J-START PROGRAM APPLICANT CLARIFICATION TEXT ON THE PROTECTION OF PERSONAL DATA
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 the “J-Start Program” (“Program”).
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 |
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| Personal Data Processed Identity Data: Name, Surname, Gender Contact Data: E-Mail Address, Telephone Number Educational Status, Professional Experience and Resume Data: Educational Status, University and Department Graduated From / Expected to Graduate From, Academic Status, Employment Status, Brief Resume, LinkedIn Profile Information, Information Regarding Sectoral and Professional Experience Application, Venture and Project Data: Country and City in Which the Venture Is Based, Venture / Company Name and Description, Information Regarding the Problem Addressed by the Venture, Information Regarding the Product or Service and Their Differentiating Features Compared to Competitors, Information Regarding Domestic and Foreign Competitors, Target Customer Group and Its Characteristics, Technology Readiness Level (TRL), Current Achievements and Development Status of the Venture, Future Objectives and Planned Activities, Revenue Model, Information Regarding Programs and Support Previously Utilized and Investments Previously Received, Information Regarding Whether the Applicant or the Venture Holds Any Patents, Information Regarding Persons Involved in the Venture Team and Their Roles Within the Venture, Information Regarding Presentations, Documents, Promotional Videos and Links Thereto, and Additional Notes, Explanations, Information and Documents Shared Within the Scope of the Application Financial Data: Current Budgetary Needs of the Venture, Turnover Information for the Last 12 Months, Financial Information Regarding Investments Previously Received Purposes of Processing Personal Data Management, Finalization and Provision of Feedback in Relation to Program Application Processes, Evaluation of the Applicant’s and the Venture/Project’s Eligibility for the Program, Technical, Commercial and Financial Assessment of the Venture Idea, Verification and Evaluation of the Information and Documents Submitted Within the Scope of the Application, Management of Selection, Evaluation and Admission Processes Within the Scope of the Program, Planning, Conduct and Organization of Program Activities, Matching the Applicant with Suitable Experts, Mentors, Evaluators and Other Program Stakeholders, Management of Entrepreneurship, Mentorship, Acceleration and Investment Processes, Communication with Applicants and Conduct of Informational Activities, Maintenance of Records Relating to Program and Investment Processes, Conduct of Retention and Archiving Activities, Ensuring that Activities Are Conducted in Compliance with Applicable Legislation and Relevant Program Rules, Fulfillment of Legal Obligations, Provision of Information to Authorized Persons, Institutions and Organizations, and Establishment, Exercise and Protection of Legal Rights in Potential Future Disputes |
| 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” and “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 the contract.”. |
| Methods of Collection of Personal Data The personal data specified above are collected electronically, by partially or fully automated means, through the Company’s website, electronic application forms provided via the Airtable platform, the information and documents submitted by you through such forms, and presentations and documents relating to the venture/project subject to the application. |
| 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 and funding persons/institutions, particularly Sabancı University, for the purposes of conducting program application, evaluation, selection and program processes, finalizing applications, providing feedback to applicants and organizing program activities. 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 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. |
| 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, 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 above 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 visits to the Company’s website and the AirTable platform on which the application form is hosted, and while completing electronic forms. |
| 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 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. 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 www.inovent.com.tr, 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 Applicant is responsible for providing the necessary information and ensuring that the applicable legal requirements are satisfied for the sharing of personal data relating to third parties.
| Data Controller | Sabancı Üniversitesi Inovent Fikri Mülkiyet Hakları Yönetim Ticaret ve Yatırım A.Ş. (Tax Identification No: 4650296747) |
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| Address | Sabancı Üniversitesi Yerleşkesi, Orta Mahalle, Üniversite Caddesi, Rektörlük Binası No: 27 P/1, 34956 Tuzla / İstanbul |
| Contact | info@inovent.com.tr |