Privacy Policy

We, İde Yönetim Danışmanlığı A.Ş. – Strategic Partner of Aon & Kincentric in Turkey (İde Consulting), provide services related to Human Resources and Management Consultancy, including employee engagement and culture studies, leadership development, HR assessment, and human resources strategy. In delivering these services, it is necessary for us to collect, store, use, and analyze personal data.

This policy sets out the basis for the processing of all personal data collected from you, provided by you when using our online data collection platform ("FikrinNe" or "Platform") or provided by your employer on your behalf, in accordance with applicable laws (including the Personal Data Protection Law numbered 6698, relevant regulations, and any other current or future legislation).

Processing of Personal Data

In the context of this policy, the term "your employer" refers to the organization that has signed a contract with us, as required by law, regardless of whether you are an employee, consultant, or contractor of that organization.

When we refer to "personal data" in this policy, we mean any information related to you that can be directly or indirectly identified. This information may include not only details such as your name, surname, date of birth, or place of birth but also information related to your physical, familial, economic, social, and other characteristics.

Within the scope of our activities and services, we process data related to:

Employees, contractors, or consultants ("Survey Participants") who are granted access to our Platform and invited to complete surveys by their employers (in cases where employers are current clients).
Authorized users ("Authorized Users") who use the Platform on behalf of their employers (in cases where their employers are current clients).

To understand how we process your personal data, please read this policy carefully.

Our Legal Responsibilities

İde Consulting, as part of the agreement ("Contract") signed with your employer to grant you access to the Platform and/or participation surveys completed on the Platform or through the Platform, acts as the data processor. Under this Contract, your employer is the data controller for your personal data. We will process your personal data transmitted to us by your employer and the information you provide to us and/or upload to the Platform (whether or not it constitutes personal data) on behalf of your employer and in accordance with their legal instructions, for the purpose of providing the services specified in the Contract.

The Information We Processs

We will process the following data about you as described below:

Information provided by your employer:

Your employer provides us with your personal data to create a user profile or participant profile for you on the Platform, allowing you to access the Platform (whether as a trial or authorized user) or receive participation surveys and similar communications. Alternatively, your employer may upload your personal data to the Platform.

The scope of the information transmitted or uploaded is determined by your employer in line with the purposes of the signed Contract. This information may include, but is not limited to, your name, company email address, department, job title, seniority level, age or date of birth, start date of employment, and workplace location.

Information you provide when using the Platform's features:

The scope of information collected in surveys is determined by your employer. This information may include, but is not limited to, your age, seniority level, department, workplace location, and any opinions you express regarding colleagues, managers, your employer, or other third parties when completing surveys.

Unless otherwise specified, all responses you provide will be evaluated under our privacy principle, keeping your identity confidential and undisclosed. No data that could potentially reveal your individual identity will be shared with your employer without your knowledge. All reporting will be aggregated into statistical figures and tables.

Information we may automatically collect about you:

When you use the Platform or complete a survey, we may automatically collect the following information:

Details of your usage, including the date, time, location, frequency, and duration of usage.
Comments, ideas, and/or feedback you provide about the Platform.
Technical information about your computer or mobile device for system administration and analysis purposes, including your IP address, URL clickstreams, device identifiers, operating system, and network and browser type.
Other information related to your use of the Platform, including pages viewed, time spent on the Platform, and data files uploaded to the Platform (where applicable, this information may be linked to your user profile).
If you are an Authorized User (using the Platform as a representative of your employer), we may obtain additional information from your employer to confirm your suitability for access to and use of the Platform, such as verifying your access and usage compliance.

Information we may receive from other sources:

During our collaboration with third parties (e.g., business partners, other companies within our group, subcontractors, and analytics data providers), we may obtain information about you. The details of third-party information providers are outlined in the "Disclosure of Your Information" section.

Legal Basis for Processing Your Personal Data

Your personal data, including data sets you upload to the Platform or provide to us, can only be processed within the scope of the purposes defined in the Contract signed with your employer and in accordance with your employer's orders and instructions. This serves as the legal basis for processing your personal data.

When processing your personal data, we may also rely on the following legal bases that are necessary for our legitimate interests or the legitimate interests of your employer:

To fulfill contractual obligations under the agreement with your employer,
To enhance or optimize our services and ensure the security of our computer systems,
To understand how the Platform is used and improve the user experience of the Platform,to protect and defend our legal rights and for troubleshooting, data analysis, testing, and research purposes.

We will use the data provided to us for the following purposes:

If you are an Authorized User, to allow you to become a registered user of the Platform.
To fulfill our contractual obligations arising from the Contract with your employer, including providing your employer with summary reports and analyses of survey results, and (where applicable) to compare this data with past or future employee responses and/or industry benchmarks. (Responding to survey questions is entirely optional: individual questions (or the entire survey) can be skipped, and completing any survey is not mandatory.)
To provide you with the information, products, and services you request from us. (We will not contact you for promotional or marketing purposes, particularly when you have not consented or expressly requested such communication, except when informing you about new products or services we offer, unless you have opted out.)
To contact you for feedback on our services and to evaluate and improve our services based on the feedback you provide.
To inform you about changes to our other services offered on the Platform and to inform you about new versions, features, and functionalities of the Platform.
To resolve issues arising from your use of the Platform.
To address inquiries, correspondence, concerns, or complaints from third parties, including your employer, if applicable, or in connection with any investigations involving or related to third parties.

We may use the information we collect about you for the following purposes:

To manage and improve the delivery of content to you on the Platform and other services in the most effective manner.
To report to your employer, if stipulated as an obligation in the Contract signed with your employer, regarding the use of the Platform.
For internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes.
To allow you to participate in interactive features of the Platform, if you choose to do so.
As part of our efforts to keep the Platform secure and safe.
To generate reports related to Platform usage (without personally identifying you).

We may also combine the information obtained from other sources with the information you provide to us and use it as described above.

Please also note:

Unless explicitly requested or instructed by your employer, we will not conduct any surveys or analyses falling under the category of Sensitive Personal Data (including but not limited to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, sexual life, or sexual orientation) through the Platform. In such cases, obtaining clear consent for such processing is the responsibility of your employer.
Except in exceptional circumstances, as detailed in the section titled "Disclosure of Your Information" below, we will not disclose your responses in a way that would reveal your identity.
Data collected from you and other employees will be used by us in aggregated and anonymized form for statistical and comparative purposes, including enabling comparisons with other organizations in the same industry.

Disclosure of Your Information

We may share your personal data with the third parties listed below in accordance with this policy:

Service providers (such as IT services, business partners, suppliers, and/or subcontractors) to fulfill any contracts we have with your employer.
Government or other law enforcement agencies for the investigation of illegal activities or other legal reasons (in such cases, the shared information may include location data).

We require our third-party service providers and all companies within our group to take appropriate and stringent security measures in line with our policies to protect your personal data. We do not permit our third-party service providers to use your personal data for their own purposes. Our third-party service providers may only process your personal data for specific purposes in accordance with our instructions.

We may also share your personal data with other third parties in the following circumstances:

In the event of a merger or acquisition, or if we invest in our business, we may share your personal data with potential or actual buyers, sellers, or investors who enter into such a relationship with us.
If all of our assets are acquired by a third party, whether on a global or local scale, the personal data processed by us, including your personal data, will be one of the transferred assets, including data related to our customers, suppliers, and their representatives.
We may share your personal data with our legal advisors if they need access to this information to provide advice on our legal rights and obligations.
If we have a legal obligation to disclose or share your personal data under any legal sanction, or to fulfill our Terms of Use or other contractual obligations with you or your employer, or to protect the rights, property, or safety of our customers or other parties, we may share your personal data.

If you are a Survey Participant, please keep in mind the following:

Your survey responses and comments will be aggregated and shared with your employer in an anonymized form, either in bulk or otherwise. Therefore, your responses and comments as a Survey Participant will be protected in a way that does not reveal your individual identity. Please note that we report your responses and comments as they are and do not conduct any research or evaluation regarding their accuracy or legality.
The Platform may include an automatic keyword tagging feature using a keyword list previously accepted by your employer. Any word in the comments within the survey that matches a keyword will be automatically reported to your employer without disclosing your identity. We do not inform you when any keyword from your comments is reported to your employer. The keyword tagging feature operates automatically, and we do not perform any manual control or have any authority to monitor, supervise, or evaluate the transmission of keywords to your employer. With respect to the keyword tagging feature, we (as Survey Participants) waive any liability to the maximum extent permitted by law for any errors or delays in reporting keywords by us and for any actions or omissions by your employer.
Your identity will be disclosed to your employer in exceptional circumstances where there is a significant public interest, even if there is no request from your employer to disclose your identity. These situations are exceptional and may include instances where you or another individual is experiencing or at risk of physical, mental, or emotional harm (including self-harm) and requires support. For example, it may be necessary to disclose your identity to prevent or detect illegal activity (such as fraud or other criminal activities) based on your comments. These situations may also arise when we cannot obtain your consent (for example, if you are not reachable at your workplace), or obtaining your consent would compromise the purpose of disclosure.

Apart from what is described above, we will not disclose your personal data to third parties for any other purpose unless we have a legal right or obligation to do so.

Data Transfers out of Turkey

The collected personal data is stored in server of Ide Consulting in Turkey. We may share your personal data with the companies we represent (Aon & Kincentric) and their affiliates when necessary or requested for the purpose of providing services under the Contract to you or your employer. In cases where explicit consent is not provided, if it becomes necessary to transfer the data abroad for the purpose of the service provided (e.g., benchmarking, Best Employer certification, etc.), the data will be anonymized and transmitted as demographic data, ensuring that it cannot be associated with an individual.

The transfer of your personal data to international servers located outside the Republic of Turkey, to be processed by our business partners (Aon & Kincentric and their affiliates) for the purpose of the Contract signed with your employer, is subject to the regulation and limitations stated in Article 9 of the Law on the Protection of Personal Data No. 6698. In cases where data transfer is mandatory, the shared data will continue to be protected in accordance with the European Union General Data Protection Regulation within the framework of Aon and Kincentric's global standards.

When processed by Aon and Kincentric affiliates outside the European Union, your data is protected by agreements that include European Union Model Clauses, in addition to the protection provisions specified in their privacy policy.

Information Security

When we provide you with access to specific features of the Platform (for example, as a manager or senior executive of your employer) by giving you access credentials such as a username, password, and/or a link including security information, it is your responsibility to keep these access credentials confidential. You should not share these credentials with anyone or store them in a way that allows third parties to access them.

We take the necessary technical and organizational measures to ensure an appropriate level of security for all personal data we process. After receiving your information, we will use security systems appropriate to the type of personal data provided to prevent unauthorized access or accidental disclosure. This may include measures such as two-factor authentication and end-to-end encryption.

Retaining you Information

We will store your personal data for the duration specified by your employer after the termination of the commercial relationship between your employer and us. If no such specific duration is provided, we will store the data for 10 years in accordance with this policy and our legal rights and obligations.

Upon written instruction from your employer, following this period, we undertake to anonymize and delete of the Personal Data in accordance with the Data Protection Legislation. For the avoidance of doubt, aggregated and anonymized data, as well as any information other than personal data, may be stored indefinitely.

Your Rights

Under Article 11 of the Data Protection Law, you have the following rights regarding your personal information. Here are your rights:

Right of Access:

To learn whether your data is being processed and obtain related information,
To learn the purpose of processing your data and whether it's being used for its intended purpose,
To learn the third parties, both domestically and internationally, to whom your data has been transferred.

Right to Object:

You have the right to object to the processing of your personal data when it's carried out on the basis of our (or a third party's) legitimate interests. In such cases, we must cease processing your data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms.

Right to Rectification:

You have the right to request the correction of any inaccurate personal data we hold about you.

Right to Erasure (Right to Be Forgotten):

You have the right to request the deletion of all personal data held about you. However, please note that this right does not apply to non-personal data and that we likely have a valid reason to retain your personal data for evaluating and verifying the data held and presented on the Platform, among other purposes, in accordance with applicable laws. For the avoidance of doubt, we reserve the right to syore your data in an anonymous form for statistical and comparative purposes.

Changing Preferences:

You can change your data processing preferences at any time. For example, if you have previously given consent for direct marketing but change your mind, you can contact us to update your preferences.

As the data subject, you may send your requests regarding your rights under the KVKK's Article 11 to our registered email address (ideyonetim@hs03.kep.tr) or in writing, along with your identity verification, to the following address: Feneryolu Mahallesi, Bağdat Cad. No 155/14 34724 Kadıköy, İstanbul. We will inform your employer in order to access your data (or use any of these rights) and we will respond accordingly.

If you are not satisfied with how we process your personal data for any reason, you also have the right to file a complaint with the relevant supervisory authority in your country. In Turkey, the relevant authority is the Personal Data Protection Authority (KVKK).

Changes to Our Privacy Policy

Any changes we may make to our privacy policy will be published on this page. Continuing to use the Platform means that you accept such changes.

Contact

If you have any querries regarding this Privacy Policy, please contact us at privacy@ideconsulting.com.tr.