Protection of Personal Data
Privacy Policy on Protection and Processing of Personal Data
The purpose of this Privacy Policy on Protection and Processing of Personal Data (Policy) is to fulfill the obligation of informing under Article 10 of the Law on Protection of Personal Data No. 6698 (the Law) regarding the use of personal data obtained and/or obtained from third parties during the use of the internet site located at https://elitcarrental.com/ (the Portal) managed by Elitcar Tourism Joint Stock Company (Elitcar). Additionally, it aims to transparently inform Users about the ways in which personal data collected by Elitcar during the use of the Portal by Users or through their positive actions in the Portal are collected, processed, the legal reasons, and their rights.
In short-term or fleet rentals, potential customers are provided with an up-to-date environment by Elitcar. In this activity, personal data, as stated in this Information, may be processed as necessary for the use of Elitcar functions.
By investing in technology, Elitcar constantly renews itself with innovative product and service applications in the internet field to provide better service to its Users and works to provide the best service, takes the highest level of security measures possible to ensure that personal data is collected, stored, and shared in compliance with the law, and protects its confidentiality. To achieve this goal, Users' personal data are processed within the scope and conditions detailed below.
Elitcar may update and change this Policy published on the Portal at any time. Updates and changes made by Elitcar will be effective from the date of publication on the Portal.
A- Data Controller
In accordance with the Law on Protection of Personal Data, your personal data will be collected and processed by Elitcar as the data controller within the scope described below.
B- Collected Personal Data
Elitcar collects various static (fixed) and dynamic (variable) data from Users through the methods specified below. The data collected by Elitcar depends on the services and features used by Users.
Under this title, the data processed within the scope of the Services provided by Elitcar and which are considered personal data within the scope of the Law on Protection of Personal Data are listed below in groups. Unless otherwise explicitly stated, the terms "personal data" and "sensitive personal data" in this Information include the information listed below:
Name and Contact Information: Name, surname, mobile phone, home phone, work phone, address, e-mail address, invoice information, TC ID number (national ID number), identity sample, passport sample, driver's license sample, and similar other documents.
Identity Verification Information: User registration information, passwords used to authenticate identity and provide access to accounts, User Name, contact information, password hints, User numbers, reservation numbers.
Demographic Data: Date of birth, age, gender, preferred language and currency data.
Usage Data and Favorites: Data collected from your devices through various software and technological tools including but not limited to reasons for calling Elitcar or Call Centers, voice recordings, website usage information, date-time queries, vehicle reviews, reservation data, survey data, and error reports generated during service usage.
Location Data: Data related to the sensitive or approximate locations of Users. It is used when permission is granted by Users while using Elitcar's mobile applications for vehicle delivery during personnel guidance.
Payment Data: Customer invoice and payment information (name, surname, invoice address, TC ID number, tax ID number), invoice copies sent to customers and receipts from customers, payment number, invoice number, invoice amount, invoice date, and similar data.
Survey Responses: Information requested from Users who respond to periodic surveys organized by Elitcar within the Portal, responses to satisfaction surveys conducted after reservations, and responses sent for feedback within the Website.
Where and How are Personal Data Stored and Processed?
Your personal data obtained are stored and processed by Elitcar, its affiliates, subsidiaries, or service providers located in another country where Elitcar or its affiliates, subsidiaries, or service providers have facilities, and they may be processed for the purposes stated in this Information and in accordance with the legislation in force in the country where the data are stored and processed, including the security measures provided.
C- Purpose of Processing Personal Data
In accordance with this Information and the Membership Agreement, your personal data will be processed within the scope of the Principles and Processing Conditions regulated by the Law on Protection of Personal Data No. 6698 and for the purposes detailed below:
Name and Contact Information: Internal evaluation, communication, User registration, obtaining potential customer information, developing post-sales processes, business development, collection, customer portfolio management, promotion, analysis, complaint management, managing customer satisfaction processes, marketing, advertising, research, billing, event notification, operational activities, measuring, improving service quality, development, audit, control, optimization, customer verification, marketing, sales, advertising, after-sales services, fraud detection, and prevention;
Identity Verification Information: User registration, problem/error reporting, control, improvement of operational activities, implementation of post-sales processes, business development, collection, complaint management, customer portfolio management, service quality measurement, improvement, communication, optimization, audit, risk management, fraud detection, and prevention;
Demographic Data: Promotion, internal evaluation, analysis, communication, improvement of post-sales processes, business development, collection, use data and interests, favorites, marketing, sales, advertising, communication, complaint management, improvement of operational activities, measurement and improvement of service quality, communication, complaint management, operational activities, error reporting;
Usage Data and Favorites: User registration, problem/error reporting, control, improvement of operational activities, implementation of post-sales services, business development, collection, complaint management, customer portfolio management, service quality measurement and improvement, communication, optimization, audit, risk management, control, promotion, analysis, determination of interests, scoring, profiling, marketing, sales, advertising, communication, complaint management, operational activities, error reporting;
Location Data: Provision of location-dependent or location-related Portal functions, audit and control, risk management;
Payment Data: Managing the billing process, accounting, improving post-sales processes, business development, collection, internal evaluation, scoring, profiling, customer portfolio management, after-sales services, communication, marketing, audit, control, processes with payment service providers;
Survey Responses: Responses given to periodic surveys organized by Elitcar within the Portal, responses to satisfaction surveys conducted after reservations, and responses sent for feedback within the Website are shared with third parties such as real and/or legal persons with whom Elitcar cooperates for the provision of Portal functions and in accordance with the purposes of use of the Portal for direct marketing, statistical analysis, process improvement, and database creation;
In order to fulfill the legal and commercial obligations arising from contracts concluded with third parties, or from activities carried out, or to perform legal actions within the scope of legal regulations, Elitcar will process personal data for purposes such as fulfilling legal and commercial obligations arising from contracts concluded with business partners/customers/suppliers, establishing rights, protecting rights, conducting commercial and legal evaluations, managing legal compliance process, conducting financial affairs, fulfilling legal requirements, fulfilling requests of authorized institutions, organizations, and authorities, and responding to them, within the scope of the purposes and processing conditions specified in Articles 5 and 6 of the Law No. 6698.
Storage Period of Personal Data
Elitcar will keep the personal data it obtains for as long as necessary to enable Users to benefit from the Service in the best possible way, within the terms specified in this Information and to fulfill its obligations arising from the Membership Agreement. In addition, Elitcar may keep personal data for the duration of the statute of limitations for any disputes that may arise from the Membership Agreement, limited to conducting administrative or judicial processes in the context of the dispute and the periods of limitation stipulated by the relevant legislation.
C- To Whom and for What Purposes Can Processed Personal Data be Transferred
Elitcar may share personal data belonging to Users and new data obtained using this personal data or personal information entered by Users into the Portal through their positive actions with third parties such as external service providers, law firms, research companies, call centers, complaint management and security software companies, agencies, consultancy firms, companies in the printing sector, including but not limited to real and/or legal persons with whom Elitcar cooperates, and third-party service providers and competent institutions, organizations, authorities, and administrative and judicial bodies within the scope of legal obligations, in order to perform its legal obligations, to ensure the security of Users, to detect and prevent fraud, to develop the Services, to carry out operational evaluation research, to correct errors, to authenticate User identities, to improve system performance, for reasons including but not limited to online behavioral advertising and marketing, managing the customer portfolio, measuring and improving service quality, communication, optimization, audit, risk management, promotion, analysis, determining interests, scoring, profiling, marketing, sales, advertising, communication, complaint management, and operational activities.
Additionally, the User's Name and Contact Information may be shared with payment institutions for identity verification purposes, in accordance with the framework agreement for payment institutions to be approved at the payment stage and the Regulation on Measures Regarding the Prevention of Laundering of Crime Revenues and Financing of Terrorism published in the Official Gazette dated January 9, 2008.
Your personal data obtained through cookies placed on your device may be shared with third parties in accordance with the scope and purposes stated in this Information. Elitcar may transfer personal data to third parties both domestically and abroad, limited to and proportional to these purposes, within the scope of the categories and purposes specified above.
D - Method and Legal Basis of Personal Data Collection
Elitcar collects your personal data to work more efficiently and provide you with the best experience. Your data is collected using the following methods:
Data Directly Provided to Elitcar: This includes personal data provided by Users to Elitcar at their own initiative for the performance of the Service and before or during the use of the Portal. This includes all personal data given directly to Elitcar by Users through their positive actions. For example, name, surname, contact information, identity information, survey responses, demographic data, and content information fall into this category of data.
Data Obtained When You Use Our Platform: This includes personal data about Users' usage habits obtained during the service provided by Elitcar, through specific software or technological tools. For example, location data, favorites, interests, and usage data fall into this category of data.
Elitcar may, for the purpose of online behavioral advertising and marketing, associate the behaviors of users on the site with a cookie (cookie) in the browser, even if they are not members, and perform operations to define remarketing lists based on metrics such as the number of pages viewed, visit duration, and goal completion.
Personal data obtained through these methods can be processed and transferred within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698 and stated in this Information.
The legal bases for collecting personal data are:
Membership Agreement, Terms of Use, and based on these, the performance of the contract, the establishment and protection of rights
Legal regulations regulating e-commerce activities, finance, and tax matters, consumer protection, and other matters
Elitcar's legitimate interest in collecting data necessary to carry out its services, especially to prevent fraud in its activities related to the Portal, to develop services, and to carry out operational evaluation research.
E- Our Commitments and Measures for Data Security
Elitcar is committed to protecting personal data securely. Technical and administrative measures are taken using various methods and security technologies to prevent the unlawful processing and access of personal data and to ensure the preservation of personal data.
Elitcar will not disclose or use personal data obtained in violation of this Information and Law No. 6698 on Protection of Personal Data for any purpose other than the processing purpose. In case of sharing personal data of Users with external service providers under this Information, Elitcar declares that it will perform the necessary warnings and supervision activities for the compliance of these external service providers with the commitments under this clause.
In case of linking to other applications through the Portal, Elitcar shall not be liable for the privacy policies and contents of the linked applications. The User undertakes to update their information immediately at https://elitcarrental.com/panel/settings if there is any change in this information. If the User does not provide up-to-date information, Elitcar will not be liable for any damages.
F- Rights of Personal Data Subjects Under Article 11 of Law No. 6698
As personal data subjects, if you submit your requests regarding your rights, Elitcar will process your request within the shortest time and no later than thirty days free of charge. No fee will be charged for the response up to ten pages. A processing fee of 1 Turkish Lira will be charged for each page over ten pages. If the response is to be provided on a recording medium such as a CD, flash drive, the fee charged by Elitcar will not exceed the cost of the recording medium.
In this context, personal data subjects have the right to:
Learn whether their personal data are processed,
Request information if their personal data have been processed,
Learn the purpose of processing personal data and whether they are used in accordance with their purpose,
Know the third parties in the country or abroad to whom personal data have been transferred,
Request correction of personal data if it is incomplete or incorrectly processed and request notification of the transaction made within this scope to third parties to whom personal data have been transferred,
Request deletion or destruction of personal data in case the reasons requiring its processing are eliminated, even if it has been processed in accordance with the provisions of Law No. 6698 and other relevant laws, and request notification of the transaction made within this scope to third parties to whom personal data have been transferred,
Object to the occurrence of a result against the person himself by analyzing the processed data exclusively through automated systems,
You can send your request to use the above-mentioned rights in Turkish; as the data controller, Elitcar's address is Yenişehir Mh. Millet Cad. Sümbül Sk. No:10 D:138/139 Pendik/İstanbul/Turkey, with identifying documents attached, in person, through a notary, by registered electronic mail to [email protected], or through other methods determined by the Personal Data Protection Authority.
Elitcar reserves the right to verify your identity before responding.
Your request must include:
Your name, surname, and if the request is written, your signature,
For Turkish citizens, your T.C. identity number, or if you are a foreigner, your nationality, passport number, or if any, your identity number,
Your place of residence or business address for notification,
If available, your e-mail address, telephone, and fax numbers for notification,
The subject of your request, and if necessary, the information and documents related to the subject should be attached to the application.