Privacy Notice - PDPL

TEMSA SKODA SABANCI ULAŞIM ARAÇLARI A.Ş.

Privacy Notice Regarding Information and Communication Processes

As Temsa Skoda Sabancı Ulaşım Araçları A.Ş. (“Company” or “Temsa”), we value your privacy and the protection of your personal data. This Privacy Notice Information and Communication Processes (“Privacy Notice”) has been prepared in order to inform our customers, potential customers, and their authorized representatives by Temsa, acting as the data controller pursuant to the Law No. 6698 on the Protection of Personal Data (“PDPL or “KVKK” in Turkish).

Below, you may find explanations regarding the purposes for which your personal data are processed, the manner of such processing, and your rights under the KVKK.

1. Purposes of Processing of Personal Data

Pursuant to Articles 5 and 6 of the KVKK, your personal data are processed in a manner that is relevant, limited, and proportionate to the purposes set out below.

Within the Scope of Information and Communication Processes

Your identity data, contact data, employment/company data, vehicle data, customer transaction data, and/or system security data are processed for the following purposes:

• Responding to, addressing, evaluating, and reporting any requests, complaints, questions, demands, and opinions regarding our Company and our products and services,
• Sending information and explanations regarding our Company and our products and services to the contact details you have provided, and carrying out communication activities with you in this context,
• Carrying out sales and after-sales service processes for goods and services,
• Conducting authorized dealer and authorized service processes,
• Planning product and service development activities and carrying out quality, efficiency, analysis, and improvement efforts relating to our products and services,
• Performing evaluation, analysis, and risk management activities within legal limits and ensuring business continuity,
• Improving and developing the services offered by our Company and determining and implementing commercial and business strategies,
• Ensuring the legal and commercial security of our Company, our products and services, and persons having a business relationship with our Company,
• Planning and monitoring activities carried out with business partners, dealers, or suppliers,
• Carrying out data retention activities within the scope of the execution of the above-mentioned processes,
• Conducting information security processes for the environments in which personal data collected within the scope of the above-mentioned activities are stored,
• Ensuring that all of the above-mentioned activities are carried out in compliance with applicable legislation,
• Providing information to legally authorized public institutions and organizations, conducting legal affairs, and exercising our right of defense where necessary.

Within the Scope of Marketing Activities

Your identity data, contact data, employment/company data, vehicle data, financial data, marketing data, customer transaction data, and/or system security data are processed for the following purposes:

• Sending commercial electronic communications through the communication channels for which you have provided consent,
• Planning and executing discounts, campaigns, advertisements, promotions, and other marketing advantages within the scope of marketing activities carried out by our Company, as well as conducting market research and analysis activities,
• Planning and organizing activities and loyalty programs aimed at ensuring and/or increasing customer satisfaction and loyalty to products and services,
• Conducting surveys within the scope of marketing activities,
• Controlling and analysing customer data in order to carry out employee performance evaluation processes and/or to plan and monitor business activities,
• Personalizing products and services according to customers’ preferences, interests, usage habits, and needs, and carrying out segmentation/profiling activities,
• Planning and organizing events, fairs, and organizations for customers,
• Carrying out data retention activities within the scope of the execution of the above-mentioned processes,
• Conducting information security processes for the environments in which personal data collected within the scope of the above-mentioned activities are stored,
• Ensuring that all of the above-mentioned activities are carried out in compliance with applicable legislation,
• Providing information to legally authorized public institutions and organizations, conducting legal affairs, and exercising our right of defense where necessary.

2. Third Parties to Whom Personal Data May Be Transferred

All personal data obtained in the manner described in this Privacy Notice may be transferred to the following persons and entities within the scope of the personal data processing conditions set out in Articles 8 and 9 of the KVKK:

• Your personal data specified above may be transferred to the relevant affiliates of Temsa Skoda Sabancı Ulaşım Araçları A.Ş. for the purposes of carrying out information and communication processes and marketing activities (where the execution of the relevant processes depends on such parties or requires their involvement).
• Your personal data specified above may be transferred to our domestic (in Türkiye) and foreign (outside of the Türkiye) business partners and suppliers for the purposes of carrying out data retention activities and obtaining technical infrastructure services within the scope of information and communication processes and marketing activities.
• Your personal data specified above may be transferred to our authorized dealers and authorized service providers for the purpose of managing your requests and complaints within the scope of information and communication processes.
• Your personal data specified above may be transferred to supplier companies providing call center services for the purpose of managing your requests and complaints within the scope of information and communication processes and contacting you in this context.
• Your personal data may be transferred to our business partners and suppliers located domestically or abroad for the purposes of carrying out marketing activities, data retention activities within this scope, and obtaining technical infrastructure services (including advertising agencies for sending commercial communications via SMS, e-mail, or telephone and creating campaigns; market research and survey companies; companies providing CRM and software support; and consultancy agencies conducting user behaviour analysis and SEO activities).
• Your personal data specified above may be transferred to legally authorized private persons and entities and legally authorized public institutions and organizations, including relevant ministries, courts, and enforcement offices, for the purposes of carrying out activities in compliance with applicable legislation, providing information to legally authorized institutions and organizations, conducting legal affairs, and exercising our right of defense where necessary.

3. Method and Legal Basis by Which Personal Data is Processed

Your personal data specified above are obtained through the following methods: (i) by being provided by you verbally and/or in writing, in physical and/or electronic environments; (ii) by filling out forms available on our Company’s website and/or by using the Connect Digital Assistant; (iii) through our Company’s authorized services and authorized dealers via physical and/or digital environments (such as the CRM System); (iv) by filling out forms available on our Company’s social media accounts and/or on search engines and social media platforms; (v) through telephone and call center communications with our Company, as well as via SMS, e-mail, and other communication channels and/or by being provided by you personally during such communications; and (vi) during events organized by or attended by our Company.

Personal data collected by our Company through the purposes and methods described above may be processed and transferred pursuant to Articles 5 and 6 of the KVKK based on the following legal grounds:

• Personal data obtained within the scope of information and communication processes and specified above are processed and transferred to the persons and entities listed above based on the legal grounds of “establishment or performance of a contract,” “explicitly provided for by law,” “fulfillment of our legal obligations,” and “legitimate interest.”
• Your personal data specified above may be transferred to our suppliers located outside of Türkiye and stored within their organizations, within the scope of appropriate safeguards provided under the KVKK, for the purposes of carrying out data retention activities and obtaining technical infrastructure services within the scope of information and communication processes and marketing activities, based on the legal ground of “legitimate interest.”
• Your personal data specified above are processed and transferred to the persons and entities listed above for the purposes of carrying out marketing activities and sending commercial electronic communications within the scope of communication preferences, based on the legal ground of “explicit consent.”
• Your personal data processed for the purposes of carrying out the above-mentioned activities in compliance with applicable legislation, providing information to legally authorized institutions and organizations, conducting legal affairs, and exercising our right of defense where necessary are processed and transferred to the persons and entities listed above based on the legal grounds of “explicitly provided for by law,” “fulfillment of our legal obligations,” and “establishment, exercise, or protection of a right.

4. Your Rights under the KVKK

Pursuant to Article 11 of the KVKK, by contacting us through the addresses specified below, you have the right to request, with regard to your personal data that you have provided to us:

• a. to learn whether your personal data are processed;
• b. to request information if your personal data have been processed;
• c.  to learn the purpose of processing of your personal data and whether they are used in accordance with such purpose;
• d. to know the third parties to whom your personal data are transferred domestically or abroad;
• e. to request the correction of your personal data if they are processed incompletely or inaccurately;
• f. to request the deletion or destruction of your personal data within the framework of the conditions set forth in Article 7 of the KVKK;
• g. to request notification of the transactions carried out pursuant to subparagraphs (e) and (f) above to third parties to whom your personal data have been transferred;
• h. to object to the occurrence of a result to your detriment arising exclusively from the analysis of your personal data through automated systems;
• i. to claim compensation for damages in the event that you suffer damage due to the unlawful processing of your personal data.

As data subjects, you may submit your requests regarding your rights through the Data Subject Application Form, which has been made publicly available on the website by applying to Temsa.

Temsa shall finalize your requests as a data subject free of charge, as soon as possible and no later than thirty (30) days, depending on the nature of the request. However, if the processing of the request requires an additional cost for our Company, a fee may be charged in accordance with the tariff determined by the Personal Data Protection Authority.

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