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Protection of Personal Data

Our company has the title of "Data Controller" in accordance with the "Personal Data Protection Law" No. 6998 published in the Official Gazette dated 07.04.2016. As FERAN CAR RENTAL , we show utmost sensitivity to the security of your personal data. With this awareness, as the Company, we attach great importance to the processing and preservation of all personal data of all persons associated with the Company, including those who benefit from our products and services, in accordance with the Personal Data Protection Law No. 6698. With full understanding of this responsibility, we process your personal data as "Data Controller" as defined in the KVK Law, as explained and within the limits determined by the legislation.

Definitions

Text: This refers to the clarification text.

Data: It refers to information stored electronically on a computer or in some paper-based filing systems.

Personal Data: It refers to any information regarding an identified or identifiable natural person. The Company generally collects "web registration information" through its websites in order to understand customer preferences and provide better service and similar purposes. may collect so-called data (information about users' internet browsers, mobile devices, operating system, the pages they visit, the other websites they access, the date and time they visit the relevant website, the specific pages visited and more) and on the website. If the pages listed are visited, cookies may be used. In this context, if Personal Data is obtained or the data collected in this way are processed together and they point to a specific person, cookies and web registration information will also be subject to this Text.

Special/Sensitive Personal Data: Race, ethnic origin, political opinions, philosophical belief, religion, sect or other beliefs, appearance and association, refers to data regarding foundation or union memberships, health, sexual life, criminal convictions and security measures and biometric data. Sensitive data can only be processed under strict conditions and processing usually requires the explicit consent of the data subject.

Data Subject or Owners: It covers all real persons, including employees, whose Personal Data is processed by  FERAN CAR RENTAL. The data owner does not have to be a Turkish citizen or reside in Turkey. All data subjects have legal rights regarding their personal data.

Data Controller: It refers to the real or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system. These persons have responsibilities to determine practices and principles in accordance with the Law. The data controller for all personal data used in FERAN CAR RENTAL's business processes is the relevant FERAN CAR RENTAL

Data Processor: Any person who processes data on behalf of and based on 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 who process personal data on behalf of FERAN CAR RENTAL may be included in this definition.

Data Processing / Processing: It covers all kinds of activities related to data use. Obtaining, recording or retaining data, or performing any action on data, including organising, modifying, retrieving, using, disclosing, deleting or destroying data. or includes a number of operations. Transferring data to third parties also means processing data.

METHOD

As FERAN CAR RENTAL, as the data controller, we use our call centers, written communication channels, social media pages, mobile communication channels, in-store communication channels and/or all kinds of services, including but not limited to through channels; Your personal and/or special personal data that we have obtained with your consent may be obtained, recorded, retained, stored, changed, updated, periodically checked, rearranged, classified, in whole or in part, for as long as necessary for the purpose for which they are processed or as stipulated in the relevant law. can be kept, in case of legal or service-related actual requirements, with private-legal persons with whom FERAN CAR RENTAL works together or with public institutions and organizations to which it is legally obliged and/or resident in Turkey or abroad. It can be shared/transferred with relevant third party real persons/legal entities, or transferred abroad in case of legal or service-related actual requirements. To enable FERAN CAR RENTAL customers to benefit from our services, to inform you about our campaigns upon your approval, to record your suggestions and complaints, to create better service standards for you, to determine FERAN CAR RENTAL's commercial and business strategies. We would like to inform you that we may process your personal data for purposes such as and implementation, and in any case in accordance with the Personal Data Protection Law No. 6698 and relevant legislation.

COLLECTION, PROCESSING AND PURPOSES OF PERSONAL DATA

As FERAN CAR RENTAL, as data controller, within the framework of our legal obligations arising from the legislation; long and short-term vehicle rental, sale, transfer, registration, loss, license renewal and issuance, license plate renewal and issuance, traffic consultancy services, second-hand vehicle sales and fulfillment of after-sales services, wholesale spare parts and accessories sales, insurance and provision of financial services etc. You may share your personal data verbally, on the website, for purposes such as enabling you to benefit from our services, informing you about our campaigns upon your approval, recording your suggestions and complaints, creating better service standards for you, determining and implementing FERAN CAR RENTAL's commercial and business strategies. We collect data verbally, in writing or electronically through social media channels, mobile applications and similar means. Personal Data is processed by FERAN CAR RENTAL in accordance with the procedures and principles set forth in the Law and this Text. FERAN CAR RENTAL 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 rule of honesty.

- Personal Data is ensured to be accurate 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 taken into account.

- Personal Data; It is processed for specific, clear and legitimate purposes. The legitimacy of the purpose means that the Personal Data processed by FERAN CAR RENTAL is related to and necessary for the work it performs or the service it offers.

- Personal Data is linked to the achievement of the purposes determined by FERAN CAR RENTAL, and the processing of Personal Data that is not related or needed to achieve the purpose is avoided. It limits the data processed only to what is necessary to achieve the purpose. Personal Data processed in this context is related to the purpose for which they are processed, limited and proportionate.

- If there is a period stipulated in the relevant legislation for the storage of data, it complies with these periods; Otherwise, it retains Personal Data only for the period necessary for the purpose for which it is processed. If there is no longer a valid reason to retain Personal Data, the data in question will be deleted, destroyed or anonymized.

Conditions of Processing of Personal Data

FERAN CAR RENTAL does not process Personal Data without the explicit consent of the data owner. If one of the following conditions exists, Personal Data may be processed without the explicit consent of the data owner.

- FERAN CAR RENTAL may process the Personal Data of Personal Data Owners in cases clearly stipulated by law, even without explicit consent. For example; In accordance with Article 230 of the Tax Procedure Law, the express consent of the relevant person will not be required to include the name of the relevant person on the invoice.

- Personal Data may be processed without explicit consent in order to protect the life or physical integrity of individuals 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 Owner's Personal Data may be processed during medical intervention to protect life or physical integrity. In this context, data such as blood type, diseases and surgeries, and medications used can be processed through the relevant health system.

- Personal Data belonging to the parties to the contract may be processed by FERAN CAR RENTAL, provided that it is directly related to the establishment or execution of a contract. For example, in accordance with a contract, the account number of the creditor party may be obtained for the payment of money.

- FERAN CAR RENTAL may process the Personal Data of Personal Data Owners if it is mandatory to fulfill its legal obligations as the data controller.

- Personal Data that has been made public by FERAN CAR RENTAL by the Personal Data Owners themselves, in other words, has been disclosed to the public in any way, It can be processed as the benefit disappears.

- FERAN CAR RENTAL, in cases where data processing is mandatory for the exercise or protection of a legally legitimate right, the Personal Data of Personal Data Owners is processed without seeking explicit consent. It can work.

- FERAN CAR RENTAL processes Personal Data in order to ensure its legitimate interests, provided that it does not harm the fundamental rights and freedoms of Personal Data Owners protected under the Law and Policy. In cases where processing is mandatory, it may process the Personal Data of Personal Data Owners. 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 Personal Data Owners.

Conditions for Processing of Special Personal Data

FERAN CAR RENTAL does not process Special Personal Data without the express consent of the person concerned. However, Personal Data other than health and sexual life may be processed without the explicit consent of the relevant person in cases stipulated by law. Personal Data regarding health and sexual life are processed by FERAN CAR RENTAL only for the purposes of protecting public health, preventive medicine, medical diagnosis and treatment and care services, planning and management of health services and their financing, without the express consent of the relevant person, under conditions where we are under a confidentiality obligation. . FERAN CAR RENTAL carries out the necessary procedures to take adequate measures determined by the Board in the processing of Special Personal Data.

CASES WHERE CONSENT IS NOT REQUIRED IN COLLECTING AND PROCESSING PERSONAL DATA

In accordance with the 2nd paragraph of Article 5 of the Personal Data Protection Law No. 6698, the processing of personal data belonging to the parties to the contract, provided that it is clearly provided for in the law and is directly related to the establishment or execution of a contract. It is necessary, it is mandatory for FERAN CAR RENTAL, as the data controller, to fulfill its legal obligation, it has been made public by the relevant person, data processing is mandatory for the establishment, use or protection of a right, the fundamental rights and fundamental rights of the relevant person. In cases where data processing is necessary for the legitimate interests of the Company, which is the data controller, provided that their freedom is not harmed, FERAN CAR RENTAL has the right to process personal data without obtaining explicit consent. Data published or disclosed to the public, or included in official registry or balance sheets and activity reports in accordance with the principle of openness in the law, or which is obliged to disclose for public disclosure in accordance with the provisions of the law, and legal data arising from the legislation to which FERAN CAR RENTAL is subject. Disclosure, use and transfer of Data to fulfill its obligations and/or due to legal obligations and/or to fulfill the obligation to transfer Data to persons who may request secrets in law are not subject to FERAN CAR RENTAL's obligation to keep confidentiality and this FERAN CAR RENTAL is authorized to disclose, give, process and transfer the Data in question to the relevant persons without the need to obtain a separate consent for the Data.

TRANSFER OF PERSONAL DATA AND ITS CONDITIONS

FERAN CAR RENTALBy creating the necessary confidentiality conditions and taking security measures in line with the purposes of processing Personal Data, the Personal Data of Personal Data Owners and Special Personal Data can be transferred to third parties in accordance with the Law. can be transferred as . FERAN CAR RENTAL acts in accordance with the regulations stipulated in the Law during the transfer of Personal Data. In this context, FERAN CAR RENTAL may transfer Personal Data to third parties based on and limited to one or more of the Personal Data processing conditions specified in Article 5 of the Law, listed below, in line with legitimate and lawful Personal Data processing purposes: Explicit consent of the Personal Data owner. If there is; If there is a clear regulation in the law regarding the transfer of Personal Data, if it is necessary to protect the life or physical integrity of the Personal Data owner or someone else, and if the Personal Data owner is unable to express his/her consent due to actual impossibility or if his/her consent is not given legal validity, being directly related to the establishment or execution of a contract. provided that it is necessary to transfer the Personal Data of the parties to the contract, if the transfer of Personal Data is mandatory for FERAN CAR RENTAL to fulfill its legal obligation, if the Personal Data has been made public by the Personal Data owner, the transfer of Personal Data is the establishment of a right, If it is mandatory for the use or protection of Personal Data, it may transfer Personal Data if it is necessary for the legitimate interests of FERAN CAR RENTAL, provided that it does not harm the fundamental rights and freedoms of the Personal Data owner.

Conditions for Transfer of Special Personal Data

FERAN CAR RENTAL, by showing the necessary care, taking the necessary security measures and taking the adequate measures prescribed by the KVK Board; In line with legitimate and lawful Personal Data processing purposes, the Personal Data Owner's Special Personal Data may be transferred to third parties in the following cases. (i) In case of the express consent of the Personal Data Owner or (ii) Without the express consent of the Personal Data Owner in the presence of the following conditions;

Special Personal Data (race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and data regarding clothing, association, foundation or union membership, criminal convictions and security measures, and biometric and genetic data), in cases stipulated by law,

Special Personal Data regarding the Personal Data Owner's health and sexual life can only be used for the protection of public health, preventive medicine, medical diagnosis, execution of treatment and care services, health services. by persons or authorized institutions and organizations under the obligation of confidentiality, for the purpose of planning and management of financing.

Purposes of Processing and Transferring Personal Data

Personal Data; Planning and implementing FERAN CAR RENTAL's human resources policies in the best possible way in accordance with the law and the purpose of the Law, Proper planning, execution and management of its commercial partnerships and strategies, Its and its business partners' legal, commercial and Ensuring physical security, Ensuring corporate functioning, planning and execution of management and communication activities, Making the best use of products and services for Personal Data Owners and recommending them by customizing them according to their demands, needs and wishes, Ensuring data security at the highest level, Maintaining databases Developing the services offered on the website and eliminating errors that occur on the site, Communicating with Personal Data Owners who submit their requests and complaints to it and ensuring demand and complaint management, Event management, Management of relations with business partners or suppliers, Carrying out personnel recruitment processes, Group Companies' Supporting the personnel recruitment processes and compliance with the relevant legislation, planning and execution of audit activities to ensure that the activities of the Group Companies are carried out in accordance with the relevant legislation, supporting the Group Companies in carrying out their corporate and partnership law transactions, financial reporting and risk management transactions. Execution/follow-up of the company's legal affairs, Carrying out work to protect its reputation, Managing investor relations, Providing information to authorized institutions based on the 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 obtained by FERAN CAR RENTAL regarding the relevant processing process.

METHOD AND LEGAL REASON FOR COLLECTING PERSONAL DATA, DELETION, DESTRUCTION, STORAGE PERIOD

Method and Legal Reason for Collecting Personal Data

Personal Data, for the purpose of checking its compliance with Article 1, which regulates the purpose of the Law, and Article 2, which regulates the scope of the Law; in all kinds of oral, written and electronic media; It is collected through various means such as technical and other methods, call center, FERAN CAR RENTAL website, mobile application, in order to fulfill the responsibilities arising from the law completely and accurately within the framework of legislation, contract, demand and optional legal reasons. and is processed by the Company or data processors appointed by the Company.

Deletion, Destruction or Anonymization of Personal Data

Without prejudice to the provisions of other laws regarding the deletion, destruction or anonymization of Personal Data, FERAN CAR RENTAL, this Law and other Although it has been processed in accordance with the provisions of the law, it deletes, destroys or anonymizes Personal Data ex officio or upon the request of the data owner, in case the reasons requiring processing are eliminated. By deleting Personal Data, this data is destroyed in a way that cannot be used again and cannot be recovered. Accordingly, Personal Data is irreversibly deleted from the documents, files, CDs, floppy disks and hard disks in which they are recorded. Destruction of Personal Data refers to the destruction of materials suitable for storing data, such as documents, files, CDs, floppy disks and hard disks in which the data is recorded, so that the information cannot be retrieved or used again. By anonymizing data, it is meant to make Personal Data unable to be associated with an identified or identifiable natural person, even if it is matched with other data.

Storage Period of Personal Data

FERAN CAR RENTAL stores Personal Data for the period specified in this legislation, if stipulated in the legislation. If a period of time is not regulated in the legislation regarding how long personal data should be stored, Personal Data may be processed by FERAN CAR RENTAL's practices and applications depending on the activity carried out while processing that data. In accordance with the practices of commercial life, it is processed for a period of time that requires processing within the framework of the rules of honesty, and then it is deleted, destroyed or anonymized. The purpose of processing personal data has expired; If the storage periods determined by the relevant legislation and FERAN CAR RENTAL have come to an end; Personal data can only be stored to serve as evidence in possible legal disputes or to assert the relevant right based on personal data or to establish a defense. While establishing the periods here, the limitation periods for asserting the mentioned right and the retention periods are determined based on the examples in the requests previously directed to FERAN CAR RENTAL on the same issues, even though the limitation periods have passed. In this case, the stored personal data is not accessed for any other purpose and the relevant personal data is accessed only when it needs to be used in the relevant legal dispute. Here too, after the mentioned period expires, personal data is deleted, destroyed or anonymized.

DISCLOSURE OBLIGATION

FERAN CAR RENTAL is obliged to inform the real persons whose data will be processed during the acquisition of Personal Data. The scope of this information obligation is as follows:

- Identity of the data controller and his/her representative, if any

- For what purpose the 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 legal reasons and rights.

FERAN CAR RENTAL will provide the necessary information on this matter through the means of obtaining data from Third Parties for processing in its systems and will provide the necessary information regarding data processing to prove that the obligation to inform is fulfilled. Will obtain informed consent from the owners. Personal Data is collected verbally, automatically or non-automatically, through FERAN CAR RENTAL's electronic commerce, all sales channels including sales stores, branches, websites, call center where service can be obtained from third parties and all other similar channels. It can be collected in writing or electronically.

- Obtaining Personal Data in Written Form: While obtaining Personal Data in written form, FERAN CAR RENTAL shall use the new relevant forms and information to be revised based on this Text. Provided that it will fulfill the Disclosure Obligation regarding the processing of data. In addition, all forms and contracts, including Authorized Contact Forms, to be received from persons with whom customer relations have been established, will be revised to indicate the explicit consent of the Data Subject for the processing of Personal Data, even though the processing of the relevant data group may be considered within the scope of exception in accordance with the Law. In customer relations, new forms, documents and information that prove compliance with the Law will be used; All relevant employees will be trained to provide sufficient detailed information and show references to the real person on this subject. It will definitely be ensured that Personal Data is obtained through written forms containing informed consent.

- Obtaining Personal Data Verbally: Obtaining any new or non-existing data regarding existing customers processed in accordance with the Permitted Contact Forms already received and obtaining data through the Call Center. Information will be provided regarding the obligation to inform regarding the processing of Personal Data. During the collection of verbal data, it will be reminded that the conversation has been recorded, provided that it is informed in advance, and it will be confirmed that consent has been given that the Personal Data will be processed in accordance with this Policy and the existing Authorized Contact Forms, if any. Employee and Call Center business processes will be re-evaluated and implemented within this framework.

- Obtaining Personal Data in Electronic Environment: Data obtained through electronic commerce channels and other internet channels of FERAN CAR RENTAL, including this Information Text. All contracts and documents / link addresses / web pages requiring the collection and processing of Personal Data have been revised to fulfill the obligation to inform regarding the processing of Personal Data. This Text will be available on all websites of FERAN CAR RENTAL and will include approval of data processing by FERAN CAR RENTAL in order to obtain data at every link address that may require data collection. Systems that require it will be established. Unless it is clearly marked that consent is given to the processing of Personal Data, any information and documents entered will not be automatically recorded in any FERAN CAR RENTAL system and will not be processed in any way.

YOUR RIGHTS TOWARDS THE PROTECTION OF PERSONAL DATA

FERAN CAR RENTAL will respond to the following requests of the relevant persons in writing, verbally and electronically:

a) Learning whether FERAN CAR RENTAL processes personal data about them and which personal data it processes,

b) Obtaining information about the purposes of the processing activity,

c) Knowing the third parties to whom FERAN CAR RENTAL transfers personal data at home or abroad,

d) Requesting correction of personal data if they are incomplete or incorrectly processed,

e) Requesting the deletion or destruction of personal data in accordance with the Law,

f) In case of request for correction, deletion or destruction of personal data; Requesting that the transactions carried out be notified to third parties to whom personal data is transferred,

g) Objecting to the emergence of a result against the person by analyzing the processed data exclusively through automatic systems, and

h) Receiving a copy of your personal data.

You can contact us with your comments and questions. In accordance with the 1st paragraph of Article 13 of the KVK Law, you can submit your request to exercise your above-mentioned rights to our Company in writing or by other methods determined by the Personal Data Protection Board.

Personal Data Owner Application Procedure

You can use the "Application Form" to submit your requests regarding your rights mentioned above.

Your applications regarding your requests;

From hand

By registered letter

Through notary

Remzi Oğuz Arık Mahallesi Tunus Caddesi NO: 83/3 Kavaklıdere ÇANKAYA / ANKARA with a wet signed copy or

You can transmit it using another method prescribed by the Personal Data Protection Board. Your request will be evaluated and concluded as soon as possible and, in any case, within the period specified in the KVKK. However, if the written response to be given by us regarding your application exceeds 10 pages and/or requires it to be given on a recording medium such as a CD or flash memory, it will be subject to the fee determined by the Personal Data Protection Board within the provisions of the "Communiqué on the Procedures and Principles of Application to the Data Controller".

In order for third parties to request an application on your behalf, there must be a special power of attorney issued through a notary on behalf of the person making the application.

If the process of examining and finalizing your application requires a cost, our Company may charge the fee in the tariff determined by the Board.

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