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TR

    GARENTA ULAŞIM ÇÖZÜMLERİ A.Ş
    PRIVACY NOTICE ON THE PROTECTION AND PROCESSING OF CUSTOMER PERSONAL DATA


    1. DATA CONTROLLER
    Pursuant to the Law No. 6698 on the Protection of Personal Data (‘Law’), your personal data will be processed by Garenta Ulaşım Çözümleri Anonim Şirketi as the data controller and the Renter, party to the General Terms and Conditions of this Motorised Land Transport Vehicle Rental Contract, whose trade name is specified at the beginning of the contract (‘Company’), within the scope described below.

    The real person whose personal data is processed within the scope of the General Conditions of the Motorized Land Transport Vehicle Hire Agreement (“Agreement”) is the Data Subject.

    Detailed information on the purposes of processing your personal data by the Company is available in the Garenta Ulaşım Çözümleri Anonim Şirketi Personal Data Protection and Processing Policy, which can be accessed at https://www.garenta.com.tr/en/personal-data-protection-policy/.

    2. PURPOSES AND LEGAL GROUNDS FOR PROCESSING PERSONAL DATA
    Your collected personal data may be processed within the scope of the data processing conditions and purposes set out in Articles 5 and 6 of the Law based on the following purposes (“Purposes”) and legal grounds.

    Based on the legal grounds that processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract;
    • Your identity, contact, financial and customer transaction data for the purpose of updating customer data,
    • Your identity, contact, financial and customer transaction data for the purpose of opening rental records in the system and performing invoicing activities related to the rental,
    • Your identity, contact, financial and customer transaction data for the purpose of providing post-rental support services,
    • Your identity, contact, financial, customer transaction and transaction security data in order to provide our services through the Website, 
    • Your identity, contact, financial, customer transaction and transaction security data in order to perform membership creation and closure transactions.

    Based on the legal ground that it is expressly provided by the laws and is necessary for fulfilment of the legal obligation to which the data controller is subject;
    • Your identity, contact, financial, customer transaction, transaction security and request/complaint data in order to fulfil the requests of official authorities,  
    • Your identity, contact, financial, customer transaction, transaction security and request/complaint data in order to provide information to the authorized institutions arising from the legislation,  
    • Your identity, contact, financial, customer transaction, transaction security and request/complaint data in order to ensure compliance with the retention obligations stipulated in the legislation,  
    • Your identity, contact, financial, customer transaction, transaction security and request/complaint data in order to respond to the data subject applications in accordance with the legislation and to carry out the necessary transactions.

    Based on the legal ground that processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject;
    • Your identity, contact, financial and customer transaction data for the purpose of conducting customer relations, 
    • Your identity, contact, financial and customer transaction data for the purpose of tracking financial transactions,
    • Your identity, contact, financial, customer transaction and transaction security data for the purpose of carrying out the necessary work by our business units and carrying out the relevant business processes in order to benefit the data subjects from the products and services offered by our Company, including the rental and marketing activities of our products and services,
    • Your identity, contact, financial and customer transaction data in order to carry out the necessary work by our relevant business units for the realization of the commercial activities carried out by our Company and to carry out the related business processes,
    • Your identity, contact, finance, customer transaction and transaction security data in order to ensure the legal, technical and commercial-business security of our Company and the data subjects who have a business relationship with our Company, 
    • Your identity, contact, finance, customer transaction and transaction security data in order to determine and implement our Company's commercial and business strategies,
    • Your identity, contact and location data for the purpose of location tracking, provided that the vehicle tracking system is available,
    • Your identity, contact and customer transaction data for the purpose of planning organization and event processes,
    • Your identity, contact, customer transaction and transaction security data in order to carry out the necessary work to improve the services offered by our Company,
    • Your identity, contact, customer transaction, transaction security and request and complaint data for the purpose of managing requests and complaints.

    Based on the legal grounds, data processing is necessary for the establishment, exercise or protection of any right; 
    • Your identity, contact, customer transaction and request/complaint data in order to receive, evaluate and finalize your requests and complaints,
    • If applicable, your identity, contact, customer transaction and request/complaint data in order to carry out processes for the resolution of disputes and lawsuits.

    Based on the legal grounds that it is mandatory for the fulfilment of legal obligations in the fields of employment, occupational health and safety, social security, social services and social assistance;
    • Processing your health data through your disability data obtained for the purpose of allocating the vehicle suitable for your needs in case you have a request in this direction.

    Based on your explicit consent; 
    • Carrying out the marketing processes of our Company's products and services of your identity, contact, customer transaction, finance and marketing data, recommending and promoting the products and services offered by our Company, including profiling and analysis activities, to the data subjects by customizing them according to the tastes, usage habits and needs of the data subjects,
    • Sending electronic commercial messages such as advertisements, promotions, etc. to your contact data shared through the preferred communication channel within the scope of your communication consent and processing your identity and contact data for this purpose.

    3. RECIPIENT PARTIES AND PURPOSES FOR TRANSFERRING PERSONAL DATA 
    Your personal data may be transferred, in accordance with the general principles set forth in the Law and within the conditions for the transfer of personal data specified in Articles 8 and 9 of the Law, and limited to the above-mentioned Purposes, within the scope of our legitimate interests, to the Company's business partners (such as the business partner providing call center services, the business partner providing roadside assistance services in case the vehicle receives roadside assistance, the business partner conducting satisfaction surveys, business partners providing software and information technology services, third parties providing services for the Company's marketing and customer relationship management activities, and other business partners from whom services may be obtained within the scope of the process), Anadolu Group Companies, the Company's shareholders and affiliates, the Company's authorized dealers who have entered into an authorized dealership agreement with the Company, within the scope of expressly provided by the laws and is necessary for fulfilment of the legal obligation, to public institutions and organizations explicitly authorized by law and administrative authorities, the General Directorate of Security, persons and organizations permitted by the applicable legislation, within the scope of standard contractual clauses published by the Personal Data Protection Board, to our business partners and suppliers whose servers are located abroad and, based on your explicit consent, to parties providing services for communication and promotional activities.

    4. METHOD FOR THE COLLECTION OF PERSONAL DATA 
    Your personal data may be obtained by the Company within the scope of the Purposes listed above and in whole or in part by automatic means or by non-automatic methods provided that they are part of the data recording system. Accordingly, it may be collected in physical environment through the conclusion of the Agreement and printed forms and in electronic environment through internet, e-mail, online form, SMS verification code, voice recording system.

    5. DATA SUBJECT’S RIGHTS SPECIFIED UNDER ARTICLE 11 OF THE LAW
    We hereby declare that as personal data subjects, you are entitled to the following rights, set forth under Article 11 of the Law: 
    • To learn whether your personal data are being processed, 
    • To request information if your personal data have been processed, 
    • To learn the purpose of the processing of your personal data and whether they have been used accordingly, 
    • To learn which third parties domestic or abroad your personal data has been transferred to, 
    • To request rectification in case your personal data has been processed incompletely or inaccurately and to demand the operations in this regard be reported to third parties your personal data has been transferred to, 
    • To demand the erasure or destruction of your personal data in the event that the reasons for the processing no longer exist even though it was processed in accordance with the Law and other relevant provisions and to demand the operations in this regard be reported to third parties your personal data has been transferred to, 
    • To object to negative consequences to you that are concluded, as a result of analysis of the processed personal data through solely automatic systems, 
    • To demand compensation for the damages that you have suffered as a result of an unlawful processing of your personal data.
    You can submit your applications for your rights listed above to the Company by filling out the Garenta Ulaşım Çözümleri Anonim Şirketi Data Subject Application Form available at http://images.garenta.com.tr/Garenta-Veri-Sahibi-Basvuru-Formu.pdf. Depending on the nature of your request, your applications will be finalized free of charge as soon as possible and within thirty days at the latest; however, if the transaction requires an additional cost, you may be charged a fee according to the tariff to be determined by the Personal Data Protection Board.