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”).
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, as the employee/authorized/representative of our corporate customer, 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 of the Law.
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;
- Establishing a business relationship between our Company and the corporate customer of which you are an employee/authorized/representative,
- Fulfilling all obligations arising from the business relationship between our Company and the corporate customer whose employee/authority/representative you are, and establishing the necessary communications within this scope,
- Managing corporate customer relations and ensuring that contact information is up-to-date and accurate,
- Planning, auditing and executing information security processes,
- Conducting legal processes in which our Company is involved,
- Determining and implementing our company's commercial and business strategies,
- Planning and executing vendor satisfaction and corporate communication activities,
- Managing transactions and requests related to the follow-up of financial and sales records,
- Tracking your passage information within the scope of the fast passage system (HGS) and similar systems with the vehicle allocated to you under the relevant corporate agreement, and managing the penalties in this matter,
- Conducting damage management and follow-up of the vehicle allocated to you due to the relevant corporate agreement, 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,
- Providing commercial electronic messages to you if you are a recipient within the scope of the trader exception pursuant to Article 6/3 of the Regulation on Commercial Communication and Commercial Electronic Messages & if you have not submitted a rejection notification,
- Conducting company audit processes,
- Receiving, evaluating and finalizing your requests and complaints,
- Providing our support services, including call center.
Based on the legal ground of data processing being necessary for the establishment, exercise or protection of any right;
- Storing personal data for the duration of general term of limitation to use them as evidence for possible disputes in the future,
- Receiving, evaluating and finalizing your requests and complaints.
Based on the legal ground of being explicitly stated in the law and being mandatory for our Company to fulfil its legal obligations as a data controller:
- 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,
- Executing the demands of governmental agencies,
- Informing the authorized agencies due to the legislative obligations,
- Ensuring that contact information is up-to-date and accurate,
- Ensuring compliance with the storage obligations which are stipulated in the legislation,
- Responding to data subject applications in accordance with the legislation and taking necessary actions.
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 production and operation processes, receiving and evaluating suggestions for the improvement of business processes and conducting marketing analysis studies.
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; concluding and executing the rental agreements, following up the activities related with the services, 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, 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.
Method for the Collection of Personal Data
Your personal data is collected by our company mainly through the corporate customer channel of which you are an employee/authorized/representative within the scope of the sale or provision of our products and services; in cases where you also contact us directly, electronically through our website, mobile applications, social media accounts, e-mail, call center and, if applicable, via the usage of vehicle; physically through camera recordings, cargo / mail, fax, face-to-face meetings channels.
Data Subject’s Rights Specified under Article 11 of the Law
We hereby inform you 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.
