Sabancı University (“University”) 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.
The data subjects/relevant persons within the scope of this Clarification Text are natural persons who participate in the SuCool Entrepreneurship and Incubation Center Community within the University.
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 University Contact Person via the e-mail address info@sabanciuniv.edu.
The University 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 University clearly sets out the purposes for which personal data are processed and processes personal data, in line with its 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 University for the purposes and on the legal bases set out below:
| Personal Data Processed |
Identity Data: Name, Surname Contact Data: E-Mail Address, Telephone Number, City/Country of Residence Professional Experience, Resume Data: Brief Resume Information, LinkedIn Profile Information, Participant Type/Profile Information Community and Participation Data*: Participation Status in Events, Trainings, Programs and Activities within the Scope of the Community, Activities of Interest, Activities and Interactions within the Community, Submitted Requests, Questions, Opinions and Feedback Visual and Audio Recording Data*: Photographs, Video and Audio Recordings Relating to Events, Trainings, Programs and Activities within the Scope of the Community |
|---|---|
| Purposes of Processing Personal Data | Conduct of Participation and Membership Processes in the SuCool Community, Determination of the Professional Profiles and Areas of Interest of Relevant Persons, Planning, Organization and Conduct of Events, Trainings, Programs, Networking, Mentorship and Similar Activities within the Scope of the Community, Informing Relevant Persons of Events, Trainings, Opportunities and Collaborations That May Be Suitable for Them, Supporting Communication and Interaction Processes Between Community Participants*, Bringing Together Suitable Participants, Entrepreneurs, Mentors, Instructors, Investors and Professionals, Maintaining Records and Conducting Analyses Relating to Community Activities, Conduct of Communication and Information Activities, Conduct of Retention and Archiving Activities, Ensuring that Activities Are Conducted in Compliance with Applicable Legislation and Program Rules, Fulfillment of Legal Obligations, Provision of Information to Authorized Persons, Institutions and Organizations |
| Legal Bases for Processing Personal Data | Your personal data are processed by the University 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”, “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 a contract” and “Explicit consent.” |
| Methods of Collection of Personal Data | The personal data specified above are collected electronically / physically, by partially or fully automated means, through electronic application forms completed via the Airtable platform, information, records and documents submitted by you or generated throughout community activities*, and automatic and/or manual photographic, video and audio recording devices* during events that may be organized within the scope of Community activities. |
| 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 community partners, instructors, investors, mentors and other third parties involved in conducting community activities for the purposes of planning, organizing and conducting events, trainings, programs, networking, mentorship and similar activities within the scope of the community, and bringing together suitable participants, entrepreneurs, mentors, instructors, investors and professionals. 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, cloud, e-mail, communication, archiving and analytics services. Furthermore, if you participate in community activities, your visual and audio personal data consisting of photographs, video and audio recordings may, subject to your explicit consent, be shared with the public by being published on the website, through press and media outlets and on social media platforms for the purposes of conducting announcement and promotional activities relating to community activities and carrying out corporate communication activities. 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 University and social media platforms are provided through service providers or data centers located abroad. |
| 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, Provision of Third-Party Services and Content, 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 University 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 visit to the University’s website and while completing electronic application forms provided via the Airtable platform. |
| 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, 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 University are provided through service providers or data centers located abroad. |
If, as personal data subjects, you submit your requests regarding your rights through the Data Subject Application Form published at sucool.sabanciuniv.edu or by using the methods specified in the Communiqué on the Procedures and Principles of Application to the Data Controller, the University shall 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 data are used in accordance with such purpose, know the third parties to whom their personal data are transferred domestically or abroad, request the 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 them 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-party companies, and the University 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 personal data and processing activities marked with “*” in this Text shall apply if you participate in community activities.
| Data Controller | Sabancı University (Tax Identification No: 7360078450) |
|---|---|
| Address | Orta Mahalle, Üniversite Caddesi No: 27, 34956 Tuzla / Istanbul |
| Contact | info@sabanciuniv.edu |
