis service in your own name, the situation is different. There, the data controller for the CV you uploaded is directly Motivex Intelligence Bilişim Yazılım Robotik Sanayi ve Ticaret Anonim Şirketi, so the channels on this page are the right recipient. For account details, payment records and site usage data we are also the direct recipient. Which data is processed for which purpose is set out on the KVKK Privacy Notice page.
6. Complaint to the Board
To be able to lodge a complaint with the Personal Data Protection Board, you must have applied to us first. Article 14 of the Law states that the complaint route cannot be taken before the application route has been exhausted.
If your application is refused, if you find our answer insufficient or if you receive no answer at all within 30 days, you can complain to the Board. The period is limited to 30 days from the date you learn of our answer and in any case to 60 days from the date of the application.
A complaint is made according to the procedure the Board itself publishes. If your personal rights have been harmed by unlawful processing, your right to claim compensation under the general provisions is reserved (Article 14/3 of the Law).
Other legal documents
- Terms of ServiceWho opens the account, how the service may be used and where liability stops.
- Transaction GuideThe steps an order goes through, how to correct a mistake, where the contract is kept.
- AI Transparency NoticeWhat the AI does, what it does not do and how to object to a decision.
- KVKK Privacy NoticeWhich personal data is processed, for what purpose and on what legal ground.
- Privacy PolicyWhere data is stored, who it is shared with and how it is protected.
- Cookie PolicyWhich cookies are used and which of them need your permission.
- Data Processing AgreementThe split of duties between controller and processor for candidate data.
- Pre-Contract Information FormThe price, term and conditions to know before ordering a subscription.
- Business Subscription AgreementThe parties, delivery, renewal and termination of a subscription sale.
- Cancellation and Refund PolicyRefund conditions for subscriptions, credit packs and CV Analysis purchases.
- GDPR NoticeA data protection summary for users reaching the service from the European Union.