Protection of Personal Data

PROTECTION OF PERSONAL DATA

Protection of Personal Data

Our company has the title of "Data Controller" in accordance with the "Law on the Protection of Personal Data" numbered 6998 published in the Official Gazette dated 07.04.2016. Rentor Vehicle Rental Trade Inc. (hereinafter referred to as "Rentor Filo"), we show maximum sensitivity to the security of your personal data. With this awareness, we attach great importance to the processing and preservation of all kinds of personal data belonging to all persons related to the Company, including those who benefit from our products and services, in accordance with the Law on the Protection of Personal Data No. 6698. With the full understanding of this responsibility, we process your personal data as described in the KVK Law as "Data Controller", as explained and within the limits determined by the legislation.

 

Definitions

Text: This refers to the lighting text.

Data: Refers to information stored electronically on a computer or some paper-based filing system.

Personal Data: It means all kinds of information related to an identified or identifiable natural person. The Company, through websites, in order to understand customer preferences and provide better service and for similar purposes, collects data, generally called "web registration information" (for users' internet browsers, mobile devices, operating system, the pages they visit, the other internet pages they access these pages, information about the date and time he visited the relevant website, the 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, if the data is processed together and if they point to a specific person.

Special Quality / Sensitive Personal Data: Race, ethnic origin, political opinions, philosophical belief, religion, sect or other beliefs, clothing, association, foundation or union membership, health, sexual life, criminal conviction and security measures, and biometric data represents the relevant 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: Includes all natural persons, including employees, whose personal data are processed by Rentor Filo. The data subject does not have to be a Turkish citizen or residing in Turkey. All data owners have legal rights regarding their personal data.

Data Controller: 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 persons have responsibilities to set practices and principles in accordance with the Law. The data controller for all personal data used in Rentor Filo's business processes is the relevant Rentor Filo.

Data Processor: Any person who processes data on behalf of and under the authority granted by a data controller. Employees of the data controller are excluded from this definition, but if applicable, suppliers, business partners and other third parties that process personal data on behalf of Rentor Filo can be included in this definition.

Data Processing / Processing: It covers all kinds of activities related to data usage. It includes obtaining, recording or keeping the data, or any or a set of operations carried out on the data, including editing, changing, retrieving, using, disclosing, deleting or destroying the data. Transferring data to third parties also means processing the data.

Method

As Rentor Filo, 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; Your personal and/or sensitive personal data, which we obtain with your consent, can be obtained, recorded, stored, stored, changed, updated, periodically checked, rearranged, classified, in whole or in part, for the period required for the purpose for which they are processed or stipulated in the relevant law. can be kept, in case of legal or service-related actual requirements, with private-legal persons with whom Rentor Filo works, or with public institutions and organizations for which it is legally liable, and/or relevant third-party real persons/legal persons residing in Turkey or abroad. It can be shared/transferred, transferred abroad in case of legal or service-related actual requirements. For Rentor Filo customers to benefit from our services, to inform you about our campaigns if you approve, to record your suggestions and complaints, to establish better service standards for you, to determine and implement Rentor Filo commercial and business strategies, and in any case, in accordance with the Personal Data Protection Law No. 6698 and the relevant legislation. We inform you that we may process your personal data accordingly.

 

COLLECTION, PROCESSING AND PURPOSE OF PERSONAL DATA

As Rentor Filo, in the capacity of 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, license plate renewal and issuance, traffic consultancy services, second-hand vehicle sales and after-sales services, wholesale spare parts and accessories sales, insurance and the provision of financial services, etc. In order to benefit from our services, to inform you about our campaigns with your approval, to record your suggestions and complaints, to establish better service standards for you, to determine and implement Rentor Filo commercial and business strategies, you can use your personal data verbally, on the website, social media channels, mobile applications and similar purposes. We collect data by verbal, written or electronic means. Personal Data is processed by Rentor Filo in accordance with the procedures and principles stipulated in the Law and this Text. Rentor Filo acts with the following principles when processing Personal Data:

 

- Personal Data is processed in accordance with the relevant legal rules and the requirements of the honesty rule.

- It is ensured that Personal Data is correct and up-to-date. In this context, issues such as determining the sources from which the data is obtained, confirming its accuracy, and evaluating whether it needs to be updated are carefully considered.

- Personal Data; processed for specific, explicit and legitimate purposes. Being legitimate means that the Personal Data processed by Rentor Filo is related to and necessary for the work it has done or the service it has provided.

- Personal Data is related to the realization of the purposes determined by Rentor Filo, 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 only to what is necessary for the realization of the purpose. Personal Data processed in this context are related, limited and measured for the purpose for which they are processed.

- If there is a period foreseen for data storage in the relevant legislation, it complies with these periods; otherwise, it retains the Personal Data only for the period necessary for the purpose for which they are processed. In the event that there is no valid reason for further preservation of Personal Data, the said data is deleted, destroyed or anonymized.

 

Terms of Processing Personal Data

Rentor Filo does not process Personal Data without the explicit consent of the data owner. In the presence of one of the following conditions, Personal Data may be processed without seeking the explicit consent of the data owner.

- Rentor Filo may process Personal Data of Personal Data Owners in cases expressly stipulated by law, even if there is no explicit consent. For example; In accordance with Article 230 of the Tax Procedure Law, the explicit consent of the person concerned will not be sought to include the name of the person on the invoice.

- Personal Data may be processed without explicit consent in order to protect the life or bodily integrity of the person or another person who are unable to express their consent due to actual impossibility or whose consent cannot be validated. For example, in a situation where the person's consent is not valid due to unconsciousness or mental illness, 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, diseases and surgeries, and medications used can be processed through the relevant health system.

- Personal Data of the parties to the contract can be processed, provided that it is directly related to the establishment or performance of a contract by Rentor Filo. For example, according to a contract made, the account number of the creditor can be obtained for the payment of money.

- Rentor Filo may process the Personal Data of Personal Data Owners if it is necessary to fulfill its legal obligations as a data controller.

- Personal Data made public by Rentor Filo by the Personal Data Owners themselves, in other words, disclosed to the public in any way, can be processed because the legal benefit that needs to be protected is no longer valid.

- Rentor Filo may process the 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.

- Rentor Filo may process the Personal Data of the Personal Data Owners in cases where it is necessary to process the Personal Data for their legitimate interests, provided that it does not harm the fundamental rights and freedoms of the Personal Data Owners protected under the Law and Policy. 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 the Personal Data Owners.

 

Conditions of Processing of Special Quality Personal Data

Rentor Filo does not process Sensitive Personal Data without the explicit consent of the person concerned. However, Personal Data other than health and sexual life may be processed without seeking the explicit consent of the person concerned, in cases stipulated by the laws. Personal Data regarding health and sexual life are only processed by Rentor Filo for the purposes of protecting public health, performing preventive medicine, medical diagnosis and treatment and care services, planning and managing health services and financing, without seeking the explicit consent of the person concerned, under the conditions under which we are under the obligation to keep confidential. Rentor Filo carries out the necessary actions to take adequate measures determined by the Board in the processing of Private Personal Data.

CONDITIONS NOT REQUESTING CONSENT IN COLLECTING AND PROCESSING PERSONAL DATA

In accordance with paragraph 2 of Article 5 of the Law on the Protection of Personal Data No. 6698, it is necessary to process the personal data of the parties to the contract, provided that it is clearly stipulated in the laws and is directly related to the establishment or performance of a contract, Rentor Filo fulfills its legal obligation as the data controller. In cases where data processing is mandatory for the establishment, exercise 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 data subject, Rentor Filo has the right to process personal data without express consent. In order to fulfill its legal obligations arising from the legislation to which Rentor Filo is subject, with the Data, which is published or disclosed to the public or in accordance with the principle of openness in the laws, which are included in the official registries or in the balance sheets and annual reports, or which are obliged to disclose in terms of disclosure to the public in accordance with the provisions of the laws and / or legal Data disclosure, use and transfers to be made in order to fulfill the obligation to transfer the Data to persons who may request secrets due to obligations and/or laws, are not subject to the obligation of keeping the secrets of Rentor Filo, and Rentor Filo is not required to disclose such Data to the relevant persons without the need for a separate consent for this Data. is authorized to give, process and transfer.

 

TRANSFER OF PERSONAL DATA AND CONDITIONS

Rentor Filo may transfer the Personal Data of Personal Data Owners and Private 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. Rentor Filo acts in accordance with the regulations stipulated in the Law during the transfer of Personal Data. In this context, Rentor Filo may transfer Personal Data to third parties, based on and limited to one or more of the Personal Data processing conditions listed in Article 5 of the Law, for legitimate and lawful Personal Data processing purposes:

 

If the Personal Data owner has express consent;

If there is a clear regulation in the law regarding the transfer of Personal Data, if it is necessary for the protection of the life or physical integrity of the Personal Data owner or someone else, and

If the Personal Data owner is unable to express his consent due to actual impossibility or if his consent is not legally valid,

If it is necessary to transfer the Personal Data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract,

If Personal Data transfer is necessary for Rentor Filo to fulfill its legal obligation,

If the Personal Data has been made public by the Personal Data owner,

If Personal Data transfer is necessary for the establishment, exercise or protection of a right,

Provided that it does not harm the fundamental rights and freedoms of the Personal Data owner, Rentor Filo may transfer Personal Data if it is necessary for its legitimate interests.

Terms of Transfer of Special Quality Personal Data

Rentor Filo, by showing the necessary care, taking the necessary security measures and taking the adequate measures prescribed by the KVK Board; In accordance with the legitimate and lawful Personal Data processing purposes, it can transfer the Personal Data of the Personal Data Owner to third parties in the following cases. (i) In case of explicit consent of the Personal Data Owner or (ii) In the presence of the following conditions, without seeking the explicit consent of the Personal Data Owner;

 

Sensitive Personal Data (race, ethnicity, political opinion, philosophical belief, religion, sect or other beliefs, dress, association, foundation or union membership, criminal conviction and data related to security measures and biometric and genetic data), in cases stipulated by law,

 

Persons who are under the obligation to keep confidential for the protection of public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing, or by authorized institutions and organizations.

 

Purposes of Processing and Transferring Personal Data

Personal Data; Rentor Filo, in accordance with the law and the purpose of the Law,

Planning and implementing human resources policies in the best way,

Accurate planning, execution and management of commercial partnerships and strategies,

Ensuring the legal, commercial and physical security of itself and its business partners,

Ensuring corporate functioning, planning and execution of management and communication activities,

Making the best use of the products and services of the Personal Data Owners and recommending them by customizing them according to their demands, needs and wishes,

Ensuring the highest level of data security,

Creation of databases,

Improving the services offered on the website and eliminating the errors that occur on the site,

Communicating with Personal Data Owners who forwarded their requests and complaints to him and ensuring the management of requests and complaints,

event management,

Management of relations with business partners or suppliers,

Execution of personnel procurement processes,

Supporting Group Companies' personnel procurement processes and compliance with the relevant legislation,

Planning and execution of audit activities in order to ensure that the activities of the Group Companies are carried out in accordance with the relevant legislation,

Supporting Group Companies in the realization of company and partnership law transactions,

Execution/follow-up of financial reporting and risk management transactions,

Execution/follow-up of company legal affairs,

Carrying out studies to protect its reputation,

Managing investor relations,

Giving information to authorized institutions based on legislation,

Creating and tracking visitor records,

It is processed within the scope of the personal data processing conditions specified in Articles 5 and 6 of the Law, limited to its purposes. If the processing activity carried out for the aforementioned purposes does not meet any of the conditions stipulated under the Law, your express consent is provided by Rentor Filo regarding the relevant processing process.

 

METHOD AND LEGAL REASON FOR COLLECTING PERSONAL DATA, DELETING, DESTROYING, STORAGE PERIOD

Method and Legal Reason for Personal Data Collection

For the purpose of checking the compliance with Article 1, which regulates the purpose of the Law, and Article 2, which regulates the scope of the Law, Personal Data; in all kinds of verbal, written, electronic media; It is collected through technical and other methods, various ways such as call center, Rentor Filo website, mobile application, within the framework of legislation, contract, demand and demand-based legal reasons, in order to fulfill the responsibilities arising from the law in a complete and correct manner, and data processors assigned by the Company or the Company. processed by.

 

Deletion, Destruction or Anonymization of Personal Data

Without prejudice to the provisions in other laws regarding the deletion, destruction or anonymization of Personal Data, although Rentor Filo has processed it in accordance with the provisions of this Law and other laws, in the event that the reasons for its processing are eliminated, the Personal Data ex officio or the data deletes, destroys or anonymizes at the request of the owner. With the deletion of Personal Data, these data are destroyed in such a way that they cannot be used again in any way and cannot be recovered. Accordingly, Personal Data is deleted from the tools such as documents, files, CDs, floppy disks, hard disks in which they are registered, in a way that cannot be recycled. Destruction of Personal Data, on the other hand, means the destruction of materials suitable for data storage such as documents, files, CDs, floppy disks, hard disks, in which the data is recorded, so that the information cannot be retrieved or used again. By anonymizing data, it is meant that Personal Data cannot be associated with an identified or identifiable natural person, even if it is matched with other data.

Retention Period of Personal Data

Rentor Filo keeps Personal Data for the period specified in this legislation, if it is stipulated in the legislation. If a period of time is not regulated in the legislation regarding how long personal data should be kept, the Personal Data is processed for a period of time that requires it to be processed in accordance with the rules of good faith, in accordance with the practices of Rentor Filo and the practices of commercial life, depending on the activity carried out by Rentor Filo while processing that data. destroys or anonymizes. The purpose of processing personal data has ended; if the relevant legislation and the storage periods determined by Rentor Filo have also come to an end; Personal data can only be stored to provide evidence in possible legal disputes or to assert the right related to personal data or to establish a defense. Despite the expiry of the statute of limitations and the statute of limitations for asserting the right mentioned in the establishment of the periods herein, retention periods are determined based on the examples previously submitted to Rentor Filo on the same issues. In this case, the stored personal data is not accessed for any other purpose and access is provided only when it is required to be used in the relevant legal dispute. Here, too, personal data is deleted, destroyed or anonymized after the aforementioned period expires.

 

LIGHTING OBLIGATION

Rentor Filo is obliged to inform the natural persons whose data will be processed during the acquisition of Personal Data. The scope of this notification obligation is as follows:

 

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

- The purpose for which 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 rights for legal reasons.

 

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

- Obtaining Personal Data in Written Form: During the acquisition of Personal Data in written form, Rentor Filo will fulfill its Clarification Obligation regarding the processing of the data, provided that the new relevant forms and information to be revised based on this Text are used. In addition, all forms and contracts, including the Permission Communication Forms to be obtained from the persons with whom customer relations are established, will be revised to show the explicit consent of the Data Subject regarding the processing of Personal Data, although the processing of the relevant data group can be considered as an exception under the Law. In customer relations, new forms, documents and information proving compliance with the Law will be used; all relevant employees will be trained to provide sufficient detailed information to the real person and to show references. Absolutely, it will be ensured that Personal Data is obtained in written forms with informed consent.

- Obtaining Personal Data Verbally: Information will be given regarding the disclosure obligation regarding the processing of Personal Data while obtaining new data in any way or not existing regarding existing customers, which are already processed pursuant to the Permissioned Communication Forms already received, and when obtaining data through the Call Center. During the acquisition of oral data, it will be reminded that the interview was recorded, provided that prior notice is given, and it will be confirmed that the Personal Data will be processed within the scope of this Policy and the existing Permissioned Communication Forms, if any. Employee and Call Center, business processes will be re-evaluated and implemented within this framework.

- Obtaining Personal Data in Electronic Media: All contracts and documents / link addresses / web pages that require the acquisition and processing of Personal Data, including this Clarification Text, including data obtained through electronic commerce channels and other internet channels of Rentor Filo. It has been revised in a way to fulfill the disclosure obligation regarding the processing of Systems that require approval of data processing by Rentor Filo will be established in order to obtain data at every link address that may require data acquisition, which will be available on Rentor Filo's websites, so that this Text can be accessed from all internet pages. Unless it is clearly marked that consent is given to the processing of Personal Data, any information and document entered will not be automatically recorded in any Rentor Filo system and will not be processed in any way.

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