INTERNIF Clarification Text on the Protection of Personal Data
This notice has been prepared to inform data subjects who use the services provided through the platforms operated by Inclusive Future Yapay Zeka Teknolojileri Limited Şirketi (“INTERNIF”) (www.internif.com)
1. Data Controller
• Trade Name: Inclusive Future Yapay Zeka Teknolojileri Limited Şirketi
• Address: Bilişim Vadisi - Teknoloji Geliştirme Bölgesi, İzmir Teknoloji Üssü, Gülbahçe Mah. İçmeler Cad. 35433 İzmir, Türkiye
• Contact: [email protected]
2. Your Processed Personal Data
• Identity and Contact Details: Full name, date of birth, gender, email address, telephone number, residential/city/country address.
• Education, Career, and Resume: University/school, department/major, graduation status, foreign language proficiency level, resume/CV files, internship/employment history, target industry sectors, and target internship destination countries.
• Simulation, Performance, and Experience (Proof): Job simulation answers, project submissions, mentor evaluation notes, participation/achievement scores (such as the 75% benchmark required for The Circle), and digital experience records.
• Audio and Visual Recordings: Audio and video recordings collected during online mentorship sessions, interviews, or verification meetings upon your explicit consent.
• Payment and Transaction Security: Invoicing details, payment transaction reference numbers (credit/debit card details are not stored on our systems and are processed directly by Stripe), IP address, session credentials, and cookie identifiers.
• Users Under 18 Years of Age: Full name, contact credentials, and electronic verification consent logs of the parent or legal guardian.
3. Processing Purposes and Legal Grounds
Pursuant to Article 5 of the KVKK, your personal data is processed based on the following statutory grounds:
• Establishment and Performance of a Contract (Art. 5/2-c): Creation and maintenance of user accounts; execution of The Taste, The Practice, The Proof, and The Performance modules; matching with international Host Companies; coordination of mentorship sessions; and issuing verified Proof of Experience records.
• Legal Obligation of the Controller (Art. 5/2-ç): Issuance of commercial invoices, maintenance of accounting/tax documentation, retention of traffic logs under Law No. 5651, and administration of parental/guardian verification workflows.
• Legitimate Interests of the Controller (Art. 5/2-f): Preserving system and platform security, detecting and preventing fraudulent or manipulative simulation practices, technical performance optimization, and evaluating eligibility for The Circle community.
• Establishment, Exercise, or Defense of a Legal Right (Art. 5/2-e): Preserving legal evidence, defending claims, and asserting statutory rights in potential contractual or administrative disputes.
• Explicit Consent (Art. 5/1): Capturing audio and video recordings during simulation interviews or mentorship sessions, and sending commercial electronic communications, marketing messages, or newsletters.
4. Data Transfers and Cross-Border Transfers
Pursuant to Articles 8 and 9 of the KVKK, your personal data is transferred strictly to the extent necessitated by internship matching and simulation processes:
• To Foreign Host Companies: Transferred to independent enterprises located in designated jurisdictions (Europe, the UK, the US, Canada, etc.) to facilitate interview scheduling, job assignments, and candidate performance evaluations.
• To Business Partners and Service Providers: Transferred to professional mentors, cloud hosting platforms, email dispatch providers, and the certified payment infrastructure provider (Stripe).
• To Competent Public Authorities: Disclosed to judicial authorities and authorized governmental bodies where legally mandated.
5. Collection Methods and Retention Periods
Your data is collected electronically via automated or semi-automated channels, including our website registration interfaces, application questionnaires, simulation module inputs, online interview sessions, and secure payment workflows. Personal data is retained for the durations required by processing purposes, general statutory limitation periods (typically 10 years), and fiscal recordkeeping rules. Upon expiry of the relevant period, data is securely erased, destroyed, or anonymized in the earliest periodic disposal cycle.
6. Your Statutory Rights Under Article 11 of the KVKK
As a data subject, you have the right to learn whether your data is processed, request information thereon, verify compliance with processing purposes, identify third-party recipients, request rectification or erasure, object to adverse results produced exclusively by automated profiling systems, and claim compensation for damages sustained due to unlawful processing.
Application Procedure: You may exercise your rights by sending an email from your registered email address to [email protected] with the subject line "Personal Data Request," or by delivering a written, signed petition to Bilişim Vadisi - Teknoloji Geliştirme Bölgesi, İzmir Teknoloji Üssü, Gülbahçe Mah. İçmeler Cad. 35433 İzmir, Türkiye. Your request will be reviewed and finalized free of charge within 30 days at the latest.