Privacy Notice on the Protection and Processing of Personal Data
Luminis Lojistik Teknoloji Ticaret Danışmanlık Hizmetleri Limited Şirketi
Effective Date: April 20, 2026
This privacy notice has been prepared by Luminis Lojistik Teknoloji Ticaret Danışmanlık Hizmetleri Limited Şirketi (hereinafter referred to as "Luminis" and "COMPANY"), in its capacity as data controller, in accordance with Article 10 of Law No. 6698 on the Protection of Personal Data (hereinafter referred to as the "Law") for the purpose of fulfilling the obligation to inform.
For more detailed information regarding the purposes of processing your personal data by our COMPANY, to whom and for what purpose the processed data may be transferred, the method and legal basis of personal data collection, and your rights under Article 11 of the Law and other rights granted under Law No. 6698 on the Protection of Personal Data, you may apply to our company through one of the methods specified in detail below.
What Is the Method and Reason for Personal Data Collection?
We collect and record your personal data through the Rota mobile application, https://rota-app.com, and https://my.rota-app.com, which are interconnected and serve a common purpose. Due to the service we provide, the data of individuals visiting our website, those wishing to obtain information about our application, companies registering with the system, and individuals added to the system by such companies are processed and securely stored in accordance with the Law.
Your personal data is processed through mandatory cookies and other automated and non-automated methods, provided that it is part of a data recording system and in accordance with the purposes above and the Law, under the conditions specified in Article 5 of the Law (including explicit legal provisions, fulfillment of legal obligations as the data controller, direct relevance to the establishment and performance of a contract, and the legitimate interests of the data controller), without causing harm to the fundamental rights and freedoms of the data subject.
For What Purpose Will Your Personal Data Be Processed?
Our COMPANY aims to process personal data in accordance with Law No. 6698 on the Protection of Personal Data and other applicable legislation. Personal data that you notify or will notify our company due to visiting our website or receiving services from us, and/or that is obtained externally by our company, shall be processed by our company as "Data Controller":
- Within the framework of the purpose requiring processing and in a manner connected, limited, and proportionate to this purpose,
- By maintaining the accuracy and most current state of personal data as notified to or by our company.
We inform you that your personal data will be recorded, stored, preserved, reorganized, shared with institutions legally authorized to request such personal data, transferred or assigned to third parties within or outside Turkey under the conditions stipulated by the Law, classified, and processed in other ways specified in the Law, and may be subject to other operations listed in the Law.
Your personal data may be processed by our Company for the following purposes: Execution of Information Security Processes, Execution of Employee Candidate / Intern / Student Selection and Placement Processes, Execution of Employee Satisfaction and Loyalty Processes, Fulfillment of Employment Contract and Legal Obligations, Execution of Fringe Benefits and Benefits Processes, Execution of Audit / Ethics Activities, Execution of Training Activities, Execution of Activities in Compliance with Legislation, Execution of Finance and Accounting Affairs, Execution of Brand / Product / Service Loyalty Processes, Follow-up and Execution of Legal Affairs, Planning of Human Resources Processes, Execution / Audit of Business Activities, Receipt and Evaluation of Suggestions for Improvement of Business Processes, Execution of Business Continuity Activities, Execution of Goods / Service Procurement Processes, Execution of Goods / Service After-Sales Support Processes, Execution of Goods / Service Production and Operation Processes, Execution of Customer Relationship Management Processes, Organization and Event Management, Execution of Marketing Analysis Studies, Execution of Performance Evaluation Processes, Execution of Storage and Archive Activities, Execution of Contract Processes, Ensuring the Security of Data Controller Operations, Providing Information to Authorized Persons, Institutions, and Organizations, and Execution of Management Activities.
Additionally, personal data recorded by contracted companies and shared with us as a result of the service we provide is processed and stored for the purposes of planning and executing fringe benefits and benefits for employees, planning and executing human resources processes, executing personnel recruitment processes, planning and executing corporate communications or corporate social responsibility or NGO activities involving employees, planning and executing talent-career development activities, fulfillment of employment contract and/or legal obligations, planning and executing in-company orientation activities, salary management, planning and executing in-company appointment, promotion, and termination processes, planning and monitoring performance evaluation processes, tracking and/or auditing business activities or working hours of employees, planning and executing employee satisfaction and/or loyalty processes, planning employee salary increases, planning and executing access permissions to information, planning and executing processes related to urgent medical needs of employees and their relatives, planning and executing processes related to union membership of employees, execution and follow-up of disciplinary practices related to employees, providing information to legally authorized public institutions, execution and follow-up of employment onboarding and personnel file creation processes, collection and evaluation of employee complaints, demands, or suggestions, determining and meeting human resources needs necessary for the organization, planning and/or executing in-company training activities, fulfilling obligations related to occupational health and safety, executing processes related to obtaining health reports from workplace physicians, and making announcements.
Your personal data will be retained for the period specified in the relevant legislation or the reasonable period until the purpose of processing ceases, and in any case for the duration of the statutory limitation periods.
Which Personal Data Will Be Processed?
| Data Category | Scope |
|---|---|
| Identity Data | Full name, Turkish ID number, marital status, mother's name - father's name, date of birth, place of birth, nationality, gender, driver's license and national ID card copy, SGK registration number, signature/initials. |
| Contact Data | Phone number, secondary contact number, open address information, residence, email address. |
| Financial Data | IBAN number, branch code, bank code, account number, bonus and advance amounts, salary details. |
| Special Category Personal Data | Criminal record (judicial record), physical health issues, medications used regularly, chronic allergies, incapacity reports, union membership, legal case files, blood type, chronic diseases, smoking-alcohol dependency, physical examination results, laboratory results, rest reports. |
| Professional Experience Data | CV, work experience, training activities, certificates, previous job information, profession, previous job entry-exit dates. |
| Visual/Audio Data | Photographs and camera recordings (excluding those within the scope of Physical Premises Security Information). |
| Physical Premises Security | Camera recordings, employee entry-exit passwords. |
| Personnel Data | Family status documents, education status, diploma, SGK employment start declaration, disability declaration, equipment receipt documents, work permits for foreign employees, İŞKUR registration documents, overtime durations, leave durations, leave requests, SGK registration no., desired resignation date, desired start date, payroll, salary receipts, promotion letters, raise declarations, job search forms during notice, temporary workplace change notifications, signature/initials. |
| Other Data | Military service document for male employees, driver's license, foreign language skills, computer literacy, diploma date and number, diploma registration date and number, workplace physician document date and number. |
The specified personal data does not mean that it is mandatorily collected and processed from all individuals visiting our website or companies using our application within the scope of contracts and all their employees. Such personal data is processed and stored as detailed in our cookie privacy notice through automated means, or when collected by contracted companies and shared with us, or when voluntarily uploaded by the data subject.
To Whom and for What Purpose May Your Processed Personal Data Be Transferred?
Your personal data may be transferred to relevant public institutions for the resolution of disputes or pursuant to legislation, to judicial authorities or relevant law enforcement upon request, and to institutions within or outside Turkey, business partners, and legally authorized private law persons, occupational health and safety experts, and financial advisors for the purpose of realizing the above-mentioned purposes while taking adequate measures, in accordance with the conditions for the transfer of personal data and transfer abroad specified in Articles 8 and 9 of the Law.
What Are the Rights of the Data Subject Under Article 11 of the Law?
As a personal data subject, we hereby inform you that you have the following rights under Article 11 of the Law:
- To learn whether your personal data is processed,
- To request information if your personal data has been processed,
- To learn the purpose of processing your personal data and whether it is used in accordance with that purpose,
- To know the third parties to whom your personal data is transferred within or outside Turkey,
- To request the correction of your personal data if incompletely or incorrectly processed, and to request that such correction be communicated to third parties to whom your personal data has been transferred,
- To request the deletion or destruction of your personal data when the reasons requiring its processing have ceased, despite being processed in accordance with the Law and other relevant legislation, and to request that such deletion or destruction be communicated to third parties to whom your personal data has been transferred,
- To object to the occurrence of a result against yourself due to the analysis of your processed data exclusively through automated systems,
- To request compensation for damages incurred due to the unlawful processing of your personal data.
You may submit your applications regarding the above-listed rights by filling out the Data Subject Application Form available at rota-app.com/legal or physically obtainable from us, and by mailing it to our Company's address at Küçükbakkalköy Mah. Yüksel Sk. No: 10 A Ataşehir/İstanbul, Turkey, by emailing it to privacy@rota-app.com, or by delivering it physically. Depending on the nature of your request, your applications will be finalized free of charge as soon as possible and no later than thirty days; however, if the operation requires additional cost, a fee may be requested from you in accordance with the tariff determined by the Personal Data Protection Board. In case of rejection of the request, the reason(s) for rejection will be communicated to you in writing or electronically with justification.
This document is provided for informational purposes only. The legally binding version is the Turkish original.