Personal Data Protection Law

Dear Customers;

This clarification text has been prepared by RS Holding Anonim Şirketi, acting as the data controller, within the framework of Article 10 of the Law on the Protection of Personal Data No. 6698 (“KVKK”) and the Communiqué on the Principles and Procedures to be Followed in Fulfillment of the Obligation to Inform, in order to inform you, our real person customers and/or the officials and employees of our legal person customers, regarding the purposes of processing your personal data, legal grounds, collection methods, to whom it may be transferred, and your rights under the KVKK.

Which Personal Data Do We Process?
Data Categories

For What Purposes Do We Process Your Personal Data?
Your Personal Data listed above is processed for the following purposes;

• To present our products and services to you,
• To conduct communication activities with you,
• To carry out after-sales support services for goods/services,
• To conduct customer relations and satisfaction management processes and activities aimed at customer satisfaction,
• To follow up on your requests and/or complaints,
• To carry out risk management processes,
• To conduct contract processes,
• To ensure that necessary work is carried out by our relevant business units for the realization of commercial activities and to conduct related business processes,
• To plan and implement commercial and/or business strategies, and to carry out finance and accounting works,
• To ensure the safety of our company and physical space security, and to provide administrative and technical measures related to these,
• To conduct advertising, campaign, and promotion processes regarding our products/services and to send commercial electronic messages,
• To confirm your identity information and documents when necessary; to take necessary actions for the prevention of abuse, loss, and fraud,
• To ensure the safety of our customers, prevent unauthorized entries, increase the process tracking and operational efficiency of our services by determining customer vehicle entry-exit times, and to create records that will constitute proof and evidence in legal disputes that may occur (e.g., theft, accidents, or damage situations),
• To preserve your information that must be kept pursuant to relevant legislation; to carry out copying and backing up processes to prevent information loss; to ensure the control of the consistency of your information, and to take necessary technical and administrative measures for the security of your information,
• To fulfill our legal obligations required or mandated by legal regulations to regulatory and supervisory institutions, and to conduct legal follow-ups and legal processes.

In addition to the purposes above, your vehicle license plate information will be processed automatically via the license plate recognition system based on the legitimate interest of the data controller, for the purposes of confirming your identity information and documents when necessary due to the necessity of data processing; taking necessary actions to prevent abuse, loss, and fraud; ensuring the safety of our customers; preventing unauthorized entries; increasing the process tracking and operational efficiency of our services by determining customer vehicle entry-exit times; and creating records that will constitute proof and evidence in legal disputes that may occur (e.g., theft, accidents, or damage situations).

3. To Whom and For What Purposes Do We Transfer Your Personal Data?

Your data may be transferred to prosecutor’s offices, courts, and relevant public officials upon request and as required by legislation regarding matters of public security and legal disputes that may arise; and when necessary, within the scope of the purposes stated above, to authorized public institutions and organizations, law firms we contract with for the follow-up of legal processes, financial advisors, banks, our group companies for the management of our company and confirmation of our compliance with group company rules and policies, to our group companies upon your request so that you can benefit from their products and services, to cargo companies so that we can send documents and products, to audit firms for the auditing of our business activities, and to companies from which we receive customer relationship management system and accounting support to carry out accounting works.

4. What are the Methods of Collecting Your Personal Data and the Legal Grounds for These?

Your personal data is processed by automatic means (license plate recognition system, etc.) or by non-automatic means (e-mail, paper environment, forms, telephone, etc.) provided that it is part of any data recording system. Your personal data specified above will be processed based on the legal grounds specified in Articles 5 and 6 of Law No. 6698: (i) it is expressly provided for by the laws, (ii) it is mandatory for the data controller to fulfill its legal obligation, (iii) it is necessary to process the personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract, (iv) it is mandatory for the legitimate interests of the data controller, provided that it does not violate the fundamental rights and freedoms of the data subject.

(v) Your identity and communication data will be processed based on your explicit consent for the purposes of advertising, campaigning, promotion, and sending commercial electronic messages to you.

5. Do We Transfer Your Personal Data Abroad?

We do not transfer your personal data abroad.

Within the scope of the purposes specified in this Clarification Text and in accordance with the General Principles listed in Article 4 of the Law; your data will be processed, recorded, stored, preserved, classified, and transferred to the places specified above when necessary, by automatic means (license plate recognition system, etc.) or by non-automatic means (e-mail, paper environment, forms, telephone, etc.) provided that it is part of any data recording system, in a manner that is:

• In conformity with the law and good faith,
• Accurate and when necessary, up to date,
• For specific, explicit, and legitimate purposes,
• Connected, limited, and measured with the purpose for which they are processed,
• To be retained for the period stipulated by relevant legislation or required for the purpose for which they are processed.

6. What Are Your Rights Regarding the Processing of Personal Data and How Can You Access These Rights?

Article 20 of the Constitution states that everyone has the right to be informed about personal data concerning themselves. Article 11 of the KVKK lists the rights of the personal data owner within the scope of the law.

You can submit your requests regarding your rights under the KVKK to RS Holding Anonim Şirketi in writing according to Article 5 of the “Communiqué on the Principles and Procedures for the Request to Data Controller” or by using a registered electronic mail (KEP) address, secure electronic signature, mobile signature, or the electronic mail address previously notified to the data controller by the data subject and registered in the data controller’s system.

Data Controller: RS Holding Anonim Şirketi
Address: Cevizli Mahallesi Tugay Yolu Cd. No:59 Maltepe/İstanbul
E-mail: kvkk@rsotomotivgrubu.com