PRIVACY POLICY OF UPLICO

1. Introduction

UPLICO TEKNOLOJİ ANONİM ŞİRKETİ ("Uplico," "we," or "us") operates as a curriculum vitae (CV) management platform designed to assist companies in overseeing and processing job applications. We are dedicated to safeguarding your personal data and ensuring compliance with applicable data protection laws.

This Privacy Policy sets forth the types of information we collect, the purposes for which we use that information, the measures we employ to protect it, and your associated legal rights. By accessing or using our website at www.uplico.com (the "Website") and/or our associated platform, extension, or application (collectively, the "Service"), you acknowledge and consent to the practices described herein. If you do not agree with the provisions of this Privacy Policy, please refrain from using our Service.

2. Definitions and Key Terms

The following definitions apply throughout this Privacy Policy:

• Cookie: A small data file placed on your device by your web browser, used to identify your browser session, provide analytics, store preferences, and remember login information.
• Company: Refers to UPLICO TEKNOLOJİ ANONİM ŞİRKETİ, located at Esentepe Mah. Talat Paşa Cad. No: 5 İç Kapı No: 1, Şişli, İstanbul, Türkiye, which is accountable for your data under this Privacy Policy.
• Country: The jurisdiction in which Uplico is based; in this case, the Republic of Türkiye.
• Customer: Any individual or entity (e.g., a hiring company or recruiter) that registers with Uplico to manage job applications and candidate data through our Service.
• Device: Any Internet-enabled equipment (e.g., desktop computer, laptop, mobile phone, or tablet) used to access our Service.
• IP Address: A numerical label assigned to each device connected to the Internet, used to determine the device's location and enable communication.
• Personal Data: Information relating to an identifiable natural person, either directly or in combination with other data.
• Third-Party Service: Refers to external advertisers, business partners, or other service providers whose offerings may be incorporated into our Service.
• You: An individual user or representative of a legal entity using our Service for professional or recruitment-related purposes.

3. Information We Collect

We collect various categories of information from and about users of our Service, including:

1. Personal Data: This may include your name, physical address, email address, telephone number, payment details, and any other identifiers enabling online or offline contact.
2. Usage Data: Data regarding your interaction with our Service, such as visited pages, duration of session, clickstream data, and other statistical usage information.
3. Applicant Documents: Résumés, CVs, cover letters, supporting certificates, and other relevant documentation submitted through the Service in furtherance of recruitment processes.
4. Location Data: Information relating to your geographic location, collected where you have granted permission to access it.
5. Device Information: Technical details about your equipment, including operating system, browser type, IP address, and unique device identifiers.

4. How We Collect Information

4.1 Direct Collection

• Account Registration: When you register an account, we request your name, email address, password, and other necessary credentials.
• Profile Details: Information you choose to add to your profile, such as your professional experience, skill sets, or additional preferences.
• Applicant Submissions: Any résumés, cover letters, or related materials uploaded to our platform for hiring or recruitment purposes.
• Customer Support: Information provided when contacting us for assistance or submitting general inquiries.
• Surveys and Feedback: Responses to voluntary surveys, feedback forms, or promotional offers.

4.2 Automatic Collection

• Usage Data: Metrics regarding how you navigate our Service, including features utilized, pages visited, and time spent on specific sections.
• Device Information: Technical specifications of the device you use to connect to our Service.
• Location Data: Where enabled, geolocation data retrieved from your device.
• Cookies and Similar Technologies: Files that monitor session activity and personalize user experience.

4.3 Collection from Third Parties

• Recruitment Platforms: Data from integrated third-party job boards or recruiting tools.
• Service Providers: Data from business partners who assist in our services.
• Publicly Available Sources: Information from open databases or other lawful sources.

5. Purposes for Processing Personal Data

We use the information we collect for the following lawful purposes:

1. Service Provision and Maintenance: To enable and support the features of our CV management platform and ensure the platform functions smoothly.
2. Personalized Experience: To tailor content, notifications, and recommendations based on your stated preferences or prior usage.
3. Communication: To send administrative messages, including confirmation emails, updates regarding feature changes, security notifications, and support responses.
4. Marketing and Promotional Messages: To inform you about product enhancements, new features, and events that may be relevant, provided you have not opted out.
5. Transaction Processing: To facilitate payments, subscription fees, or other monetary transactions related to your use of the Service.
6. Analytics and Improvement: To evaluate user engagement, identify performance trends, and improve functionality across the Service.
7. Legal and Regulatory Compliance: To satisfy applicable legal requirements, resolve disputes, and enforce contractual obligations in Turkey and for other needed countries with CCA and for other law codes.
8. Security and Fraud Prevention: To detect, prevent, or investigate potential fraud, unauthorized access, or illicit activities.

6. Treatment of Applicant Documents and Other User-Submitted Content

We recognize the sensitivity of materials submitted to our platform, such as résumés and supporting documents:

1. Limited Use: We use these materials strictly for the hiring or recruitment purposes you or your organization have authorized.
2. Secure Storage: Applicant documents are temporarily stored on encrypted servers while they are in active use by authorized account holders.
3. Data Retention and Deletion: Upon completion of the recruiting cycle or at your discretion, documents may be archived or permanently deleted in accordance with applicable laws and the needs of the Customer.
4. No Unauthorized Use: We do not exploit these documents for marketing or other unrelated activities without obtaining explicit consent.
5. User Control: Applicants, recruiters, or hiring personnel may remove or purge these documents at any point, subject to relevant recordkeeping requirements.
6. No Automated Profiling with Legal Effect: We do not engage in automated decision-making that could produce legally significant consequences for applicants.

7. Use of Third-Party Information

We may integrate data from external sources in order to enhance your experience:

• Recruitment Integrations: If you link Uplico to external recruiting or job listing sites, we may process relevant applicant information or job postings.
• Analytics Providers: Data from analytics services is employed to measure user behavior, trends, and system performance.
• Advertising Partners: Where applicable, we may receive information allowing us to deliver or measure targeted advertisements.

8. Disclosure of Personal Data to Third Parties

We may disclose your data in the following circumstances:

1. Service Providers: Engaged entities that carry out tasks on our behalf, such as web hosting, data analysis, payment processing, and customer support. These entities are contractually bound to safeguard your data.
2. Affiliates and Subsidiaries: Corporate affiliates or subsidiaries, provided such sharing is aligned with the principles set out in this Privacy Policy.
3. Business Transactions: In the event of a merger, acquisition, asset sale, or similar corporate transaction, personal data may be transferred as part of the proceedings.
4. Legal Obligations: Where required by law, for instance, in response to subpoenas, court orders, or official requests by governmental authorities.
5. Protection of Rights: To enforce our Terms of Service, or if necessary, to protect our operations, property, or the safety of our users or other individuals.
6. Consent: We will share your data with third parties if you have expressly consented to such sharing.

Uplico does not sell or rent your personal information to third parties for their independent marketing purposes without your explicit consent.

9. Third-Party Services and External Links

Our Service may include hyperlinks to third-party websites, services, or applications. We assume no responsibility for the privacy practices of these external parties. Users are advised to consult the respective privacy policies of external sites before disclosing any personal information.

10. Cookies and Other Tracking Technologies

We utilize cookies and similar tools for a range of purposes:

1. Authentication: To recognize and maintain sessions for returning users.
2. Preferences and User Experience: To store user preferences, thereby streamlining navigation.
3. Analytics and Performance: To gather insight into user interactions, enabling service enhancements.
4. Advertising (If Applicable): To present relevant advertisements and gauge their efficacy.

Types of Cookies:

• Session Cookies: Remain active only while the browser session is open.
• Persistent Cookies: Remain on your device until a predetermined expiration or manual deletion.

Managing Cookies: You may adjust browser settings to block or delete cookies. However, disabling cookies may limit functionality within the Service.

11. Advertising and Analytics

We partner with select advertising networks and analytics services for:

1. Interest-Based Advertising: Displaying relevant ads based on observed preferences (if such activities are undertaken).
2. Usage Metrics: Tracking usage trends to diagnose issues and refine features.

These third parties may employ their own cookies, web beacons, or other tracking technologies to gather information about how you interact with our Service and other websites.

Opt-Out Procedures:

• Interest-Based Advertising: Adjust your browser settings or use recognized opt-out tools, such as those provided by the Digital Advertising Alliance or Network Advertising Initiative.
• Analytics: Install the Google Analytics Opt-Out Browser Add-on, if you wish to opt out of data collection by Google Analytics.

12. Data Security Measures

We implement industry-recognized safeguards to protect your personal information:

1. Encryption: Data exchanged with our servers is secured using Secure Socket Layer (SSL) or Transport Layer Security (TLS).
2. Access Controls: Only authorized personnel who require access for legitimate business purposes may handle sensitive data.
3. Secure Data Centers: Information is stored on servers with high-level physical and electronic protections.
4. Ongoing Assessments: Regular security reviews are performed to address evolving threats.

Despite reasonable efforts, no Internet-based system can guarantee absolute security. Users are encouraged to take appropriate precautions to protect their accounts.

13. Data Retention

We retain personal data only for as long as necessary to fulfill the objectives outlined in this Privacy Policy or to comply with legal obligations, including:

1. Statutory Compliance: Meeting mandates set forth by data protection, tax, and other relevant legislation.
2. Dispute Resolution: Handling potential claims or enforcing contractual provisions.
3. Legitimate Business Interests: Supporting operational, administrative, and auditing needs.

When no longer necessary, personal data will be securely deleted or anonymized in accordance with applicable data protection laws.

14. Your Rights and Choices

1. Access and Rectification: You have the right to request access to and correction of your personal information. Updates can be made within your account settings or by contacting us at info@uplico.com.
2. Erasure: You may request the deletion of your account and associated data, subject to any retention obligations under law or legitimate interests.
3. Marketing Preferences:
   • Opt-Out: You can opt out of promotional email communications by clicking the "unsubscribe" link or amending your account notifications.
   • Device Notifications: Configure your device settings to limit push notifications or alerts.
4. Location Services: Disable location sharing in your device settings if you prefer not to share your real-time location.
5. Cookies and Trackers: Configure your browser to reject cookies or notify you when they are in use.
6. Do Not Track: Our Service does not respond to Do Not Track signals, though you can reduce certain tracking activities by using your browser's settings or trusted extensions.

15. International Data Transfers

When transferring your data outside your home jurisdiction, we employ legally recognized safeguards, such as:

• Standard Contractual Clauses: Binding clauses that enforce the level of protection required under applicable privacy regulations.
• Approved Frameworks: Participation in recognized data transfer frameworks, where available, to ensure appropriate protection standards.

16. Children's Privacy

Our Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from minors. If it comes to your attention that we have inadvertently processed data related to a minor, kindly contact us at info@uplico.com so we may take the necessary steps to remove such data.

17. European Economic Area (EEA) Residents: GDPR Rights

If you reside in the EEA, you may have the following data protection rights under the General Data Protection Regulation (GDPR):

1. Right of Access: The right to request copies of your personal data.
2. Right to Rectification: The right to correct inaccuracies in your personal data.
3. Right to Erasure ('Right to be Forgotten'): The right to request the deletion of certain personal data under specific circumstances.
4. Right to Restrict Processing: The right to limit the processing of your personal data where lawful grounds apply.
5. Right to Object: The right to object to certain types of data processing, including direct marketing.
6. Right to Data Portability: The right to obtain a copy of your personal data in a structured, commonly used, and machine-readable format.
7. Right to Withdraw Consent: Where Uplico relies on consent for data processing, you have the right to revoke such consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at info@uplico.com. We may request documentation or verification to confirm your identity before proceeding with your request.

18. California Residents: CCPA Rights

California residents are afforded specific rights under the California Consumer Privacy Act (CCPA):

1. Right to Know: Request disclosure of the categories and specific pieces of personal data collected about you.
2. Right to Delete: Request the deletion of your personal data, subject to certain exceptions.
3. Right to Opt-Out of Data Sale: We do not sell personal information; however, you may exercise the right to opt out if our practices change.
4. Right to Non-Discrimination: We shall not discriminate in terms of price or service offerings based on your choice to exercise these rights.

You may submit such requests via info@uplico.com or telephone at +90 212 924 24 10. Verification of your identity may be required for the protection of your data.

19. Changes to This Privacy Policy

We reserve the right to amend or supplement this Privacy Policy at our discretion and will publish any updated version on this page with a revised "Last Updated" date. Where material changes occur, we will provide additional notice or obtain your consent if required by law. We encourage you to periodically review this Privacy Policy to remain informed of your data protection rights and our practices.

20. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of Türkiye, specifically Istanbul (Çağlayan), without reference to its conflict of law principles. You hereby consent to the exclusive jurisdiction and venue of the competent courts located in Istanbul (Çağlayan), Türkiye, for the resolution of any disputes arising out of or relating to this Privacy Policy.

21. Your Consent

By proceeding to use our Service, creating an account, or otherwise interacting with Uplico in the context of recruitment or candidate management, you acknowledge and agree to be bound by the terms of this Privacy Policy.

22. Contact Us

We appreciate your interest in our data protection practices. If you have any queries, concerns, or comments regarding this Privacy Policy or related matters, please contact us using the details below:

• Company Name: UPLİCO TEKNOLOJİ ANONİM ŞİRKETİ
• Address: Esentepe, Kolektif House Esentepe Mahallesi Talatpaşa Caddesi No: 5 / 1, Levent, İstanbul, Talatpaşa Cd. No: 5/1, 34394 Şişli/İstanbul, Türkiye
• Email: info@uplico.com
• Phone: +90 212 924 24 10

Thank you for placing your trust in Uplico. We remain committed to protecting your personal data and ensuring compliance with all relevant data protection laws.