1) Data Controller

The protection of your personal data is held at utmost importance by Otokoç Otomotiv Ticaret ve Sanayi Anonim Şirketi (“the Company”) who acts as a data controller in accordance with the Personal Data Protection Law No. 6698 (“the Law”).
You may find the detailed information regarding the processing purposes of your personal data by our Company under the Otokoç Otomotiv Ticaret ve Sanayi Anonim Şirketi Policy of Protection and Processing of Personal Data (“Policy”), which can be found at https://otokocotomotiv.com.tr/kvk_politikasi.pdf.

2) Purposes for Processing Personal Data

Your collected personal data may be processed by our Company within the scope of conducting the necessary works by our work units so that you can benefit from the goods and services offered by our Company and to manage the relevant processes accordingly, conducting the necessary works by our work units and to manage the relevant process for carrying out the commercial activities conducted by our Company, and securing the legal, technical and commercial-business security of our Company and data subjects who are in a business relationship with our Company and for the below mentioned purposes (“the Purposes”), in accordance with the data processing conditions set out in Articles 5 and 6 of the Law.
 
Regarding our Avis & Budget goods and services:

• Ensuring that you can benefit from our hourly/daily/monthly vehicle or tire rental service and in this regard, fulfilling the requests of reservations and cancellations, 
• Concluding and executing the rental agreements,
• Tracking the passage information of the vehicle that is allocated to you via the fast passage system (HGS) and similar systems and managing the fines related with it,
• Having mandatory GPS device (global satellite navigation system) in rental vehicles and keeping records of the location information of the vehicles as stipulated in the legislation,
• Conducting damage management processes of the vehicle assigned to you, and within this context, benefiting from artificial intelligence technologies at the beginning and end of the rental process for the damage detection,
• Conducting location tracking,
• Tracking the fuel level,
• Logging the end destination if vehicle sharing system is used,
• Allowing you to benefit from Koç Ailem Special Moments Experience program,
• Allowing you to benefit from our Connected Car goods and services, 
• If you have given your consent in scope of your usage of Connected Car goods and services, processing your identity, location, vehicle, customer transaction and marketing data to analyze your driving performance for offering tailored vehicle insurance and to decrease the insurance premium if low risk is detected, to calculate points on the basis of driving and offering advantages based on these points.

 
Regarding our Otokoç goods and services:

• Concluding vehicle sales,
• Providing vehicle maintenance services,
• Managing after sales support services,
• Providing valet services.

Regarding our 2^nd Hand Otokoç goods and services:

• Concluding second-hand vehicle sales,
• Concluding cash vehicle purchasing services,
• Concluding vehicle purchasing and sales services via bidding,
• Providing the vehicle expertise service.
• Providing the listing and routing service of second-hand vehicle sales advertisements,
• Carrying out second-hand vehicle reservation procedures,
• In case you become a member of the Kazananlar Kulübü Loyalty Program (“Loyalty Program”); creating and operating the Loyalty Program membership of our Company and you or the corporate customer whose employee/official/representative you are; calculating the points/benefits earned, providing information about the points/benefits earned, ensuring that you benefit from discounts, campaigns, gifts, promotions and similar benefits, reminding the points/benefits that will expire, and carrying out the necessary procedures to ensure the benefits of the Loyalty Program,
• In case you become a member of the Loyalty Program, carrying out Loyalty Program loyalty creation and development activities.

 Regarding our Avis Fleet goods and services:

• Ensuring that you can benefit from our long-term vehicle and tire rental services and, fulfilling the requests of reservations and cancellations in this regard,
• Concluding and executing the rental agreements,
• Tracking the passage information of the vehicle that is allocated to you via the fast passage system (HGS) and similar systems and managing the fines related with it, 
• Having mandatory GPS device (global satellite navigation system) in rental vehicles and keeping records of the location information of the vehicles as stipulated in the legislation,
• Providing HGS/OGS,
• Providing the periodic car maintenance processes,
• Providing extra services according to your demands such as car fleet rental insurances, management of accident and damages.

In relation to our Maestro Fleet Management products and services;

The personal data processing activities carried out by the Company may differ depending on your membership status. In this context, your personal data may be processed by the Company as follows:

If you are a corporate member:

• Planning, execution and tracking of vehicle maintenance, malfunction, damage and tire replacement processes,
• Planning, coordinating and carrying out complementary service operations (maintenance, repair, tire, warranty, roadside assistance, etc.) for customers who receive Maestro Fleet Management services,
• Carrying out valuation and appraisal procedures and recording them,
• Carrying out and recording administrative procedures related to vehicles (payments, traffic fine management, insurance, etc.).

If you are an individual member:

• Planning, coordinating and carrying out complementary service operations (maintenance, repair, tire, warranty, roadside assistance, etc.) for customers who receive Maestro Fleet Management services.

 Regarding our Otokoç Parça goods and services:

• Executing the sales of spare parts and accessories for vehicles,
• Rendering of installation services,

Regarding all of our goods and services:

• Executing the verification and/or activation processes regarding your registrations and transactions,
• Creating an appointment and making an offer,
• Opening the sales logs, executing the online/offline payment and billing activities,
• Concluding and executing the sales agreement regarding your purchase of our Company’s goods and services,
• Executing the notification and promotion activities regarding our goods and services,
• Creating, tracking, and cancelling the memberships,
• Delivering the vehicle protection services,
• Ensuring the security of Company operations and vehicles,
• Executing the after-sales support services,
• Managing the accounting and financial processes,
• Executing the customers’ financial risk evaluations,
• Receiving, evaluating, and finalizing your demands, questions, complaints, and suggestions,
• Updating the customer information,
• Ensuring compliance with the storage obligations, which are stipulated in the legislations,
• Conducting the evaluations of the applications you convey to the Company, based on exercising your rights stipulated in Article 11 of the Law regarding your personal data that are processed by our Company, finalizing these applications according to the legislations and conducting the necessary processes in this regard,
• Storing the logs for the duration of general term of limitation to use them as evidence for possible disputes in the future,
• Planning and executing the processes of customer relationship management,
• Following up and managing the legal matters,
• Following up and developing the activities regarding the services,
• Executing the demands of governmental agencies and informing the authorized agencies due to the legislative obligations, 
• Executing the information security processes,
• Concluding audits and ethical activities,
• Planning and executing the customer satisfaction and corporate communication processes,
• Executing draws, campaigns, contests, promotion, or advertising processes,
• Providing extra benefits to members of the loyalty program, 
• If you have given your consent, processing your health data for the purpose of providing after-sales support services when you have been involved in an accident,
• Transferring and processing of username, password and other account information regarding your membership accounts on our websites or applications to Company’s other brands’ websites and applications,
• If you have given your consent, processing your identity, communication, customer transaction, marketing, and vehicle-insurance information for the purposes of tailoring and suggesting the goods and services provided by our Company, based on your likes, usage habits and needs, and in this regard, sending commercial electronic messages such as advertisements, promotions, and campaigns to your contact information.  

3) Recipient Parties and Purposes for Transferring Personal Data

Your collected personal data may be transferred, within the scope of the Purposes, to our business/solution partners, our suppliers, legally authorized public authorities, and legally authorized private institutions. Your personal data is shared with our foreign supplier Microsoft Ireland Operations Limited based on the legal reason for the existence of a standard contract for the purposes of conducting information security processes, conducting communication activities, conducting / auditing business activities, conducting goods / service after-sales support services, conducting goods / service sales processes, conducting goods / service sales processes, conducting goods / service production and operation processes, receiving and evaluating suggestions for the improvement of business processes and conducting marketing analysis studies. You may find detailed information on whom your personal data is transferred in the Policy.

If you benefit from the Koç Ailem Special Moments Experience program, your personal data may be shared with Tanı Pazarlama ve İletişim Hizmetleri Anonim Şirketi within the scope of the data processing conditions set out in Article 8 of the Law, for the purposes of receiving reservations, arranging vehicle provision, and enabling you to benefit from the advantages of the Koç Ailem Special Moments Experience program.

If you benefit from Avis vehicle renting services:

• Your information may be transferred to Avis Europe and Middle East Limited, who is a processor located abroad for the purposes of; taking the reservations for you to benefit from daily or monthly vehicle renting services, concluding and executing the rental agreements, receiving and executing the cancellation demands, following up the activites related with the services, providing extra benefits to members of the loyalty program and creating, following up, and cancelling memberships as per the Personal Data Protection Board’s decision numbered E-67322700-045.02-0000137706 and dated 04.04.2023, namely “Application for Letter of Commitment for Cross Border Data Transfer”, pursuant to the personal data processing conditions specified in Article 9 of the Law. 
• Your information may be transferred to Avis Europe and Middle East Limited, who is located abroad for the purposes of; tracking and organizing the actions regarding the services, executing the performance measurements, calculating the licensing fees of Otokoç and executing the financial transactions, reporting the reservation requests and cancellations, creating, tracking and cancelling memberships and actions of loyalty programs, providing vehicle rental services if you ask to benefit from the services that are located abroad and actualizing the membership processes, as per the Personal Data Protection Board’s decision numbered E-67322700-045.02-0000137706 and dated 04.04.2023, namely “Application for Letter of Commitment for Cross Border Data Transfer”, pursuant to the personal data processing conditions specified in Article 9 of the Law.

 
4) Method and Legal Ground for the Collection of Personal Data

Your personal data is collected when you have been in contact with our Company for the sales or delivering of our goods and services, electronically, through our web page, mobile applications, social media accounts, e-mail, call center and via the usage of vehicle, if you wish to benefit from the Koç Ailem Special Moments Experience program, via e-mail through your employer, physically, through camera records, cargo/mail, facsimile, face-to-face meeting channels, pursuant to legal grounds specified in Articles 5 and 6 of the Law and provided below:
 
Based on the legal ground that processing of personal data of the parties of a contract is necessary, provided that it is directly related to the conclusion or performance of a contract:

• Concluding vehicle sales,
• Concluding cash vehicle purchasing services,
• Concluding vehicle purchasing and sales services via bidding,
• Concluding second-hand vehicle sales,
• Ensuring that you can benefit from our hourly/daily/monthly vehicle or tire rental service and in this regard, fulfilling the requests of reservations and cancellations, 
• Ensuring that you can benefit from our long-term vehicle and tire rental services and in this regard, fulfilling the requests of reservations and cancellations,
• Providing the valet service,
• Providing vehicle maintenance services,
• Providing the vehicle expertise services,
• Providing HGS/OGS,
• Providing periodic car maintenance processes,
• Providing extra services according to your demands such as car fleet rental insurances, management of accident and damages,
• Concluding and executing the rental agreements,
• Executing the sales of spare parts and accessories for vehicles,
• In the event of an accident or damage calling a tow truck, providing road assistance and conducting failure reporting,
• Logging the end destination if vehicle sharing system is used,
• Allowing you to benefit from Koç Ailem Special Moments Experience program,
• Allowing you to benefit from our Connected Car goods and services, 
• Concluding tire sales,
• Rendering of installation services, 
• Creating an appointment and making an offer,
• Opening the sales logs, executing the online/offline payment and billing activities,
• Concluding and executing the sales agreement regarding your purchase of our Company’s goods and services,
• Updating the customer information,
• Executing the verification and/or activation processes regarding your registrations and transactions,
• Creating, following, and cancelling the memberships,
• Delivering the vehicle protection services,
• Concluding after sales support services,
• Providing extra benefits to members of the loyalty program,
• Providing you with the listing and routing service of second-hand vehicle sales advertisements,
• Carrying out second-hand vehicle reservation procedures,
• In case you become a member of the Kazananlar Kulübü Loyalty Program (“Loyalty Program”); creating and operating the Loyalty Program membership of our Company and you or the corporate customer whose employee/official/representative you are; calculating the points/benefits earned, providing information about the points/benefits earned, ensuring that you benefit from discounts, campaigns, gifts, promotions and similar benefits, reminding the points/benefits that will expire, and carrying out the necessary procedures to ensure the benefits of the Loyalty Program,
• Planning, coordinating, and carrying out complementary service operations (such as maintenance, repair, tire, warranty, roadside assistance, etc.) for customers who receive Maestro Fleet Management services,
• Conducting valuation and appraisal procedures and recording the results.
• Planning, executing and monitoring processes related to vehicle maintenance, malfunction, damage, and tire replacement.
• Carrying out and recording administrative procedures related to vehicles (such as payments, traffic fine management, insurance, etc.).

 Based on the legal ground of being explicitly stated in the law and being mandatory for the data controller to perform its legal obligations:

• Executing the demands of governmental agencies and informing the authorized agencies due to the legislative obligations,
• Ensuring compliance with the storage obligations, which are stipulated in the legislations,
• Conducting the evaluations of the applications you convey to the Company, based on exercising your rights stipulated in Article 11 of the Law regarding your personal data that are processed by our Company, finalizing these applications according to the legislations and conducting the necessary processes in this regard,
• Having mandatory GPS device (global satellite navigation system) in rental vehicles and keeping records of the location information of the vehicles as stipulated in the legislation.

Based on the legal ground of data processing being necessary for the establishment, exercise or protection of any right:

• Receiving, evaluating, and finalizing your demands, questions, complaints, and suggestions,
• Storing the logs for the duration of general term of limitation to use them as evidence for possible disputes in the future.

 
Based on the legal ground of data processing being mandatory for the legitimate interests of the data controller, provided that this processing does not violate the fundamental rights and freedoms of the data subject:

• Managing the information and promotion activities of our goods and services,
• Ensuring the security of Company operations and vehicles,
• Conducting damage management processes of the vehicle assigned to you, and within this context, benefiting from artificial intelligence technologies at the beginning and end of the rental process for the damage detection,
• Tracking the passage information of the vehicle that is allocated to you via the fast passage system (HGS) and similar systems and managing the fines related with it, 
• Managing the verification and/or activation processes regarding your registrations and transactions,
• Managing the accounting and financial processes,
• Executing the customers’ financial risk evaluations,
• Planning and executing the processes of customer relationship management,
• Following up and managing the legal matters,
• Executing the information security processes,
• Concluding audits and ethical activities,
• Following up and developing the actions regarding the services,
• Planning and executing the customer satisfaction and corporate communication processes,
• Executing the draws, campaigns, contests, promotion, or advertising processes,
• Ensuring the legal, technical, commercial and business security of our Company and the data subjects who are in business relationship with our Company,
• In case you become a member of the Loyalty Program, carrying out Loyalty Program loyalty creation and development activities.

Based on your explicit consent:

• Within the scope of allowing you to benefit from our Connected Car goods and services, processing your identity, vehicle, location, customer transaction and marketing information to analyze your driving performance for offering tailored vehicle insurance and to decrease the insurance premium if low risk is detected, to calculate points on the basis of driving and offering advantages based on these points,
• Processing your health data for the purpose of providing after-sales support services when you have been involved in an accident,
• Processing your identity, communication, customer transaction, marketing, and vehicle-insurance information for the purposes of tailoring and suggesting the goods and services provided by our Company, based on your likes, usage habits and needs, and in this regard, sending commercial electronic messages such as advertisements, promotions, and campaigns to your contact information.

5) Data Subject’s Rights Specified under Article 11 of the Law

We hereby inform that as a data subject, you are entitled to the following rights, set forth under Article 11 of the Law: 

• To learn whether your personal data are being processed, 
• To request information if your personal data have been processed, 
• To learn the purpose of the processing of your personal data and whether they have been used accordingly, 
• To learn which third parties domestic or abroad your personal data has been transferred to, 
• To request rectification in case your personal data has been processed incompletely or inaccurately and to demand the operations in this regard be reported to third parties your personal data has been transferred to, 
• To demand the erasure or destruction of your personal data in the event that the reasons for the processing no longer exist even though it was processed in accordance with the Law and other relevant provisions and to demand the operations in this regard be reported to third parties your personal data has been transferred to, 
• To object to negative consequences to you that are concluded, as a result of analysis of the processed personal data through solely automatic systems, 
• To demand compensation for the damages that you have suffered as a result of an unlawful processing of your personal data.

You may convey your requests concerning your rights listed above to the Company, by filling out the Data Subject Application Form, which can be found at, https://otokocotomotiv.com.tr/veri_sahibi_basvuru_formu.pdf. Depending on the nature of your request, your application will be concluded by the Company, as soon as possible, within 30 days at the latest and in principle, free of charge. However, if the process requires additional costs, a fee may be demanded by the Company according to the tariff determined by the Personal Data.