You share with us your personal data listed below through the traineeship application form, your C.V., mutual correspondence, calls and interviews with our company. These personal data are processed under the conditions described in this clarification text. Your personal data helps us to get to know you and to assess your aptitude to the vacant positions in our company. 

The Personal Data Protection Law numbered 6698 (KVKK) and other relevant legislations describe some procedures to be observed when processing the personal data. Due to the provisions of the KVKK and other relevant legislation, our company, acting as data controller, is obliged to explain the processing of personal data to you and to obtain your explicit consent in certain cases. This clarification text has been prepared for this purpose.  


1.    Your personal data processed by our company in the context of your traineeship application:

a.    General personal data:

•    Identity Information: Name, last name, date of birth, place of birth, maiden name, marital status, gender, nationality, and similar information included in identification card, discharge certificate, driving licence etc.  
•    Contact Information: Telephone number / gsm number, e –mail address, mail/ domicile address.  
•    Career information: C.V. information, references, Social Security (SGK) Number, information about former employer companies etc. 
•    Information on professional qualifications : Information on your school/university, certificates, diplomas,
education level, titles, certificates/results of our company’s exams given during your traineeship applications etc.   
•    Financial information: Salary / wage (proposal) etc. 
•    Visual and Audial records:  Photographs, image/video and audio records taken during online traineeship interviews.  
•    Other information: Information on smoking habit. 

b.    Particular personal data:

•    Sentence of verdict and security measures: criminal records. 
•    Philosophical conviction, religion, sect and other beliefs: Information on religion included in the identification card.
•    Health information: Blood type, if it is not included in the identification card                           

(Information on religion and blood type is entered unintentionally due to the need to process the identification card or its photocopy including such information, within the context of some activities indicated in the clarification text.)


2.    Purposes for processing your personal data and legal reasons: 

Your personal data is processed within the limits of the following purposes and on the basis of the legal grounds set out in the articles 5 and 6 of KVKK and within the framework required by KVKK and other relevant legislation.

a.    To carry out business activities and the activities ensuring business continuity, to conduct the process of traineeship applications for vacant positions in our company and the process of selection and placement of the suitable candidates, within the described context your personal data is recorded and your traineeship application, C.V., training, qualifications, experience and competences are assessed. (Legal reason: Legal obligation of the data controller to process the personal data, necessity of data processing for the legitim interests of the data controller under the reserve of not harming the principal rights and freedoms of the person concerned. Legal reason for processing the identification card or its photocopy including the information of religion and blood type: Explicit consent of the data subject. Legal reason for processing criminal records: “Clear requirement of the law”)

b.    To conduct face-to-face or online traineeship interviews with you, to record images/videos of the online interviews and to store these records. (Legal reason: Legal obligation of the data controller to process the personal data, necessity of data processing for the legitim interests of the data controller under the reserve of not harming the principal rights and freedoms of the person concerned.”. Legal reason for recording and processing images/videos of the online traineeship interviews: Explicit consent of the data subject.)

c.    to conduct activities relating to the competence/career development as part of the process of selection and placement of the trainee candidates, to make exams for assessing your language skills and other competences, to record and evaluate the results of the exams (Legal reason: Legal obligation of the data controller to process the personal data, necessity of data processing for the legitim interests of the data controller under the reserve of not harming the principal rights and freedoms of the person concerned. Legal reason for processing the identification card or its photocopy including the information of religion and blood type: Explicit consent of the data subject.)

d.    To keep your personal data (including images/videos of online traineeship interviews) for 2 years as part of human resources process planning and for the possibility of having a suitable vacancy in our company or in the company Kansai Altan Boya Sanayi ve Ticaret A.Ş. in the future, to evaluate your application again during this period and to contact you by phone or SMS or e-mail to inform you about suitable vacancies. (Legal reason: Legal obligation of the data controller to process the personal data, necessity of data processing for the legitim interests of the data controller under the reserve of not harming the principal rights and freedoms of the person concerned. Legal reason for processing the identification card or its photocopy including the information of religion and blood type and images/videos of the online job interviews: Explicit consent of the data subject.)

e.    To organise travel, to book accommodation, to buy plane, train or bus tickets in your name if required for face-to-face traineeship interviews as part of the organisation and management of activities. (Legal reason: Legal obligation of the data controller to process the personal data, necessity of data processing for the legitim interests of the data controller under the reserve of not harming the principal rights and freedoms of the person concerned. Legal reason for processing the identification card or its photocopy including the information of religion and blood type: Explicit consent of the data subject.)

f.    to contact you by telephone, SMS or e-mail and provide you with information about the activities and processes described in this clarification text as part of conducting communication activities. (Legal reason: Legal obligation of the data controller to process the personal data, necessity of data processing for the legitim interests of the data controller under the reserve of not harming the principal rights and freedoms of the person concerned.).  

g.    To use applications/programs/systems necessary for the company's IT and data processing activities, business activities and internal and external communications in the implementation of data security processes and the performance of activities to securely store your personal data shared with our company in electronic systems, (Legal reason: Legal obligation of the data controller to process the personal data, necessity of data processing for the legitim interests of the data controller under the reserve of not harming the principal rights and freedoms of the person concerned.).  

3.    Method of collecting personal data:

 For the above-mentioned purposes and on the basis of the legal grounds governed by Articles 5 and 6 of the KVKK, your personal data: is collected and processed by us by automatic or non-automatic means that are part of the data recording system, or is collected by verbal, written or electronic methods if you contact our company through the human resources department, by telephone, by e-mail, by online job interviews or by other means. 

4.    Persons to whom your personal data is transmitted within the country and purpose of transmission:

Under the conditions specified in the article 8 of KVKK, your collected personal data is transmitted to the following service providers/suppliers and legal persons/companies within the scope required by the legislation:

a.    Your personal data is transmitted to the service providers such as travel and visa agencies, hotels, organisation/consulting companies in order to organise travel, book accommodation, purchase plane, train or bus tickets on your behalf, if necessary, for face-to-face traineeship interviews. (Legal reason: Legal obligation of the data controller to process the personal data, necessity of data processing for the legitim interests of the data controller under the reserve of not harming the principal rights and freedoms of the person concerned. Legal reason for processing the identification card or its photocopy including the information of religion and blood type and images/videos of the online job interviews: Explicit consent of the data subject.)
b.    Your personal data is transmitted to instructors/training institutions and service providers providing services such as online training/exams/programs for conducting activities relating to the competence/career development as part of the process of selection and placement of the trainee candidates, making exams for assessing the language skills and other competences, recording and evaluating the results of the exams Legal reason: Legal obligation of the data controller to process the personal data, necessity of data processing for the legitim interests of the data controller under the reserve of not harming the principal rights and freedoms of the person concerned. Legal reason for processing the identification card or its photocopy including the information of religion and blood type/transmitting personal data to training institutions and instructors: Explicit consent of the data subject.)

c.    Due to the intersection of the shareholding structures of our company and Kansai Altan Boya Sanayi ve Ticaret A.Ş  some business activities and processes are carried out jointly, for example the security process, information technology and data processing activities are carried out by a joint department acting on behalf of both companies. Besides that your traineeship application is assessed by the company Kansai Altan Boya Sanayi ve Ticaret A.Ş. if suitable vacancy positions are not found in our company, your traineeship application is necessarily transmitted to the said company (legal reason: “ Explicit consent of the data subject”). 

5.     Persons/locations abroad to which your personal data is transmitted and purpose of transmission:
On the basis of the legal reason of "explicit consent" required by the article 9/1 of KVKK, your personal data is transmitted to the following service providers/suppliers and the private law legal persons/companies:

a.    Your personal data will be transmitted to the company Microsoft because from this company we obtain applications such as Microsoft Office365 to use them for our company’s information technology and data processing processes, information security and the company’s internal and external communications, and this data is stored in the data centres/cloud databases of Microsoft abroad.

b.    Your personal data will be transmitted within the related context to the company Microsoft because from this company we obtain applications such as Skype, MS Teams to use them for making the online traineeship interviews, recording images, videos and audios and making online communications for other purposes explained in this clarification text and this data is stored in the data centres/cloud databases of Microsoft abroad.
c.    Your personal data on identity such as name, surname and the data on professional experience such as exam results will be transmitted to the service provider/supplier in Holland from whom we obtain the services related to online training/exam/program application to use them for conducting activities relating to the competence/career development as part of the process of selection and placement of the trainee candidates, to make exams for assessing your language skills and other competences and this data is stored in the data centres/cloud databases and servers of the service provider/supplier in Germany and in the cloud databases of Amazon services used by the service provider/supplier. 
d.    Your personal data indicated in this clarification text will be transmitted to the company SAP in Europe from whom we obtain IT/software/application to use them for conducting our company’s human resources management processes and personnel affairs, recording information of the trainee candidates, and this data will be stored in the data centres/cloud databases of the company SAP in Europe. 


6.    Your Rights within the framework of KVKK:
The article 11 of KVKK regulates the rights of the data subjects. You may transmit your requests within the context of the said article to our address Kemalpaşa OSB Mahallesi İzmir Ankara Yolu (Ansızca) Küme Evleri No.287 Kemalpaşa/ İzmir or to the electronic address akzonobel@hs01.kep.tr in accordance with the Communiqué on Procedures and Principles of the Application to Data Controller or by the other methods specified by the relevant legislation.

7.    Information about Our Company acting as Data Controller:

Tradename        : AkzoNobel Kemipol Kimya Sanayi Ve Ticaret Anonim Şirketi
Address        : Kemalpaşa OSB Mah. İzmir Ankara Yolu (Ansızca) Küme Evleri No 287,
  Kemalpaşa / İzmir 
Trade Registry Office    : İzmir Trade Registry Office 
Trade Registration No    : 340 K 2097
Telephone number    : +90 (232) 877 00 30
E-mail            : akzonobel@hs01.kep.tr 

FR-KVKK-139