Personel Data Protection

BESA VIP TURIZM OTOMOTİV TAŞ. ORG. GID. BİLG. TEKS. TEM. İNŞ. TAAH. SAN. VE TİC. LTD. ŞTİ.

PERSONAL DATA PROTECTION AND PROCESSING

CUSTOMER CLARIFICATION TEXT

Data Controller

In accordance with the Personal Data Protection Law No. 6698 (“Law”), Besa VIP Turizm Ltd. Şti. (“Company”) acting as the data controller places great importance on the protection of your personal data.

Purpose of Processing Personal Data

Your collected personal data may be processed by our Company for the purposes of making necessary efforts by our business units to benefit you from the products and services offered by our Company, conducting relevant business processes, performing necessary efforts by our business units to carry out the commercial activities conducted by our Company, ensuring the legal, technical and commercial-occupational safety of related persons who have a business relationship with our Company, and for the purposes listed below (“Purposes”) and within the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law:

Regarding Besa Car Rental products and services:

• Ensuring that you benefit from our hourly/daily/monthly car or tire rental services and managing reservations or cancellation requests within this scope,
• Execution and performance of rental agreements,
• Monitoring your transition information within systems such as the fast transit system (HGS) and managing related penalties,
• Location tracking,
• Monitoring fuel levels,
• Recording destination locations in case of using car-sharing services.

For all our products and services:

• Performing verification and/or activation processes related to your records and transactions,
• Creating appointments and providing offers,
• Opening sales records, performing online/offline payment and billing activities,
• Establishing or performing sales agreements due to the purchase of our products and services,
• Conducting information and promotional activities about our products and services,
• Creating, monitoring, or canceling memberships,
• Providing vehicle protection services,
• Ensuring the safety of company operations and vehicles,
• Providing after-sales support services,
• Performing accounting and finance processes,
• Conducting financial risk assessments for customers,
• Receiving, evaluating, and concluding your requests, questions, complaints, and suggestions,
• Updating customer information,
• Ensuring compliance with retention obligations stipulated in the legislation,
• Conducting evaluations and concluding requests made to the Company related to your rights specified in Article 11 of the Law and carrying out necessary procedures within this scope,
• Retaining records for the general statute of limitations to serve as evidence in potential future disputes,
• Planning and executing customer relationship management processes,
• Tracking and managing legal affairs,
• Monitoring and improving service-related activities,
• Fulfilling official institution requests and providing information to authorized entities as required by legislation,
• Conducting information security processes,
• Performing audit and ethical activities,
• Planning and executing customer satisfaction and corporate communication activities,
• Conducting sweepstakes, campaigns, contests, promotions, or advertising activities,
• Providing additional benefits to loyalty program members,
• Processing health data to provide after-sales support services in case of accidents, with your consent,
• Customizing our products and services based on your preferences, usage habits, and needs and sending commercial electronic messages for advertisements, promotions, campaigns, and similar purposes to your contact information, with your consent.

To Whom and For What Purpose Processed Personal Data May Be Transferred

Your collected personal data may be transferred within the framework of the personal data processing conditions and purposes specified in Article 8 of the Law, to our business/solution partners, suppliers, legally authorized public institutions, and legally authorized private individuals for the realization of the Purposes. Detailed information on the parties to whom your personal data is transferred can be found in the Policy.

Method and Legal Reason for Collecting Personal Data

Your personal data is collected by our Company in electronic media through our website, mobile applications, social media accounts, email, call center, and your vehicle usage; and in physical media through cargo/post, fax, face-to-face meetings, based on the legal reasons specified in Articles 5 and 6 of the Law as detailed below:

• For the realization of vehicle sales, cash vehicle purchase services, vehicle purchase and sale processes through tenders, second-hand vehicle sales, rental services of hourly/daily/monthly vehicles or tires, provision of valet services, vehicle maintenance services, vehicle appraisal services, provision of HGS/OGS, execution of periodic vehicle maintenance processes, provision of additional services such as fleet vehicle rental insurance, accident and damage management based on your request, execution and performance of rental agreements, sales of vehicle spare parts and accessories, calling a tow truck in case of an accident or breakdown, provision of road assistance, recording the destination location in case of using the car-sharing service, creating appointments and providing offers, opening sales records, performing online/offline payment and billing activities, establishing or performing sales agreements due to the purchase of our products and services, updating customer information, performing verification and/or activation processes related to your records and transactions, creating, monitoring, or canceling memberships, providing vehicle protection services, based on the legal reason that it is necessary for the establishment or performance of a contract to which the data subject is a party.

• For fulfilling the requests of official institutions and providing information to authorized entities as required by legislation, ensuring compliance with retention obligations stipulated in the legislation, evaluating and concluding requests made to the Company related to your rights specified in Article 11 of the Law and carrying out necessary procedures within this scope, based on the legal reason that it is necessary for the fulfillment of the Company’s legal obligations.

• For receiving, evaluating, and concluding your requests, questions, complaints, and suggestions, retaining records for the general statute of limitations to serve as evidence in potential future disputes, based on the legal reason that it is necessary for the establishment, exercise, or protection of a right.

• For conducting information and promotional activities about our products and services, ensuring the safety of company operations and vehicles, monitoring your transition information within systems such as the fast transit system (HGS) and managing related penalties, performing verification and/or activation processes related to your records and transactions, performing accounting and finance processes, conducting financial risk assessments for customers, planning and executing customer relationship management processes, tracking and managing legal affairs, conducting information security processes, performing audit and ethical activities, monitoring and improving service-related activities, planning and executing customer satisfaction and corporate communication activities, conducting sweepstakes, campaigns, contests, promotions, or advertising activities, based on the legal reason that data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

• For the provision of our services, analyzing your driving performance and determining a low-risk rate for providing a special pricing for the insurance product, earning points and providing advantages based on driving scores, processing your health data to provide after-sales support services in case of accidents, customizing our products and services based on your preferences, usage habits, and needs and sending commercial electronic messages for advertisements, promotions, campaigns, and similar purposes to your contact information, based on your explicit consent.

Rights of the Relevant Person under Article 11 of the Law

As the relevant person, we inform you that you have the following rights under Article 11 of the Law:

• To learn whether your personal data is processed,
• To request information if your personal data has been processed,
• To learn the purpose of processing your personal data and whether they are used in accordance with their purpose,
• To know the third parties to whom your personal data is transferred within the country or abroad,
• To request the rectification of your personal data if it is incomplete or incorrectly processed, and to request the notification of the third parties to whom your personal data is transferred within this scope,
• To request the deletion or destruction of your personal data in accordance with the conditions stipulated in the Law and other relevant laws, and to request the notification of the third parties to whom your personal data is transferred within this scope,
• To object to the occurrence of a result against you by analyzing the processed data exclusively through automated systems,
• To request compensation for the damage arising from the unlawful processing of your personal data.