Start Stop — Operator Privacy Notice Template

Version v1.0 · 3 November 2026

NOTE TO THE EMPLOYER — how to use this template (do NOT include in the text given to employees)

1. This is a sample, not your privacy notice. You are the controller of your employees' personal data; the duty to inform them (KVKK Art. 10 in Türkiye, GDPR Arts. 13-14 in the EU) is yours. This template is provided to help you describe accurately what Smartifie Start Stop records. It does not replace your general employee privacy notice; it supplements it.
2. Fill in the bracketed fields [...] and delete options that do not apply (installation rows you do not use, the legal-basis paragraph that does not fit your country, etc.). When you change your settings (identification method, break method, photo, per-person reports, retention period), update the text too.
3. Do not add a consent/approval checkbox. Start Stop records are not based on consent; asking for consent puts the employee in front of a choice they cannot really refuse. If you want proof of delivery, use the "received" line in §18.
4. Do not put reasons in your stop-reason list that suggest special-category data such as health, trade-union membership or religion (e.g. "went to the infirmary"), and ask your staff not to write such information in free-text stop notes.
5. Before turning on per-person reports, give this text (with §9 completed) to your employees; the software asks you to confirm that you have done so, and the accuracy of that confirmation is your responsibility.
6. Have your legal adviser review it. Smartifie is not your lawyer; this template is not legal advice.

Smartifie Start Stop — Employee / Operator Privacy Notice

[Employer name] · Version: [employer version] · Date: [DD.MM.YYYY]

1. About this notice

This notice explains which of your personal data are processed, for what purposes and how, in Smartifie Start Stop, the production time-tracking software used at our workplace. It is prepared under Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK") [and, for employees in the EU, Article 13 of the General Data Protection Regulation ("GDPR")].

This notice does not replace [Employer name]'s general employee privacy notice; it supplements it as regards Start Stop. You can find the general notice at [where: e.g. HR portal / notice board].

2. Controller

The Start Stop software is developed under the Smartifie brand by Birileri Dış Ticaret Danışmanlık Sanayi ve Ticaret Limited Şirketi ("Smartifie"). Smartifie is not the controller of your data; depending on the installation we use, it is either not involved at all or acts only as a processor on our behalf and on our instructions (see §13 and §14).

3. What Start Stop records, and what it does not

Start Stop records the moments when you start, pause and finish a work-order operation on the terminal (tablet, computer or phone), and the production information linked to that work.

What it does not record:

• It does not record when you arrive at or leave the workplace. Recording begins when you start your first job on the terminal; the time between arriving at work and starting your first job is not visible in Start Stop.
• It does not process biometric data (see §8).
• It does not record your location, camera images or your screen.

4. Personal data processed

5. How the data are collected

• From you, at the terminal: when you identify yourself, press start / pause / finish, and enter quantities and stop reasons.
• How you identify yourself — at our workplace: [choose: scanning your badge / picking your name from the terminal list / signing in with a user account / badge or list]. [If the list method is used:] With this method, your colleagues' names are also visible in the list on the shared terminal.
• From the employer: your operator card is entered manually by [HR / production planning] or imported from an Excel/CSV file.
• Automatically: time stamps, time calculations and terminal data are generated by the software.

6. Purposes

Your data are processed for the following purposes:

1. Documenting working time — helping the employer meet its legal duty to document working hours;
2. Production planning, costing and quality — seeing how much labour went into which work order, and stoppages and scrap causes;
3. Accuracy of records and accountability — keeping corrections traceable and allowing wrong records to be put right;
4. [If per-person reports are on — see §9: [specific purpose, e.g. "setting standard operation times and capacity planning"]].

Your data are not used for any purpose incompatible with these — for example, for a general, abstract "monitoring" purpose.

7. Legal bases

[Employer in Türkiye — use this table:]

[Employer in the EU — use this paragraph: GDPR Art. 6(1)(c) — the employer's legal obligation ([national law: e.g. in Spain, Workers' Statute (Estatuto de los Trabajadores) Art. 34.9]); GDPR Art. 6(1)(f) — the employer's legitimate interest (production planning, costing, quality). You may request a summary of the legitimate-interest assessment via §17.]

[Employer in other countries: determine the legal basis with your legal adviser and state it here.]

Your data are not processed on the basis of your consent. Because consent cannot be regarded as freely given in the employer–employee relationship, Start Stop records are not made dependent on consent. This notice is not a consent form, which is why it contains no checkbox.

8. No biometric data

Start Stop does not process fingerprints, facial recognition, palm, iris or any other biometric data. You are identified by badge, by selection from a list or by a user account. The software has no biometric identification option, and Smartifie does not add one, as a product rule.

9. Per-person performance reports

Start Stop ships with per-person time reporting switched off by default. It cannot be switched on until the employer confirms in the software that it has informed its employees.

[Choose:]

• [ ] Off. Reports are by work order, operation, work centre and stop reason; no per-person reports are produced.
• [ ] On. Since [date switched on], per-person time reports are produced for [specific purpose]. Only [authorised roles] can see them.

10. Seeing your own record

On the terminal you can always see your own day — your first start time and your raw time, break time and net time, each separately. This view cannot be switched off in the software. You can request a statement of older records via §17.

11. How breaks are calculated

At our workplace breaks are deducted using the [choose] method:

• [ ] Calculated break (the software's default): the break is not measured; the break window defined in the shift calendar is assumed and deducted from working time. In records and exports this break is labelled "calculated". The record does not show whether you actually took your break. [Our shift and break times: ...]
• [ ] Reported break: you press the relevant button on the terminal when you go on and come back from a break; the break is recorded from those presses.
• [ ] Both: [description].

Raw time, break time and net time are shown separately in every report and export; they are never presented as one merged figure. This rule cannot be changed in the software.

12. How records are corrected

If a record is wrong (e.g. you forgot to press "finish"), an authorised person can correct it. Every correction records who corrected it, when and why; a reason is mandatory and the original record is not deleted. [If used:] Corrections take effect after approval by [approving role]. [If used:] Authorised operators may backdate a press by at most [X] minutes; such a press goes to the approval queue together with the time it was actually made.

13. Who can access your data, and to whom they are disclosed

• Within the employer: the [roles: e.g. production manager, shift supervisor, HR] who have been given access to Start Stop.
• Smartifie (the software provider) — only in the Cloud or Private Database installation and only to provide the service, on our behalf and on our instructions (as processor). Smartifie does not use your data for its own purposes and does not sell them. Smartifie's server hosting provider in Türkiye works in the same capacity and within the same limits.
• [Other recipients — employer completes: e.g. payroll/accounting service provider; competent public authorities (labour inspectorate, social-security institution) and courts, when they request it].
• Transfers abroad: [For an employer in Türkiye:] In the Cloud and Private Database installations the data are kept on servers in Türkiye; no transfer abroad takes place for Start Stop. [For an employer in the EU: In the Cloud and Private Database installations the data are kept in Türkiye; there is no EU adequacy decision for Türkiye. The transfer is based on: [employer completes: e.g. Standard Contractual Clauses]; you may request a copy via §17.]

If you also sign in to the terminal with a user account, Smartifie is a separate controller for that account itself (e-mail, password, session records); those data are governed by Smartifie's own privacy notice and privacy policy (smartifie.com).

14. Where your data are kept

Installation used at our workplace: [choose, delete the other rows]

15. Retention and anonymisation

• Work and production records are kept for [X] months. [The software's default is 60 months; the employer may extend this to at most 132 months. Today the software does not allow less than 60 months at any workplace.] [Reason for the period — employer completes: e.g. "keeping working-time records as evidence for the limitation period for wage claims and the period for producing social-security records".]
• When the period ends, the software does not delete the records but anonymises them: your operator code and the terminal ID are removed from work segments, job records and the change trail (including the before/after versions of corrections); the production and time data remain without being linked to anyone. This behaviour cannot be changed in the software.
• Correction requests (requester, reason, proposed change, decision note) are not anonymised automatically by the software; they are [deleted / anonymised] after [employer completes: period].
• Your operator card (name, code, badge code, PIN hash, photo, skills) remains until the employer deletes it. After your employment ends, your card is deleted [employer completes: e.g. within X months].
• [In the Single Terminal installation:] Records stay on the terminal device; backing them up and keeping the device secure is the employer's responsibility.

16. Automated decisions

Start Stop does not take automated decisions about you (disciplinary action, pay deductions, dismissal, etc.); it only produces time and production data. [Employer statement: no decision producing an adverse result for you is taken based on Start Stop data analysed solely by automated systems.]

17. Your rights and how to make a request

Under KVKK Art. 11 you have the right to: learn whether your personal data are processed; request information if they are; learn the purpose of processing and whether the data are used in line with it; know the third parties in Türkiye or abroad to whom they are disclosed; request rectification if they are incomplete or inaccurate; request erasure or destruction under the conditions of KVKK Art. 7; request that rectification and erasure be notified to third parties to whom the data were disclosed; object to a result to your detriment arising from analysis exclusively by automated systems; and claim compensation if you suffer damage from unlawful processing.

[For employees in the EU: under GDPR Arts. 15-22 you have the rights of access, rectification, erasure, restriction of processing, data portability and (for processing based on GDPR Art. 6(1)(f)) objection; you may also lodge a complaint with [supervisory authority, e.g. AEPD in Spain].]

Requests: [e-mail / address / registered e-mail / request form]. Your request will be answered free of charge within 30 days at the latest [EU: one month]. If you send your request to Smartifie by mistake, Smartifie will forward it to the employer; it is the employer who decides about your data.

18. Changes and delivery

This notice is updated when our Start Stop settings or installation change; you can find the current version at [where].

[Optional — for proof of delivery only; this is NOT a declaration of consent:]
I have received this notice. — Name: ________ · Date: ________ · Signature: ________