Protection of Personal Data

Clarification Text on Protection and Processing of Personal Data

The purpose of this Information on the Protection and Processing of Personal Data (Information) is to fulfill the disclosure obligation imposed by Article 10 of the Law No. 6698 on the Protection of Personal Data (Personal Data Protection Law) regarding the use of personal data obtained and/or received from third parties during the use of the website located at https://elitcarrental.com/, Elitcar Rental Android mobile application and Elitcar Rental iOS mobile application (all will be referred to as “Portal”) managed by Elitcar Turizm Anonim Şirketi (Elitcar). In addition, it is to transparently inform the Users about the collection methods, processing purposes, legal reasons and rights of the personal data collected by Elitcar regarding the use of the Portal by the Users or entered into the Portal by the Users themselves with their positive actions.

An up-to-date environment is offered by Elitcar to potential customers for short-term or fleet rentals. Within this activity, personal data may be processed as stated in this Information text as a requirement for the use of Elitcar functions.

Elitcar constantly renews itself in order to provide better service to its Users in the internet field with innovative product and service applications by investing in technology and works to provide the best service, takes the highest possible security measures to ensure that personal data is collected, stored and shared in accordance with the law and to protect its confidentiality. In order to realize this purpose, the personal data of the Users are processed within the scope and conditions detailed below.

Elitcar may update and change the provisions of this Information at any time by publishing it on the Portal. Updates and changes made by Elitcar shall be effective from the date of publication on the Portal.

A- Data Controller

In accordance with the Law on the Protection of Personal Data, your personal data will be collected and processed by Elitcar as the data controller within the scope described below.

B- Collected Personal Data

Elitcar collects various static (fixed) and dynamic (variable) data from Users through the methods set out below. The data collected by Elitcar depends on the services and features used by the Users.

Under this heading, the data processed within the scope of the Services offered by Elitcar and Personal

Pursuant to the Law on the Protection of Personal Data, the data considered as personal data are listed in groups below. Unless otherwise explicitly stated, the terms “personal data” and “sensitive personal data” within the scope of the terms and conditions provided in this Information include the following information:

Name and Contact Information: Name, surname, mobile phone, home phone, work phone, address, e-mail address, billing information, Turkish ID number (national ID number), ID sample, passport sample, driver's license sample and other similar documents.

Identity Verification Information: Users' membership information, passwords used to authenticate and access the account, Username, contact information, password tips, User numbers, reservation numbers.

Demographic Data: Date of birth, age, gender, preferred language and currency.

Usage Data and Favorites: Data collected from your devices through various software and technological tools, including but not limited to your reasons for calling Elitcar or Call Centers, voice recordings, website usage information, date and time queries, vehicle reviews, reservation data, survey data and error reports during service use.

Location Data: It includes data related to the precise or approximate location of users. Location data extracted from GPS data and IP and port addresses are used when the user uses Elitcar's mobile applications, if permitted during personnel guidance during vehicle delivery.

Payment Data: Customer invoice and payment information (name, surname, billing address, Turkish ID number, tax ID number), invoices sent to the customer and receipt samples of payments received from the customer, payment number, invoice number, invoice amount, invoice cut-off date.

Survey Answers: It includes responses to periodic surveys organized by Elitcar within the Portal, responses to the survey conducted for satisfaction measurement after booking and responses sent for feedback within the Website.

Where is Personal Data Stored and Processed?

Your personal data we obtain may be stored at home or abroad in another country where Elitcar or its affiliates, subsidiaries or service service providers with which it cooperates have facilities and may be processed in line with and proportionate to the purposes in this Information.

Your personal data collected within the scope of this Information will be processed in accordance with the provisions herein and within the scope of the legislation in force in the country where the data is stored and processed and within the prescribed security measures.

C- Purpose of Processing Personal Data

In line with the purposes set out in this Information and the Membership Agreement, your personal data will be processed in accordance with the Principles and Processing Conditions regulated by the Personal Data Protection Law No. 6698 and for the purposes detailed below:

Name and Contact Information: Internal evaluation, communication, user registration, obtaining potential customer information, development of after-sales processes, business development, collection, customer portfolio management, promotion, analysis, complaint management, managing customer satisfaction processes, marketing, advertising, research, invoicing, event information, conducting operational activities, measuring and improving service quality, audit, control, optimization, customer verification, marketing, sales, advertising, after-sales services, detection and prevention of fraud;

Authentication Information: User registration, problem/error notification, control, development and execution of operational activities, development of after-sales processes, business development, collection, internal evaluation, customer portfolio management, measurement of service quality, communication, optimization, audit, risk management, audit, customer verification, fraud detection and prevention;

Demographic Data: Promotion, internal evaluation, analysis, communication, development of after-sales processes, business development, collection, usage data and interests, favorites, marketing, sales, advertising, audit and control, risk management, development of after-sales processes, business development, collection, internal evaluation, customer portfolio management, after-sales services, measurement and development of service quality, communication, complaint management processes, execution and development of operational activities, registration, problem / error reporting;

Usage Data and Favorites: User registration, problem/error notification, control, execution and development of operational activities, after-sales services and development of after-sales processes, business development, collection, internal evaluation, online behavioral advertising and marketing, customer portfolio management, measurement and development of service quality, communication, optimization, audit, risk management and control, promotion, analysis, interest identification, scoring, profiling, marketing, sales, advertising, communication, complaint management processes, registration, problem/error notification;

Location data: Use of location-based or location-related Portal functions, audit and control, risk management;

Payment Data: Managing the billing process, accounting, development of after-sales processes, business development, collection, internal evaluation, scoring, profiling, customer portfolio management, after-sales services, communication, marketing, audit, control, processes carried out with payment service providers;

Survey Responses: Information requested from users who respond to periodic surveys organized by Elitcar within the Portal, direct marketing to these users, statistical analysis, improvement of processes and database creation by third real and legal persons with whom Elitcar cooperates with real and / or legal persons with whom Elitcar cooperates for the use of Portal functions and the fulfillment of these functions by Elitcar and third real and legal persons with whom Elitcar cooperates within the scope of all processing activities mentioned above in accordance with the intended use of the Portal;

Performing the obligations arising from the contracts made by Elitcar with its business partners/customers/suppliers for the realization of legal and commercial obligations within the framework of the contracts made with third real or legal persons who are in a business relationship with Elitcar or the activities carried out and the obligations arising from legal regulations, establishing rights, protecting rights, conducting commercial and legal evaluation processes, conducting legal and commercial risk analysis, conducting legal compliance process, conducting financial affairs, fulfilling legal requirements, fulfilling the decisions of competent institutions, organizations and authorities, responding to their requests, for the purposes of Law No. 6698. and 6. of Law No. 6698 for the purposes of carrying out the legal compliance process, carrying out financial affairs, fulfilling legal requirements, fulfilling the decisions of authorized institutions, organizations and authorities, responding to their requests.

Personal Data Retention Period

Elitcar will retain the personal data it obtains for the period required for the purpose for which they are processed in order for the Users to benefit from the Service in the best way, within the framework of the conditions specified in this Information and the Membership Agreement and in order to fulfill the obligations arising from the nature of the Membership Agreement. In addition, Elitcar may retain personal data in the event of any dispute that may arise from the Membership Agreement, limited to the purpose of conducting administrative or judicial processes within the scope of the dispute and during the statute of limitations determined in accordance with the relevant legislation.

Ç- To Whom and For What Purpose the Processed Personal Data Can Be Transferred

Elitcar may use the personal data belonging to the User and the new data obtained by using this personal data or the personal information that Users enter into the Portal with their positive actions, in particular to fulfill the requirements of the Membership Agreement and the Services, to improve the User experience (including improvement and personalization), to ensure the security of Users, to detect and prevent fraud, to improve the Services, to conduct operational evaluation research, to eliminate errors, to verify User identities, outsourcing service providers, law offices, research companies, call centers, software companies for complaint management and security, agencies, consulting companies, companies in the printing sector, third real and/or legal persons, including social media channels, and authorized institutions, organizations, authorities, administrative and judicial bodies within the scope of legal obligations in order to achieve any of the purposes specified in the processing purposes section above, including improving system performance.

In addition, the User's Name and Contact Information may be shared with payment institutions in order to perform identity verification in accordance with the payment institution framework agreement that the User will approve at the payment stage and in accordance with the Regulation on Measures to Prevent Laundering of Proceeds of Crime and Terrorist Financing published in the Official Gazette dated January 9, 2008 and numbered 26751.

Your personal data obtained through cookies placed on your device may be shared with third parties for the scope and purposes specified in this Information. Elitcar may transfer personal data to third parties within the above-mentioned categories and purposes, limited and proportionate to these purposes, as well as abroad.

D - Method and Legal Reason of Personal Data Collection

Elitcar collects your personal data in order to work more effectively and provide you with the best experience. Your data is collected using the following methods:

Data You Provide Directly to Elitcar: It refers to the personal data provided to Elitcar by the Users on their own initiative for the performance of the Service and before or during the use of the Portal. This personal data includes all personal data provided directly by Users to Elitcar as a result of their positive actions. For example, name-surname, contact information, identity information, answers to surveys, demographic data and content information are included in such data.

Data We Obtain When You Use Our Platform: During the service provided by Elitcar, it includes personal data regarding the usage habits of Users obtained through certain software or technological tools. For example, location data and favorites, as well as interests and usage data are included in such data.

In order to carry out online behavioral advertising and marketing, Elitcar may associate the behavior of the user coming to the site with a cookie in the browser, even if they are not a member, and define remarketing lists based on metrics such as the number of pages viewed, the duration of the visit and the number of target completions.

Your personal data collected by these methods may be processed and transferred for the purposes specified in this Information within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698.

Legal grounds for collecting personal data;

Membership Agreement, Terms of Use and performance of the contract based on them, establishment and protection of the right
Legal regulations governing electronic commerce activities, financial and tax matters, consumer protection and other issues
It is based on Elitcar's legitimate interest in collecting the data necessary for Elitcar to carry out services, especially to prevent fraud, in its activities related to the Portal.

E- Our Measures and Commitments Regarding Data Security

Elitcar is committed to protecting personal data securely. Technical and administrative measures to ensure the appropriate level of security in order to prevent unlawful processing and access to personal data and to ensure the protection of personal data are carried out using various methods and security technologies.

Elitcar will not disclose the personal data it obtains to anyone else in violation of the provisions of this Information and the Law No. 6698 on the Protection of Personal Data and will not use it for purposes other than processing. Elitcar declares that in the event that personal data belonging to Users are shared with outsourcing service providers in accordance with this Information, it will carry out the necessary warning and audit activities in order for such outsourcing suppliers to comply with the commitments under this article.

In case of linking to other applications through the Portal, Elitcar does not bear any responsibility for the privacy policies and contents of the linked applications. The User undertakes that the information subject to this Information is complete, accurate and up-to-date, and in case of any changes in this information, the User undertakes to update them immediately at "Customer Panel". Elitcar shall not have any responsibility in case the User fails to provide updated information.

F- Rights of the Personal Data Owner listed in Article 11 of Law No. 6698

As personal data owners, you can submit your requests regarding your rights by the methods set out below

If you submit your request to Elitcar, Elitcar will finalize the request free of charge as soon as possible and within thirty days at the latest, depending on the nature of the request. No fee will be charged for up to ten pages in the response. A transaction fee of 1 Turkish Lira will be charged for each page over ten pages. If the response to the application is given in a recording medium such as CD, flash memory, the fee that may be requested by Elitcar will not exceed the cost of the recording medium. Bu kapsamda kişisel veri sahipleri;

Learn whether their personal data is being processed,
Request information if their personal data has been processed,
To learn the purpose of processing personal data and whether they are used for their intended purpose,
To know the third parties to whom personal data is transferred domestically or abroad,
To request correction of personal data in case of incomplete or incorrect processing and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,
Although it has been processed in accordance with the provisions of Law No. 6698 and other relevant laws, to request the deletion or destruction of personal data in the event that the reasons requiring its processing disappear and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,
To object to the emergence of a result to the detriment of the person himself/herself by analyzing the processed data exclusively through automated systems,
In case of damage due to unlawful processing of personal data, it has the right to demand the compensation of the damage.

You may submit your request for exercising your rights mentioned above in Turkish; in the capacity of data controller, Elitcar's Yenişehir Mh., Ankara Cd., No 405, Kat 4, Daire: 117 Pendik/Istanbul/Turkey address with documents identifying your identity by hand, through a notary public, by registered e-mail to [email protected] or by other methods determined by the Personal Data Protection Authority.

Elitcar reserves the right to verify your identity before responding.

In your application

Your name, surname and signature if the application is in writing,
For citizens of the Republic of Turkey, your Turkish ID number; if you are a foreigner, your nationality, passport number or ID number, if any,
Your residential or workplace address for notification,
Your e-mail address, telephone and fax numbers, if any,
The subject of your request is mandatory and information and documents related to the subject, if any, must be attached to the application.