Personal Data Protection Statement

ÇELİK MOTOR TİCARET ANONİM ŞİRKETİ

CLARIFICATION TEXT ON PROTECTING AND PROCESSING PERSONAL DATA

1. DATA CONTROLLER

Your personal data may be processed by Çelik Motor Ticaret Anonim Şirketi (the “Company”) in the capacity of data controller pursuant to the Law on the Protection of Personal Data no. 6698 (the “Law”) under the following scope.

Real person whose personal data are processed under access to www.garenta.com.tr/ and garenta app (“web”) is Data Subject.

2. PURPOSE OF PROCESSING YOUR PERSONAL DATA

In the event of only gaining access to web as Data Subject, IP address information, other data connected to such information and cookie information is processed, in accordance with general principles provided at the Law intended for processing of such information, they are processed under purposes of execution of operations carried out by the Company in compliance with legislation (following obligations of information storage, reporting, notification envisaged by governmental agencies) and execution of anlysis works (operations that may be performed intended for increasing quality of service and products).

In the event you fill out form or forms contained in web as Data Subject, in addition to abovementioned personal data and personal data processing purposes, name-last name information, phone number information, electronic mail address information, request contents (only processed at write to us form) is processed.

In addition to this, if the event you fill out web membership form; date of birth information, gender information, driver’s license information (license no., license class, license issue place, license issue date) gender information, T.R. ID no., credit card and findeks information during your reservation transactions are processed.

In the event you fill out dealership application form as Data Subject; firm owner or officer name-last name information, phone number information, electronic mail address information is processed.

Also permisison information is processed in case of Data Subjects who give permisson for commercial electronic communication. Processing all such information, it is processed within purposes of fulfilling statutory obligations in compliance with general principles envisaged at the Law, ensuring organisation and event management, execution of merchandise/service sales and after-sales processes, marketing processes of products/services and execution of processes of communication activity. Further, in the event you receive car rental service from the company or its authorized dealers, your personal data may be processed and stored if it is considered that as a result of adverse incidents arising during rental (like fraud, misappropriation, theft, smuggling, drunk driving, letting another person to drive) this may constitute a risk with respect to future rentals.

Detailed information regarding purposes of processing your personal data by the Company are contained at Çelik Motor Ticaret Anonim Şirketi Policy for Protecting and Processing Personal Data which may be accessed at htt.

3. PARTIES TO WHOM YOUR PERSONAL DATA ARE TRANSFERRED AND PURPOSES OF TRANSFER

Your personal data processed, in conformity with general principles provided by the Law and under personal data processing terms indicated at articles 8 and 9 of the Law may be transferred to Company business partners (business party that provides call center service, business partner that conducts satisfaction survey, business partners that provide software and information technology services, third parties from whom service is received by the Company concerning marketing and customer relations management activities and other business partners from whom we may receive service under process), Companies of Anadolu Group, Company shareholders and subsidiaries, Company authorized dealers that conclude authorized dealer contracts with the Company, state institutions and organizations that are legally authorized, administrative authorities, persons and organizations allowed by legislation in force limited to purposes of ensuring management of organisation and event carried out by the Company, executing operations in compliance with legislation, execution of marketing analysis work processes, merchandise/service sale and after-sale support processes, product/service marketing processes, communication activity processes and information security processes. Further, they are transferred to Police Department, to be valid for car renting Data Subjects. In the event Data Subject gives commercial electronic permission, their information will be transferred to İYS A.Ş. as limited.

4. METHOD OF COLLECTING YOUR PERSONAL DATA AND LEGAL REASON

Your personal data may be obtained by the Company under the above-mentioned purposes and by means of automated ways in whole or in part, or by means of non-automated methods provided being a part of data recording system. Accordingly, they may be collected in the event of usage of web via internet, cookies, online web forms in electronic medium (new member form, travel agents form, corporate rent a car form, dealership application form, write to us form).

Your processed personal data may be processed and transferred for purposes specified in this present Clarification Text under personal data processing terms based on articles 5 and 6 of the Law and in addition to this legal reasons details of which are specified below.

In the event of only gaining access to web as a Data Subject,

Pursuant to article 5/2-b of the Law, expressly provided by laws (Law on Regulation of Publications on the Internet and Suppression of Crimes Committed by means of such Publications no. 5651,),
Pursuant to article 5/2-ç of the Law, being obligatory so that data controller is able to fulfill his legal obligation (Law on Regulation of Publications on the Internet and Suppression of Crimes Committed by means of such Publications no. 5651, Law on the Regulation of Electronic Commerce no. 6563, Regulation About Commercial Communication and Commercial Electronic Messages and Applicable Legislation,),
Pursuant to article 5/2-f, legitimate interest of data controller,

In the event of gaining access to web as data subject and variable depending on quality of form you fill out and although in addition to abovementioned legal reasons,

Pursuant to article 5/1 of the Law, existence of express consent in cases when data Subject gives express consent,
Pursuant to article 5/2-c of the Law, provided being directly related to entering into or performance of a contract, processing personal data of contracting parties is necessary,
Pursuant to article 5/2-b of the Law, being expressly envisaged at laws (The Identity Notification Law no. 1774 to be valid for Data Subjects who rent a car),
Pursuant to article 5/2-d of the Law, made available to general public by Data Subject.

5. YOUR RIGHTS AS DATA SUBJECT LISTED AT ARTICLE 11 OF THE LAW

We do hereby inform that as Data Subject you have the following rights as per article 11 of the Law:

Learning whether your personal data are processed, if processed, requesting information regarding this,
Learning purpose of processing your personal data and whether these are used in conformity with intended purpose,
Knowing third parties to whom your personal data are transferred at home or abroad,
In case your personal data are processed incomplete or wrong, asking rectification of this and asking notification of transaction performed in this scope to third parties to whom your personal data are transferred,
In spite of processing in accordance with the Law and provisions of other applicable laws, in case reasons requiring processing disappear, asking deletion or destruction of personal data and asking notification of transaction performed in this scope to third parties to whom your personal data are transferred,
If any result arises against you when data processed are analyzed exclusively through automated systems, objecting to this,
Requesting restitution in case you incur loss because of procession of your personal data unlawfully.

You may submit your applications regarding your above listed rights to the Company by filling out Çelik Motor Ticaret Anonim Şirketi Data Subject Application Form which you may access from http://images.garenta.com.tr/Garenta-Veri-Sahibi-Basvuru-Formu.pdf. According to quality of your request, your applications will be brought to a conclusion as soon as possible and within no later than thirty days free of charge, however if transaction requires any separate cost, you may be charged according to tariff to be designated by Personal Data Protection Board.