Cookie Policy

Cookie Policy

Temsa Skoda Sabancı Ulaşım Araçları A.Ş. (“Temsa” or “Company”) attributes great importance to the secure and transparent processing of your personal data in conformity with the law and good faith. This Cookie Policy (“Policy”) is prepared for general principles for the processing of personal data by Temsa, the purposes for which your personal data is processed and the rights that you have concerning your personal data within the scope of our cookie usage activity.

This Cookie Policy does not cover the information collected by applications, third-party websites, web applications and platforms outside the control of our Company. Our Company is not responsible for the actions taken regarding the personal data collected, stored and used by third parties through their own websites.

General Information

While, being an entity located in the Republic of Turkey, Temsa shall comply with the provisions of the Law No. 6698 on the Protection of Personal Data (“Law”), the European General Data Protection Regulation (“GDPR”) as far as these laws apply for the processing of personal data by Temsa.

1. Data controller

The person responsible for processing your data is:

Temsa Skoda Sabancı Ulaşım Araçları A.Ş

Sarıhamzalı Mahallesi Turhan Cemal Beriker Blv. No: 563 /1 Seyhan/Adana/Türkiye

In its capacity as data controller, Temsa is your contact for any questions relating to this Privacy Notice and the data processing described herein.

You can contact us by e-mail at kvk@temsa.com. 

What Are Cookies?

Like most websites, we use cookies to provide you with a better, faster and safer experience. Cookies are small text files that are placed on your computer by the websites you visit. Cookies may be stored on your device through your browser during your first visit to a website. Web traffic is analysed through cookies and your web sites/applications may be personalized according to your preferences.

What Is Personal Data?

“Personal Data” means any information relating to an identified or identifiable individual (a data subject) in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

Which Personal Data We Collect and For Which Purposes Is Your Personal Data Processed?

Your personal data is processed in a limited and measured manner in connection with the following processing purposes in line with the cookies used on Temsa’s https://temsa.com/en website.

Cookies and Purposes

Browser  device type and operating system, router (from which site you came from), IP address, date and time of your visit, interaction status (e.g. whether you can access the site or receive an error warning, link accessed), the use of the features on the site, the search phrases you enter, the frequency of visits, the time you spend on the page, your regional settings, your geographic location, your search keywords, your language preferences, page scrolling movements, user transaction information regarding the tabs you access and marketing data are processed through cookies for the purposes listed in the cookie tables below.

There are first-party and third-party cookies that we use on our web site. There are also session cookies and persistent cookies by lifespan. Session cookies are deleted when you leave the website. Persistent cookies continue to remain on your devices after you leave. Temsa uses both session cookies and persistent cookies on its website.  Lastly, according to their usage purposes, cookies can be examined as (i) strictly necessary cookies, (ii) functional cookies, (iii) performance / analytics cookies and (iv) advertising / marketing cookies. Our website only uses (i) strictly necessary cookies, (ii) performance / analytics cookies and (iii) advertising / marketing cookies.

Below, you will find a detailed explanation with regard to your personal data processed through these cookies and their processing purposes.

Strictly Necessary Cookies

The most important cookies are strictly necessary cookies. Strictly necessary cookies enable you to browse Temsa's website, set your privacy preferences, and fill out request forms. These cookies are essential for performing the basic functions necessary for the operation of our website and platforms, ensuring the security of our website, platforms, and visitors, fulfilling our legal obligations, and exercising our rights under applicable legislation, and cannot be disabled. These cookies are used by Temsa.

Performance / Analytics Cookies

Performance/analytics cookies are used on Temsa’s website to identify what is or is not functioning properly, optimize and improve the website, monitor and measure website visits and traffic information, assess the use of the website and the features and areas available on it, introduce new features, ensure that the website remains relevant and fit for its intended purposes for you, adjust performance settings on the website, and detect potential issues on the site. These cookies are used by third-party service providers based on your explicit consent. If you do not allow these, you will not be able to use the relevant functions.

Advertising / Marketing Cookies

Advertising / marketing cookies are used to promote and advertise our products and services on Temsa’s website, to present you with personalized advertisements, to analyse and improve your advertising and promotional activities, to calculate your product purchasing tendencies, to plan activities to increase your loyalty to products and services, and to carry out marketing activities. These cookies are used by third-party service providers based on your explicit consent. If you do not allow these, you will not be able to use the relevant functions.

The cookie name and category used on our website, the duration of the cookie and the descriptions on the basis of the relevant cookie are given below in more detail:

Apart from the above processing purposes, all your personal data collected through cookies can also be processed for the following purposes:

• For the purposes of improving user experience; monitoring and tracking errors, issues and malfunctions in the operation of our Company’s website; and, where necessary, intervening to address and remedy such errors or malfunctions,
• Carrying out the storage activities of the personal data collected regarding the above-mentioned activities within the scope of the execution of these processes,
• Conducting information security processes in environments where personal data collected within the scope of the above-mentioned activities are stored,
• Carrying out all the above-mentioned activities in accordance with the current legislation, informing legally authorized institutions and organizations, following up the legal affairs and exercising our right of defence when necessary.

How Do We Collect Personal Data?

Your personal data processed for the abovementioned purposes is obtained completely or partially automatically, electronically, through Temsa’s website, your browsers, our third-party advertising partners.

Who May Access Your Personal Data?

Your personal data will not be shared with third parties without your explicit consent, except as stipulated in the legislation or specified in this Policy.

As mentioned above, your personal data is also collected through third-party cookies and transferred to third-party companies based abroad that manage the aforementioned cookies for the purposes stated above.

Temsa may transfer your personal data to the legally authorized private individuals and organizations and public institutions including relevant ministries, courts and enforcement offices for the purposes of carrying out all the above-mentioned activities in accordance with the current legislation, informing legally authorized institutions and organizations, following up the legal affairs and exercising our right of defence when necessary.

Legal Basis for Processing Personal Data

Your personal data collected through strictly necessary cookies is processed within the scope of Article 6 of the GDPR, based on the legal reason of “existence of legitimate interest”, “performance of a contract”, and “compliance with our legal obligations”.

Your personal data collected through performance / analytic cookies and advertising / marketing cookies are processed based on the legal reason of "existence of your explicit consent" within the scope of Article 6 of the GDPR.

Your personal data is processed based on the legal reasons of “fulfilment of our legal obligations” and “establishment, exercise or protection of a right” for the purposes of carrying out the above-mentioned activities in accordance with the current legislation, informing legally authorized institutions and organizations, following legal affairs and exercising our right to defence when necessary and transferred to the persons and organizations mentioned above.

Safety measures implemented by TEMSA

TEMSA implements all organisational and technical measures to ensure an appropriate level of security for your personal data, and in particular to prevent any loss of confidentiality, integrity or accessibility of your data.

How Can You Block/Reject/Manage Cookies?

Any consent is provided freely. If you give your consent, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. After your withdrawal we will stop processing your Personal Data, including storage, unless further data processing is legally permitted.

You may click the "Manage Cookie Settings" button to partially or completely disable the cookies on our website.

You may find instructions on how to allow, block, or delete third-party cookies used on our website in the explanations provided on the third party's own website.

In addition, you may also partially control this through your browser settings. You may access information about managing cookies in commonly used browsers via the links below:

- Google Chrome:

https://support.google.com/accounts/answer/61416?hl=tr&sjid=13511582565833483627-EU

- Mozilla Firefox:

https://support.mozilla.org/tr/kb/masaustu-firefox-surumunde-gelismis-izlenme-koruma-

Safari:

https://help.apple.com/safari/mac/9.0/#/sfri40732

- Opera:

https://help.opera.com/en/latest/web-preferences/ 

Rights of the person concerned

You have the following rights in relation to the processing of your personal data, which you may exercise by contacting TEMSA.

• A right of access

You have the right to ask us for a copy of the personal data we hold about you in a readable and comprehensible format, as well as a copy of this Privacy Notice on a durable medium.

• A right of rectification

You have the right to obtain rectification of the data concerning you, to correct it, to complete it or to update it, should it appear to you to be inaccurate, incomplete or obsolete.

If this is the case, we would be grateful if you could provide us, as far as possible, with the new information we need to make the requested corrections, additions or updates.

If you exercise this right, we undertake to communicate any corrections to all recipients of your data as far as possible.

• A right to erasure

You may request the deletion of all or part of the data we hold about you if at least one of the following conditions is met:

• You have withdrawn your consent to the processing (in the case of the newsletter), and would also like TEMSA to proceed with the destruction of the data concerned.
• You have objected to the continuation of this processing in accordance with the above, and also wish TEMSA to proceed with the destruction of the data concerned.
• The data concerned no longer appears necessary for any of the purposes set out above.
• You consider that TEMSA has collected and/or processed the data concerned in a manner contrary to the law.
• The deletion of the data concerned is required by law.
• The data concerned relates to a person who was under the age of fifteen (15) when the data was collected.

This right is not absolute and TEMSA is entitled to object to the deletion of certain data for legal or legitimate reasons, where their retention is necessary for particularly important reasons, such as the protection and defence of its interests in legal proceedings.

TEMSA may also choose, as an alternative to deleting data, to make it completely and irreversibly anonymous. In this way, we will be entitled to keep this data in a format that no longer allows you to be identified (for example, for statistical purposes).

• A right to object to processing

You have the right to object at any time to the processing of your data for processing based on our legitimate interest, a mission of public interest.

In other words, you may ask TEMSA to cease any or all of these processing operations in relation to you, setting out the specific reasons which justify this request from your point of view.

However, this right is not absolute and TEMSA may for legal or legitimate reasons refuse your request to object, for example if the continued processing is necessary for compelling reasons (for example: if the data concerned is necessary for the protection and defence of TEMSA's rights in a court of law).

Objection (if it is based on valid reasons and there are no compelling reasons against it) will result in the cessation of processing for the future, but not necessarily in the destruction of the data concerned: to obtain this destruction you must exercise your right to erasure under the conditions described above.

• The right to restrict processing

You have the right to obtain the limitation of the processing of your data, i.e. TEMSA will be able to keep this data separately, without using it any more (except legal obligations).

You can make such a request if at least one of the following conditions is met:

• The data concerned seems inaccurate to you, and you would like TEMSA to stop using it while you check it and rectify it if necessary.
• You have exercised your right to object as set out above, and you would like TEMSA to stop using the data concerned for the time needed to check that your objection is well-founded.
• You consider that TEMSA has collected and/or processed the data concerned in a manner contrary to the law, but nevertheless prefer that we retain the data rather than delete it.
• The data concerned is no longer required for any of the purposes set out above, but you wish TEMSA to retain it for the purposes of defending your interests in court.

In such cases, we will isolate the data subject to a request for restriction for the necessary period, for example by means of a "Do not use - Right to restriction" mark.

• A right to data portability

You have the right to ask us for and receive the data you have provided in a structured, commonly used and machine-readable format, for your personal use or to pass it on to a third party of your choice.

This right only applies where the processing of your data is based on your consent, on a contract or is carried out by automated means.

This right to portability differs from the right of access in that its aim is not to obtain a copy that you can necessarily read yourself, but rather a copy of the data that can be re-used, particularly with a view to changing service providers.

However, TEMSA may refuse to exercise this right if it would require technical resources deemed excessive.

• The right to withdraw your consent at any time 

You may withdraw your consent to the processing of your data where the processing is based on your consent. Withdrawal of consent does not affect the lawfulness of processing based on consent carried out prior to such withdrawal.

In the case of newsletter subscriptions, you may withdraw your consent at any time, without having to provide any justification.

• The right to give instructions concerning the fate of your data after your death

You have the right to tell us how you would like us to deal with your data in the unfortunate event of your death.

• In particular, you may ask us to destroy all your data (subject to any overriding conservation requirements we may have, for example to defend TEMSA's rights in court), or to send a copy of all this data to a person of your choice.
• You may also designate any person of your choice to be responsible for carrying out these "last wishes"; this person does not necessarily have to be one of your heirs or even the executor of your estate. 

TEMSA will respond to any exercise of rights as soon as possible and in any event within 30 days of receipt of the request.

TEMSA reserves the right to:

• Ask for proof of the applicant's identity if there is reasonable doubt about it, in order to respect the applicant's duty of confidentiality;
• Extend the deadline for a response by two months, informing the applicant of the extension and the reasons for the postponement within one month of receipt of the request;
• To refuse to respond to an exercise of rights if this is considered abusive (in view of their number, repetitive or systematic nature).

Summary table

How to exercise your rights regarding your personal data:

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