Clarification Text on Processing Candidate Personal Data
Last Updated: July 30, 2026
Candidate Registration, Job Application & AI Assessment Notice
At RecruGate ("RecruGate", "Company", "we"), the protection of your personal data obtained during job application, registration, and assessment processes is one of our primary priorities. As a global AI recruitment platform operating from Türkiye and serving international employers, RecruGate processes candidate personal data in compliance with both the European Union General Data Protection Regulation (GDPR - Regulation EU 2016/679) and the Turkish Personal Data Protection Law No. 6698 (KVKK).
This clarification text explains how we collect, process, share, and protect your personal data as a Data Controller during your membership and application activities on www.recrugate.com("Website").
1. Processed Candidate Data, Purposes, and Dual Legal Grounds
The table below summarizes the categories of candidate data we process, the processing purposes, and the dual legal grounds under GDPR (Art. 6) and KVKK (Art. 5):
| Processed Data Category | Purposes of Data Processing | Legal Grounds (GDPR & KVKK) |
|---|---|---|
| Identity & Contact: Full Name, Email Address, Phone Number. Security & Credentials: Password (hashed), IP Address, Session Logs. | Candidate registration, authentication, account security, user verification, and enabling core platform features (job applications, interview scheduling, account communications). | GDPR Art. 6(1)(b) / KVKK Art. 5(2)(c): Necessary for the performance of a contract or service agreement. |
| Professional & Resume Data: Work history, education, skills, certificates, portfolios, languages, resume attachments. | Matching candidates with open job positions, presenting profile summaries to prospective employers, and facilitating hiring evaluations. | GDPR Art. 6(1)(b) & (f) / KVKK Art. 5(2)(c): Contractual performance & legitimate interests in recruitment matching. |
| Interview & AI Assessment Data: Audio/video interview recordings, AI transcriptions, answer scores, skill match ratings. | Conducting AI-assisted phone/video mülakats, generating objective evaluation reports for hiring managers under human oversight ("Human-in-the-loop"). | GDPR Art. 6(1)(b) & EU AI Act Guidelines / KVKK Art. 5(2)(c): Service performance with explicit candidate consent for recording where required. |
| Legal & Dispute Records: Correspondence logs, legal notifications, regulatory compliance records. | Fulfilling statutory requirements, responding to legal proceedings, and establishing or defending legal rights. | GDPR Art. 6(1)(c) & (f) / KVKK Art. 5(2)(ç) & (e): Compliance with legal obligations and legal defense. |
2. AI Profiling & Automated Decision-Making Notice (GDPR Art. 22 & EU AI Act)
RecruGate utilizes AI technologies to transcribe interviews, summarize candidate qualifications, and provide match scores. In accordance with GDPR Article 22:
- AI evaluations serve solely as advisory decision-support tools for employers.
- Final hiring decisions, interview invitations, or rejections are always conducted by human recruiters (Human-in-the-loop).
- Candidates retain the right to request human review of automated evaluation scores or submit feedback regarding their mülakat analysis.
3. Candidate Data Rights & Self-Serve Account Deletion
Whether you are protected under GDPR (Art. 15-22) or KVKK (Art. 11), you have comprehensive rights over your personal data:
- Self-Serve Right to Erasure / Unutulma Hakkı: You can permanently delete your candidate account and erase your profile, resume files, and assessment records at any time directly through your account dashboard (Candidate Settings > Delete Account).
- Right to Access & Data Portability: Request a copy of your stored candidate data in a structured, machine-readable format.
- Right to Rectification: Edit or update your resume, profile details, and contact preferences at any time.
- Right to Object or Restrict Processing: Object to specific data processing based on legitimate interests or request processing limits.
To exercise any of these rights or for questions regarding candidate privacy, you may contact our Data Protection Officer:
- Email: privacy@recrugate.com / dpo@recrugate.com
- Company Support: info@recrugate.com