Personal Data and General Confidentiality Agreement

PROTECTION OF PERSONAL DATA

Our company has the title of "Data Supervisor" in accordance with the "Personal Data Protection Law" numbered 6998 published in the Official Gazette dated 07.04.2016. As CİTY CAR RENTAL, we show maximum sensitivity to the security of your personal data. With this awareness, as the Company, we attach great importance to the processing and preservation of all personal data belonging to all persons related to the Company, including those who benefit from our products and services, in accordance with the Law No. 6698 on the Protection of Personal Data. With the full understanding of this responsibility, we process your personal data as "Data Supervisor" as defined in the KVK Law, as explained and within the limits determined by the legislation.

Definitions

Text: This refers to the text of clarification.

Data: It refers to the information stored electronically on a computer or a number of paper-based filing systems.

Personal Data: It refers to all kinds of information regarding an identified or identifiable natural person. The company uses the data generally referred to as "web registration information" (users' internet browsers, mobile devices, operating system, the pages they visit, other internet pages that they access to these pages, through the websites for the purposes of understanding customer preferences and providing better service, and for similar purposes, information about the date and time of visiting the relevant website, specific pages visited and more) and may use cookies if the pages on the website are visited. Cookies and web registration information will also be subject to this Text in case the data is processed together, if they point to a specific person.

Special Quality / Sensitive Personal Data: Race, ethnic origin, political thoughts, philosophical belief, religion, sect or other beliefs, dress and dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures and biometric data Refers to the related data. Sensitive data can only be processed under strict conditions, and processing often requires the explicit consent of the data subject.

Data Subject or Owners: It includes all natural persons, including employees whose Personal Data is processed by CİTY CAR RENTAL. The data owner does not have to be a Turkish citizen or reside in Turkey. All data owners have legal rights regarding their personal data.

Data Supervisor: It refers to the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system. These people have responsibilities in determining practices and principles in accordance with the Law. The data controller for all personal data used in the business processes of CİTY CAR RENTAL is the relevant CİTY CAR RENTAL.

Data Processor: Any person who processes data on behalf of and based on the authority given by a data controller. Employees of the data controller are excluded from this definition, but if applicable, suppliers, business partners and other third parties who process personal data on behalf of CİTY CAR RENTAL may be included in this definition.

Data Processing / Processing: Covers all kinds of activities related to data use. It includes the acquisition, recording or retention of data, or one or some operations performed on the data, including editing, modification, retrieval, use, disclosure, deletion or destruction. Transferring data to third parties also means processing the data.

METHOD

As CİTY CAR RENTAL, as a data controller, through our call centers, written communication channels, social media pages, mobile communication channels, in-store communication channels and / or all kinds of channels including but not limited to these; Your personal and / or private personal data that we have obtained with your consent can be obtained, recorded, stored, stored, changed, updated, periodically checked, re-classified, for the period required for the purpose for which they are processed or for the period stipulated in the relevant law. In case of legal or service-related actual requirements, CİTY CAR RENTAL works with the private-legal persons or the public institutions and organizations with which it is legally obliged and / or the relevant third person real person / legal person residing in Turkey or abroad can be shared / transferred with individuals, can be transferred abroad in case of legal or service-related actual requirements. CİTY CAR RENTAL customers can benefit from our services, inform you about our campaigns in case of your approval, record your suggestions and complaints, create better service standards, CİTY CAR RENTAL commercial and 

We inform you that we can process your personal data for purposes such as determining and implementing business strategies and in any case in accordance with the Personal Data Protection Law No. 6698 and the relevant legislation.

COLLECTION, PROCESSING AND PURPOSE OF PERSONAL DATA

As CİTY CAR RENTAL, as a data controller, within the framework of our legal obligations arising from the legislation; long and short term car rental, sale, transfer, registration, loss, license renewal and issuance, plate renewal and removal, traffic consultancy services, used vehicle sales and after-sales services, wholesale spare parts and accessories sales, insurance and the provision of financial services, etc. You can take advantage of our services, inform you about our campaigns upon your approval, record your suggestions and complaints, create better service standards for you, determine and implement CİTY CAR RENTAL commercial and business strategies, verbally, website, social media channels, mobile applications and We collect it through similar means, verbally, in writing or electronically. Personal Data is processed by CİTY CAR RENTAL in accordance with the procedures and principles stipulated in the Law and this Text. CİTY CAR RENTAL acts on the following principles while processing Personal Data: - Personal Data is processed in accordance with the relevant legal rules and the requirements of the honesty rule.

- Personal Data is ensured to be accurate and up to date. In this context, issues such as determining the sources from which the data are obtained, verifying their accuracy, and evaluating whether they need to be updated are carefully considered.

- Personal Data; processed for specific, explicit and legitimate purposes. The legitimacy of the purpose means that the Personal Data processed by CİTY CAR RENTAL is linked to the work it has done or the service it has provided and is necessary for them.

- Personal Data is linked to the achievement of the purposes determined by CİTY CAR RENTAL, and the processing of Personal Data that is not related to the realization of the purpose or is not needed is avoided. It limits the processed data to only what is necessary for the achievement of the purpose. Personal Data processed in this context are related, limited and measured with the purpose for which they are processed.

- If there is a period stipulated in the relevant legislation for the storage of data, it complies with these periods; otherwise, it retains Personal Data only for the period required for the purpose for which it was processed. In the event that there is no valid reason for the further preservation of Personal Data, the data in question will be deleted, destroyed or anonymized.

Conditions of Processing Personal Data

CİTY CAR RENTAL does not process Personal Data without the explicit consent of the data owner. In the event of one of the following conditions, Personal Data may be processed without the explicit consent of the data owner.

- CİTY CAR RENTAL may process Personal Data of Personal Data Owners, even without express consent, in cases clearly stipulated in the laws. For example; In accordance with Article 230 of the Tax Procedure Law, the explicit consent of the relevant person will not be sought in order to include the name of the relevant person on the invoice.

- Personal Data may be processed without explicit consent in order to protect the life or physical integrity of the persons who are unable to disclose their consent due to the actual impossibility or whose consent cannot be given validity or the life or body integrity of another person. For example, in a situation where the consent of the person is not conscious or his consent is not valid because he is mentally ill, the Personal Data of the Personal Data Owner may be processed during medical intervention in order to protect the integrity of life or body. In this context, data such as blood type, previous diseases and surgeries, medications used can be processed through the relevant health system.

- Personal Data belonging to the parties of the contract can be processed, provided that it is directly related to the establishment or performance of a contract by CİTY CAR RENTAL. For example, in order to pay the money in accordance with a contract made, the account number of the creditor can be obtained.

- CİTY CAR RENTAL may process Personal Data of Personal Data Owners, if it is mandatory to fulfill its legal obligations as a data controller.

- Personal Data made public by CİTY CAR RENTAL, in other words, disclosed to the public in any way by the Personal Data Owners themselves, can be processed as the legal benefit that needs to be protected disappears.

- CİTY CAR RENTAL may process Personal Data of Personal Data Owners without seeking explicit consent in cases where data processing is necessary for the exercise or protection of a legally legitimate right.

- CİTY CAR RENTAL, Personal Data in cases where it is necessary to process Personal Data for the provision of legitimate interests of Personal Data Owners, provided that they do not harm their fundamental rights and freedoms protected under the Law and Policy.

It can process the Personal Data of its Owners. The Company shows the necessary sensitivity to comply with the basic principles regarding the protection of Personal Data and to observe the balance of interests of Personal Data Owners.

Conditions for Processing Special Quality Personal Data

CİTY CAR RENTAL does not process Special Qualified Personal Data without the express consent of the person concerned. However, Personal Data other than health and sexual life may be processed without the explicit consent of the relevant person in cases stipulated by the law. Personal Data related to health and sexual life are only processed by CİTY CAR RENTAL for the purpose of protecting public health, conducting preventive medicine, medical diagnosis and treatment and care services, planning and managing health services and financing, without seeking the explicit consent of the relevant person under conditions where we are under the obligation to keep confidential. . CİTY CAR RENTAL carries out the necessary actions to take adequate measures determined by the Board in the processing of Special Quality Personal Data.

CONDITIONS WITHOUT CONSENT TO COLLECTING AND PROCESSING PERSONAL DATA

Pursuant to the 2nd paragraph of Article 5 of the Law on the Protection of Personal Data No.6698, the legal obligation of CİTY CAR RENTAL as the data controller, provided that it is clearly stipulated in the law, that it is directly related to the establishment or execution of a contract, the processing of personal data belonging to the parties of the contract. data processing is mandatory for the establishment, use or protection of a right, data processing is mandatory for the legitimate interests of the company, which is the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned, CİTY CAR RENTAL has the right to process personal data without obtaining explicit consent. In order to fulfill the legal obligations arising from the legislation that CİTY CAR RENTAL is subject to and / or Due to legal obligations and / or in order to fulfill the obligation to transfer the Data to persons who may demand secrets in the law, Data disclosure, use and transfer are not subject to the confidentiality obligation of CİTY CAR RENTAL and CİTY CAR RENTAL does not need to obtain a separate consent for this Data. is authorized to disclose, give, process and transfer to the relevant persons.

TRANSFER OF PERSONAL DATA AND CONDITIONS

CİTY CAR RENTAL may transfer Personal Data of Personal Data Owners and Special Qualified Personal Data to third parties in accordance with the Law by creating the necessary confidentiality conditions and taking security measures in line with the purposes of processing Personal Data. CİTY CAR RENTAL acts in accordance with the regulations stipulated in the Law during the transfer of Personal Data. In this context, in line with the legitimate and lawful personal data processing purposes of CİTY CAR RENTAL, based on one or more of the Personal Data processing conditions specified in Article 5 of the Law, and limited to the Personal Data to third parties: If the Personal Data owner has explicit consent; If there is a clear regulation in the laws regarding the transfer of Personal Data, if it is mandatory for the protection of the life or body integrity of the Personal Data owner or someone else, and if the Personal Data owner is unable to disclose his consent due to actual impossibility or his consent is not legally valid, To be directly related to the establishment or execution of a contract If it is necessary to transfer Personal Data belonging to the parties of the contract, if the Personal Data transfer is mandatory for CİTY CAR RENTAL to fulfill its legal obligation, If the Personal Data is made public by the Personal Data owner, If the Personal Data transfer is mandatory for the establishment, use or protection of a right, Provided that the fundamental rights and freedoms of the Personal Data owner are not damaged, Personal Data transfer can be transferred if necessary for the legitimate interests of CİTY CAR RENTAL.

Conditions of Transfer of Special Quality Personal Data

CİTY CAR RENTAL, with due diligence, taking the necessary security measures and taking adequate precautions stipulated by the KVK Board; can transfer the Personal Data of the Personal Data Owner to the third parties in the following cases in line with the legitimate and lawful Personal Data processing purposes. (i) In the event of the explicit consent of the Personal Data Owner or (ii) Without the explicit consent of the Personal Data Owner in the presence of the following conditions;

Special Qualified Personal Data (race, ethnicity, political opinion, philosophical belief, religion, sect or other beliefs, dress and dress, association, except for the health and sexual life of the Personal Data Owner,

foundation or union membership, data on criminal convictions and security measures, as well as biometric and genetic data), in cases stipulated by law,

Special Qualified Personal Data related to the health and sexual life of the Personal Data Owner, only for the protection of public health, preventive medicine, medical diagnosis, treatment and care services, planning and managing health services and financing, or persons under confidentiality obligation. by authorized institutions and organizations.

Purposes of Processing and Transferring Personal Data

Personal Data; Planning and implementing the human resources policies of CİTY CAR RENTAL in accordance with the law and the purpose of the Law, Planning, executing and managing its commercial partnerships and strategies correctly, Ensuring the legal, commercial and physical security of itself and its business partners, Ensuring the corporate operation Planning and execution of management and communication activities, Making the best use of the products and services of Personal Data Owners and tailoring them according to their demands, needs and requests, Ensuring the highest level of data security, Creating databases, Improving the services offered on the website and to eliminate errors on the site, to communicate with Personal Data Owners who convey their requests and complaints, and to provide demand and complaint management, Event management, Managing relations with business partners or suppliers, Managing personnel recruitment processes, Group Companies Supporting the personnel recruitment processes and compliance with the relevant legislation, planning and execution of audit activities to ensure that the activities of Group Companies are carried out in accordance with the relevant legislation, Supporting Group Companies in the realization of corporate and partnership law transactions, Financial reporting and risk management transactions Execution / follow-up, Execution / follow-up of Company legal affairs, Conducting studies to protect its reputation, Managing investor relations, Providing information to authorized institutions based on legislation, Creating and tracking visitor records are processed within the scope of the personal data processing conditions specified in Articles 5 and 6 of the Law, limited to their purposes. If the processing activity carried out for the aforementioned purposes does not meet any of the conditions stipulated under the Law, your explicit consent is obtained by CİTY CAR RENTAL regarding the relevant processing process.

METHOD OF PERSONAL DATA COLLECTION AND LEGAL REASON, DELETION, DESTRUCTION, STORAGE TIME

Method and Legal Reason for Collecting Personal Data

Personal Data, in order to control compliance with Article 1 regulating the purpose of the Law and Article 2 regulating the scope of the Law in all kinds of verbal, written, electronic media; It is collected by technical and other methods, through various means such as call center, CİTY CAR RENTAL website, mobile application, within the framework of legislation, contract, demand and legal reasons, in order to fulfill the responsibilities arising from the law completely and correctly, and the data assigned by the Company or the Company processed by the processors.

Deletion, Destruction or Anonymization of Personal Data

Provided that the provisions of other laws regarding the deletion, destruction or anonymization of Personal Data are reserved, CİTY CAR RENTAL has processed Personal Data in accordance with the provisions of this Law and other laws, in case the reasons requiring its processing are eliminated, the Personal Data is ex officio or Deletes, destroys or anonymizes at the request of the data subject. With the deletion of Personal Data, these data are destroyed in such a way that they cannot be used and retrieved in any way. Accordingly, Personal Data is irreversibly deleted from tools such as documents, files, CDs, floppy disks, and hard disks in which they are recorded. Destruction of Personal Data, on the other hand, refers to the destruction of materials suitable for data storage such as documents, files, CDs, floppy disks, hard disks in which the data are recorded so that the information cannot be recovered and used. By making the data anonym, it is meant to render the Personal Data not to be associated with a real person whose identity is known or can be determined, even if it is matched with other data.

Retention Period of Personal Data

CİTY CAR RENTAL keeps Personal Data for the period specified in this legislation, in case it is stipulated in the legislation. If a period of time is not regulated in the legislation regarding how long personal data should be stored, Personal Data will be processed for the period required to be processed within the framework of honesty rules, in accordance with the practices of CİTY CAR RENTAL and the practices of CİTY CAR RENTAL's business life, depending on the activity carried out while processing that data. then delete, destroy or anonymously

brings. The purpose of processing personal data has ended; If the storage periods determined by the relevant legislation and CİTY CAR RENTAL have also come to an end; Personal data can only be stored in order to provide evidence in possible legal disputes or to assert the relevant right related to personal data or to establish a defense. In the establishment of the periods here, although the time-out periods for the claiming of the mentioned right and the time-out periods have passed, the retention periods are determined based on the examples made in the requests made to CİTY CAR RENTAL before on the same issues. In this case, the stored personal data is not accessed for any other purpose, and access to relevant personal data is provided only when it is required to be used in the relevant legal dispute. Here, too, after the aforementioned period expires, personal data are deleted, destroyed or anonymized.

LIGHTING OBLIGATION

CİTY CAR RENTAL is obliged to inform the real persons whose data will be processed during the acquisition of Personal Data. The scope of this information obligation is as follows:

- Identity of the data controller and, if any, its representative,

- For what purpose Personal Data will be processed,

- To whom and for what purpose the processed Personal Data can be transferred,

- Management of Personal Data collection and its legal reason and rights.

CİTY CAR RENTAL will provide necessary information from Third Parties through data acquisition tools to process in its systems and obtain informed consent from the Data Owners for data processing in order to prove that the disclosure obligation has been fulfilled. Personal Data may be collected verbally, in writing or electronically through all channels of CİTY CAR RENTAL including electronic commerce, sales stores, branches, websites, call center and all other similar channels from which service can be obtained from third parties, automatically or non-automatically.

- Obtaining Personal Data in Written Form: During the acquisition of Personal Data in written form, CİTY CAR RENTAL will fulfill its Disclosure Obligation regarding the processing of data provided that new relevant forms and information to be revised based on this Text are used. In addition, all forms and contracts, including Authorized Communication Forms to be obtained from persons with whom a customer relationship is established, will be revised to show the explicit consent of the Data Respondent regarding the processing of Personal Data, although the processing of the relevant data group may be considered as an exception in accordance with the Law. In customer relations, new forms, documents and information that prove compliance with the Law will be used; All relevant employees will be trained to provide sufficient detailed information and referrals to the real person on this subject. Absolutely, it will be ensured that Personal Data will be obtained through written forms with informed consents.

- Verbal Obtaining of Personal Data: Information will be provided regarding the obligation of disclosure regarding the processing of Personal Data during the acquisition of new data in any way or not available for existing customers, and data acquisition through the Call Center, in accordance with the currently received Authorized Communication Forms. During the acquisition of verbal data, it will be reminded that the interview has been recorded, provided that prior information is given, and it will be confirmed that the Personal Data will be processed as included in this Policy and the existing Authorized Communication Forms, if any. Employee and Call Center business processes will be re-evaluated and implemented within this framework.

- Obtaining Personal Data in Electronic Environment: All contracts and documents / link addresses / web pages that require the acquisition and processing of Personal Data, including the data obtained through electronic commerce channels and other internet channels of CİTY CAR RENTAL, are Personal It has been revised to fulfill the disclosure obligation regarding data processing. This text will be available on all internet pages of CİTY CAR RENTAL, and systems will be installed that require the approval of data processing by CİTY CAR RENTAL in order to obtain data at every link address that may require data acquisition. Unless it is clearly marked that the processing of Personal Data is approved, any information and document entered will not be automatically recorded in any CİTY CAR RENTAL system and will not be processed in any way.

YOUR RIGHTS FOR THE PROTECTION OF PERSONAL DATA

CİTY CAR RENTAL will respond to the following requests made by the relevant persons in written, verbal, electronic e-mail:

a) Learning whether CİTY CAR RENTAL processes personal data related to them and which personal data it processes,

b) Obtaining information regarding the purposes of the processing activity,

c) CİTY CAR RENTAL's domestically or domestically

To know the third parties to whom personal data are transferred,

d) Request rectification in case personal data are processed incompletely or inaccurately,

e) To request the deletion or destruction of personal data in accordance with the Law,

f) In case of request for correction, deletion or destruction of personal data; to request the transactions made to be notified to third parties to whom personal data have been transferred,

g) To object to the occurrence of a result against the person himself by analyzing the processed data exclusively through automated systems, and

h) Getting a copy of their personal data.

You can contact us about your comments and questions. Pursuant to paragraph 1 of Article 13 of the KVK Law, you can submit your request to use your above-mentioned rights to our Company in writing or by other methods determined by the Personal Data Protection Board.

Personal Data Owner Application Procedure

You can use the "Application Form" to submit your requests regarding your rights mentioned above.

Your applications regarding your demands;

From hand

By registered mail

Via notary

Karakavak Mah. Güngör Caddesi No: 16 / A Yeşilyurt / MALATYA with a wet signed copy or

You can transmit the Personal Data by another method stipulated by the Protection Board. Your request will be evaluated and concluded as soon as possible and in any case within the period specified in the KVKK. However, if the written response to be given by us regarding your application exceeds 10 pages and / or requires it to be given in a recording medium such as CD, flash memory, it will be subject to the fee determined by the Personal Data Protection Board in accordance with the provisions of the "Communiqué on Application Procedures and Principles for Data Supervisor".

In order for third parties to apply on your behalf, there must be a special power of attorney issued by a notary public on behalf of the person to apply.

If the process for the examination and finalization of your application requires a cost, our Company may charge the fee in the tariff determined by the Board.

Click on CİTY CAR RENTAL Data Owner Application Form.