Personal Data Protection

Under the Personal Data Protection Law No. 6698 (“Law”), Otokoç Otomotiv Ticaret ve Sanayi Anonim Şirketi (“Company”), acting as the data controller, places great importance on protecting your personal data. Detailed information about the purposes of processing your personal data by our Company can be found in the Otokoç Otomotiv Trade and Industry Inc. Personal Data Protection and Processing Policy (“Policy”), available at https://otokocotomotiv.com.tr/kvk_politikasi.pdf.

Your collected personal data may be processed by our Company for the purposes (“Purposes”) within the scope of necessary work by our business units to enable you to benefit from the products and services offered, execution of related business processes, performance of commercial activities by relevant units, and to ensure legal, technical, and commercial-business security of our Company and related persons in business relations, in accordance with the personal data processing conditions stated in Articles 5 and 6 of the Law:

Regarding Avis & Budget products and services;

• Facilitating your hourly/daily/monthly vehicle or tire rental service, including making or canceling reservations,
• Execution and enforcement of rental agreements,
• Monitoring your toll passage information with the vehicle assigned and management of related fines,
• Mandatory presence of GPS devices (global satellite navigation system) in rental vehicles and storage of vehicle location data as legally required,
• Managing and tracking damages on the assigned vehicle, including using AI technologies for damage assessment at rental start and end,
• Location tracking,
• Fuel level monitoring,
• Recording destination location when using vehicle sharing service,
• Enabling your participation in the Koç Ailem Special Moments Experience program,
• Utilization of Connected Car products and services,
• With your consent for Connected Car products and services; processing your identity, location, vehicle, customer transaction, and marketing data to analyze driving performance and offer discounted insurance (kasko) pricing, reward points, and related benefits linked to low risk assessments.

Regarding Otokoç products and services;

• Vehicle sales,
• Provision of vehicle maintenance services,
• After-sales support services,
• Provision of valet services,

Regarding Otokoç Used Vehicle products and services;

• Used vehicle sales,
• Cash vehicle purchase services,
• Vehicle auctions and sales processes,
• Vehicle inspection services,
• Listing and directing used car sales ads to you,
• Managing used vehicle reservation transactions,
• If you join the Winners Club Loyalty Program (“Loyalty Program”); establishing and managing your or your corporate client’s membership, calculating earned points/benefits, informing about earned points/benefits, providing discounts, campaigns, gifts, promotions, reminding about expiring points/benefits, and performing necessary processes for Loyalty Program benefits,
• If you join the Loyalty Program; carrying out loyalty development activities.

Regarding Avis Fleet products and services;

• Facilitating your long-term vehicle or tire rental, including accepting or canceling reservations,
• Execution and enforcement of rental agreements,
• Monitoring toll passages and managing related fines for assigned vehicles,
• Mandatory GPS presence in rental vehicles and location data storage as required by law,
• Provision of HGS / OGS systems,
• Conducting periodic vehicle maintenance,
• Providing additional services such as fleet insurance, accident and damage management upon your request,

Regarding Maestro Fleet Management products and services, personal data processing activities by the Company may vary depending on your membership status. In this context, if you are a corporate member:

• Planning, execution, and monitoring of maintenance, breakdown, damage, and tire change processes for vehicles.
• Planning, coordination, and execution of complementary service offerings (maintenance, repair, tires, warranty, roadside assistance, etc.) for customers receiving Maestro Fleet Management services,
• Conducting and recording appraisal and expertise procedures,
• Managing and recording administrative vehicle processes (payments, traffic fine management, insurance, etc.).

If you are an individual member:

• Planning, coordination, and execution of complementary service offerings (maintenance, repair, tires, warranty, roadside assistance, etc.) for customers receiving Maestro Fleet Management services,

Regarding Otokoç Parts products and services;

• Execution of vehicle spare parts and accessory sales,
• Provision of installation services,

For all our products and services;

• Verification and/or activation processes for your registration and transactions,
• Creating appointments and providing quotes,
• Opening sales records, carrying out online/offline payment and invoicing activities,
• Establishing or fulfilling the sales contract due to your purchase of our company's products and services,
• Providing information and promotion activities about our products and services,
• Creating, tracking, or canceling memberships,
• Providing vehicle protection services,
• Ensuring the security of company operations and vehicles,
• Delivering post-sale support services,
• Conducting accounting and finance processes,
• Performing customers' financial risk assessments,
• Receiving, evaluating, and resolving your requests, questions, complaints, and suggestions,
• Updating customer information,
• Ensuring compliance with legally mandated storage obligations,
• Evaluating and concluding your applications to the Company regarding your rights under Article 11 of the Law about personal data processing by our Company, and performing necessary procedures in accordance with legislation,
• Storing records throughout the general statute of limitations to serve as evidence in possible future disputes,
• Planning and executing customer relationship management processes,
• Tracking and managing legal affairs,
• Monitoring and improving service-related activities,
• Fulfilling official institution requests and providing information to authorized bodies as required by law,
• Managing information security processes,
• Conducting audit and ethical activities,
• Planning and executing customer satisfaction and corporate communication activities,
• Conducting sweepstakes, campaigns, competitions, promotions, or advertising activities,
• Providing additional benefits to loyalty program members,
• Processing your health data for post-sale support services in case of an accident if you have given consent,
• Transferring and processing your usernames, passwords, and other account info of membership accounts on our websites or apps to membership accounts of our company's brands’ websites and/or apps,
• Processing your identity, contact, customer transaction, marketing, and vehicle-insurance data for personalized product and service offers tailored to your preferences, usage habits, and needs and sending commercial electronic communications like ads, promotions, and campaigns to your contact info upon your consent.

Your collected personal data may be transferred to our business/solution partners, suppliers, legally authorized public institutions, and authorized private entities within the scope of the Purpose. Your data is shared with our overseas supplier Microsoft Ireland Operations Limited based on the existence of a standard contract for legal reasons, for purposes such as conducting information security processes, communication activities, business operations/audits, post-sale support services, sales processes, production and operations processes, receiving and evaluating suggestions to improve business processes, and marketing analysis. Detailed information about the parties to whom your personal data is transferred can be found 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 data processing conditions specified in Article 8 of the Law, for purposes including booking reservations, providing vehicles, and enabling benefits within the Koç Ailem Special Moments Experience program.

If you use Avis car rental services;

• your personal data may be shared with Avis Europe and Middle East Limited, a data processor located abroad, within the scope of vehicle reservations, rental agreements, cancellations, service tracking, loyalty program benefits, and memberships, under the personal data processing conditions outlined in Article 9 of the Law and according to the Personal Data Protection Board's decision E-67322700-045.02-0000137706 dated 04.04.2023 about "Commitment to Data Transfer Abroad".
• Your personal data may also be shared with Avis Europe and Middle East Limited abroad for following up and organizing service activities, performance measurements, calculating Otokoç’s license fees and conducting financial transactions, reporting reservation requests and cancellations, membership activities, and loyalty programs, and for providing car rental services and membership activities if you wish to use overseas services, under the same Board decision and legal conditions.

Your personal data is collected by our Company electronically through our website, mobile applications, social media accounts, email, call center, and vehicle usage when you contact us within the scope of selling or providing our products or services; by email through your employer if you wish to benefit from the Koç Family Special Moments Experience program; and physically via camera recordings, cargo/mail, fax, face-to-face meetings, based on the legal grounds specified in Articles 5 and 6 of the Law as detailed below.

Based on the legal reason that processing personal data related directly to the conclusion or performance of a contract is necessary;

• Completion of vehicle sales,
• Completion of cash vehicle purchase services,
• Execution of tender-based vehicle purchase and sale processes,
• Completion of used vehicle sales,
• Access to our hourly/daily/monthly vehicle or tire rental services, including making or canceling reservations,
• Access to our long-term vehicle or tire rental services, including making or canceling reservations,
• Provision of valet service,
• Provision of vehicle maintenance services,
• Provision of vehicle inspection (expertise) services,
• Provision of HGS / OGS services,
• Execution of periodic vehicle maintenance processes,
• Provision of additional services upon your request such as fleet vehicle rental insurance, accident and damage management,
• Conclusion and execution of lease agreements,
• Execution of vehicle spare parts and accessories sales,
• Calling towing services and providing roadside assistance in case of accidents or breakdowns,
• Recording the destination location when using vehicle sharing services,
• Your participation in the Koç Family Special Moments Experience program,
• Your use of Connected Car products and services,
• Completion of tire sales,
• Provision of installation services,
• Appointment scheduling and quotation issuance,
• Opening sales records, conducting online/offline payment and invoicing activities,
• Establishment or performance of sales contracts related to your purchase of our Company’s products or services,
• Updating customer information,
• Verification and/or activation processes for your records and transactions,
• Creation, tracking, or cancellation of memberships,
• Provision of vehicle protection services,
• Fulfillment of after-sales support services,
• Providing additional benefits to loyalty program members,
• Providing listing and referral services for used vehicle sale advertisements,
• Processing used vehicle reservation transactions,
• If you join the Loyalty Program; creating and operating a loyalty membership for you or your corporate client (employee/authorized person/representative); calculating earned points/benefits; informing about earned points/benefits; enabling use of discounts, campaigns, gifts, promotions, and similar benefits; reminding of expired points/benefits; and conducting necessary operations to provide Loyalty Program benefits,
• Planning, coordinating and managing supplementary service tasks (maintenance, repair, tire, warranty, roadside assistance, etc.) for customers using Maestro Fleet Management services,
• Conducting valuation and inspection procedures and recording them,
• Planning, managing, and monitoring vehicle maintenance, breakdown, damage, and tire change processes,
• Execution and recording of administrative vehicle procedures (payment, traffic fine management, insurance, etc.).

Based on the legal reason of explicit legal requirements and the necessity for our Company to fulfill its legal obligations;

• Fulfillment of official institution requests and provision of information to authorized organizations as required by law,
• Ensuring compliance with legally mandated data retention obligations,
• Evaluation and lawful completion of your applications submitted to the Company regarding your rights under Article 11 of the Law concerning your personal data processed by our Company, and carrying out necessary procedures accordingly,
• Mandatory presence of GPS devices (global satellite navigation system) in rental vehicles and retention of location records as required by law.

Based on the legal grounds that data processing is necessary for establishing, exercising, or protecting a right;

• Receipt, evaluation, and resolution of your requests, questions, complaints, and suggestions,
• Retention of records as evidence during the general statute of limitations period for potential future disputes.

Based on the legal grounds that data processing is necessary for the legitimate interests of the data controller without harming the fundamental rights and freedoms of the relevant person;

• Providing information and promotional activities about our products and services,
• Ensuring the security of company operations and vehicles,
• Managing and tracking damage to the vehicle assigned to you; using AI technologies for damage assessment at rental start and end,
• Monitoring your transit data under fast pass systems (HGS) and similar systems for the assigned vehicle, and managing related fines accordingly,
• Location tracking,
• Fuel level monitoring,
• Verification and/or activation processes related to your records and transactions,
• Executing accounting and financial processes,
• Performing financial risk assessments of customers,
• Planning and execution of customer relationship management processes,
• Handling and conducting legal affairs,
• Managing information security processes,
• Carrying out audit and ethical activities,
• Monitoring and improving service-related activities,
• Planning and executing customer satisfaction and corporate communication activities,
• Conducting lotteries, campaigns, contests, promotions, or advertising activities,
• Ensuring legal, technical, commercial, and occupational safety for our Company and individuals in business relations with the Company,
• If you join the Loyalty Program; implementing efforts to build and enhance loyalty within the Loyalty Program.

Upon your explicit consent;

• For you to benefit from our Connected Car products and services; processing identity, vehicle, location, customer transaction, and marketing data to offer personalized pricing for insurance products based on your driving performance analysis and low risk rate, providing discounts on the insurance product, earning points based on driving, and offering related advantages,
• Processing your health data to provide after-sales support services in case of an accident,
• Processing your identity, contact, customer transaction, marketing, vehicle, and insurance data to customize the products and services offered by our Company according to your preferences, usage habits, and needs, and to send commercial electronic communications such as advertisements, promotions, and campaigns to your contact information.

As a data subject, you are hereby informed that you have the following rights under Article 11 of the Law:

• To learn whether personal data is processed,
• To request information if personal data has been processed,
• To learn the purpose of personal data processing and whether it is used accordingly,
• To know the third parties within or outside the country to whom personal data is transferred,
• To request correction if personal data is incomplete or incorrect, and to demand notification of this correction to the third parties the data was shared with,
• To request deletion or destruction of personal data if the reasons requiring processing no longer exist, despite processing being lawful, and to demand notification of this to the third parties the data was shared with,
• To object to results against the individual arising solely from analysis by automated systems,
• In case of damage due to unlawful processing of personal data, to claim compensation.

You can submit your requests regarding the above rights by filling out the Data Subject Application Form available at https://otokocotomotiv.com.tr/veri_sahibi_basvuru_formu.pdf and sending it to our Company. Depending on the nature of your request, it will be processed free of charge within the shortest possible time and no later than thirty days; however, if the process involves additional costs, fees may be charged according to the tariff determined by the Personal Data Protection Board.