SmartHR Insan Kaynaklari ve Proje Yonetim Ltd. Sti.
Version 1.0
Updated: 01 June 2020
In this Privacy Policy, the following capitalized terms shall have the following meanings:


Provider (also referred to as “we” or “us” herein) is Smarthr Insan Kaynaklari ve Proje Yonetim Ltd. Sti. Tax. No: 772 067 6187, with its registered office at Alsancak Mahallesi, 1481 Sokak No:9/9 , Konak / İzmir / Turkey as operator and administrator of the online platform available from the website Smarthronline and its national mutations (the website) and provider of the other services available through the website (services).


Talent is any person who has registered and is looking for a job opportunity through the Website.


Company is anyone, who makes job offers through the Website with the intention of attracting the Talents.

Interested Party

Interested Party is anyone who subscribes to the newsletter on the Website.

T&Cs for Talents

T&Cs for Talents means the terms and conditions for use of the Website Smarthronline for Talents available here.

T&Cs for Companies

T&Cs for Companies means the terms and conditions for use of the Website Smarthronline for Companies available here, including a possible contract signed offline between the Provider and the Company.

Please read how we process your personal data if you are a Talent, an Interested Party or a representative of a Company (you). This document provides important information about your rights.

Who will process your data

The Controller of your data is the Provider and the Company, about whose job offer or job opportunity you are interested through the Website (the Provider and Company are hereinafter referred to as the Data Controller). You may reach each the Data Controller at their registered address or at the email

Why Data Controllers process your data and what personal data is involved

We as the Provider are processing your data for the following purposes:

  • To provide our Services: In order to fulfill our contractual obligations to you under the T&Cs for Talents or the T&Cs for Companies. This includes an obligation to connect you as the Talent with the Company, an obligation to pay, under certain conditions, the Talent a remuneration as well as an obligation to send a notifications according to your settings. This is the fulfillment of the contract between you and us. In case You are a representative of the Company, then the purpose is to connect your Company and the Talent. That is our legitimate interest. For this purpose, we may use your data that you have provided to us or will provide in the future by submitting your registration or your Talent profile. If you are a representative of the Company, then we process your contact information.
  • To send newsletters: If you have subscribed to a newsletter, we will occasionally send you a newsletter about our Services to fulfill your order. If you have registered on the Website and have not refused to receive newsletters about our Services, we may occasionally send you such a newsletter because it is our legitimate interest. You can reject newsletters anytime, as described below. If we explicitly ask you if you want to receive our newsletter and you do not confirm your interest, we take it as a refusal to process and we will not send you newsletters.
  • To protect our rights. This is particularly in cases when the Provider refuses or cancels the registration. In any case, the Provider may keep your data that is necessary to claim its rights and to know that the Talent was registered or would have liked to have been registered. Also after you cancel your registration, we may need your information to claim or protect our rights. Such purpose is our legitimate interest and we may use your information that you have given us or you will be transmitting in the future during negotiations on use of the Website. Specifically, the data can include your name, contact details, and information about the registration process. The Company processes your data to negotiate your employment contract. That is a step taken prior to the entry into a contract with you at your request. Specifically, by showing your interest in a job offer or a job opportunity of a particular Company, you are requesting the opening of negotiations on an employment contract. Until you conclude the employment contract, the process is a non-binding act that you can interrupt at any time. For this purpose, the Company may use your data that you have provided to us or will provide in the future by submitting your registration or your Talent profile.

How long will we process your data

Data according to subparagraph (1) – providing services – will be processed for the duration of your registration. Data according to subparagraph (2) – sending newsletters – will be processed until you reject sending newsletters. Data according to subparagraph (3) – negotiating your employment contract – will be processed by the Company until you enter into an employment contract and if you do not enter into an employment contract, within 6 months from the first contact. The Company will then stop processing your data 3 months after the last communication between you and the Company. The Company may also process your data beyond these principles if there is a lawful basis (including your potential consent) and if you are informed about it by the Company.

To whom we may transfer your data

We may transmit your data to a Company about whose job offer or job opportunity you are interested and you show the interest through the Website and further to other Smarthronline group companies who operate the Website in cooperation with us and to other processors who provide us with IT, marketing and other support services, always in accordance with the above-mentioned purposes. If we transmit your data outside of the EU, protection of the data will be ensured under standard contractual clauses or under the Privacy Shield arrangement as applied to USA.

Additional information may be obtained on the European Commission’s websites.

Your rights

Legal rules on personal data protection guarantee you various rights in the area of personal data protection: In the scope guaranteed by legal rules on personal data protection – especially GDPR.

You may request access to your data from us (information about what your specific data we process and how do we work with them); you may request restriction of the processing your data (which means that we do not delete the data but we will not work with them); you may request data deletion (always if the legal conditions are met); and you also have the right to object to the processing of data and you may exercise your right to data portability. To exercise any of these rights, contact us via above mentioned contact details – the easiest way is to send us an email to and we would be glad to help you exercise your rights. If you believe that we are violating legal rules by processing your personal data, you have the right to lodge a complaint with the national supervising authority.

Objections against processing

If you do not agree with using your data to sending newsletters, you may refuse it. The easiest way is to use the link that is in each newsletter, or you can send us an objection by e-mail or letter and, if technically possible, even when you register. If you refuse such processing, we will stop sending you newsletters. You may also refuse other processing based on a legitimate interest and we will limit processing, unless we prove serious and qualified legitimate reasons for processing.