ÇELİK MOTOR TİCARET ANONİM ŞİRKETİ

CLARIFICATION TEXT ON THE PROTECTION AND PROCESSING OF PERSONAL DATA

1. DATA CONTROLLER

Your personal data may be processed by Çelik Motor Ticaret Anonim Şirketi in the capacity of data controller as well as by the Lessor (“Company”), who is a party to this present Motor Land Vehicle Leasing Agreement General Conditions and whose commercial title is specified in the beginning of this agreement, in the capacity of data controller in accordance with the Law No. 6698 on Protection of Personal Data (“Law”) within the scope described below.

The real person whose personal data is processed under the Motor Land Vehicle Leasing Agreement General Conditions ("Agreement") is the Data Subject.

2. PURPOSE OF PROCESSING YOUR PERSONAL DATA

In case of conclusion of the Agreement as the Data Subject, the following data are processed in accordance with the general principles provided in the Law: name and surname, T.R. Identity number, address, phone number, signature, information on the leased vehicle, driver’s license and its sample (driver’s license no, class, place of its issuance, date of its receipt and information on driver’s license), identity card information and its sample, location, voice recording, credit cart and findeks information in case of receiving road assistance service or in case it is notified that there is a vehicle tracking device in the vehicle, passport information in case of foreign customers, and also, if permitted, commercial electronic permission.

Processing is performed in order for the activities carried out by the Company be conducted in accordance with the legislation (complying with obligations of official institutions to store, report information and inform and fulfilling the legal obligations), to ensure organization and efficiency management, to conduct good/service sales and after-sales processes, product/service marketing processes and communication activity processes and to carry out analysis works (activities that can be made for enhancement of service and product quality). In addition, in case you receive rent a car service from our company or its authorized dealers, in case of negative incidents arising during the leasing (fraud, abuse of confidence, larceny, smuggling, drink-driving, having the vehicle used by others), your personal data may be processed by and stored in our company if this incident is deemed to be a risk for the future leasing procedures.

Detailed information on the purposes for which your personal data is processed by our Company can be found at Çelik Motor Ticaret Anonim Şirketi Personal Data Protection and Processing Policy that can be accessed from https://www.garenta.com.tr/kvk-politikasi/

3. PARTIES TO WHICH YOUR DATA ARE TRANSMITTED AND PURPOSES OF TRANSMISSION

Your personal data may be transferred to the Company’s business partners (business partner providing call center service, business partner providing road assistance service if the vehicle receives road assistance service, business partner carrying out a satisfaction survey, business partners providing software and information technology services, third parties from whom the company receives services related to marketing and customer relationship management activities, and our other business partners that we can get service within the scope of the process), Anadolu Group Company, Company shareholders and affiliates, Company authorized dealers who have concluded the authorized dealership agreement with the Company, legally authorized public institutions and organizations, administrative authorities, General Directorate of Security, persons and entities permitted by the legislation in force, in accordance with the general principles provided in the Law and under the conditions for personal data processing specified in articles 8 and 9 of the Law, as limited to the purposes of conducting the activities carried out by the Company be conducted in accordance with the legislation, of performing good/service sales and after-sales support processes, communication processes and information security processes, product/service marketing processes, marketing analysis work processes and of ensuring organization and efficiency management. In case the data subject gives commercial electronic consent, his information will be transferred to İYS A.Ş. in a limited manner. 

4. METHOD OF COLLECTING PERSONAL DATA AND LEGAL REASON

Your personal data may be obtained by the Company under the above-mentioned purposes and through fully or partially automatic means or non-automated methods provided that it is part of the data recording system. Accordingly, personal data may be collected with conclusion of Agreement and printed forms physically and through internet, cookies, online form, SMS verification code, voice recording system electronically.

Your personal data processed may be processed and transferred for the purposes stated in this Clarification Text and under the personal data processing conditions based on the legal reasons in Article 5 and 6 of the Law and also whose details are given below.

• Based on article 5/2-b of the Law, it is stipulated explicitly in the laws and it is mandatory for the data controller in order to fulfil his/her legal obligation based on article 5/2- of the Law (Law No. 6563 on the Regulation of Electronic Commerce, Regulation on Commercial Communication and Commercial Electronic Messages and the Relevant Legislation, Law No. 6502 on Consumer Protection, Turkish Commercial Code No. 6102, Tax Procedure Law No. 213, Turkish Code of Obligations No. 6098, Law No. 5651 on Regulation of Publications on the Internet and Suppression of Crimes Committed by Means of Such Publications, The Identity Notification Code No. 1774 in case of renting a car),
• It is mandatory for the legitimate interests of the data controller based on Article 5/2-f of the Law,
• In case of explicit consent in cases where the Data Subject gives his explicit consent based on Article 5/1 of the Law,
• Processing of personal data belonging to the parties to a contract is necessary provided that it is directly related to the conclusion or fulfilment of that contract in accordance with Article 5/2-c of the Law,
• Data concerned is made available to the public by the Data Subject himself based on Article 5/2-d of the Law.

5. YOUR RIGHT SPECIFIED IN ARTICLE 11 OF THE LAW AS OWNER OF PERSONAL DATA

As the Data Subject, we hereby notify that you have the following rights, according to article 11 of the Law:

• To learn whether your personal data are processed or not, and to request information if your personal data are processed,
• To learn the purpose of processing personal data and whether they are used appropriately for their purpose,
• To know the third parties at home or abroad to whom personal data are transferred,
• To request correction of personal data if they are processed incompletely or incorrectly and to request that the process carried out in this context be notified to the third parties to whom personal data is transferred,
• To request that personal data to be deleted or destroyed and to request that third parties be notified of the processing carried out in this context, where the reasons that require the processing of personal data disappear although it has been processed in accordance with the provisions of the Law and other related laws,
• To object to the occurrence of a result against you through analysing the processed data exclusively through automated systems,
• To demand the damage be compensated in the event of a damage due to the processing of your personal data unlawfully.

You can deliver your applications as per your rights stated above by filling  Çelik Motor Ticaret Anonim Şirketi Data Owner Application Form which can be accessed from http://images.garenta.com.tr/Garenta-Veri-Sahibi-Basvuru-Formu.pdf   According to the nature of your request, your requests shall be finalized as soon as possible free of charge; however, in the event the transaction requires a cost, such cost may be charged as per the tariff to be determined by the Personal Data Protection Board.