Protection of Personal Data

Information Text on Protection and Processing of Personal Data

Information Text on Protection and Processing of Personal Data (The purpose of the Information)is to fulfill the obligation of informing stipulated by Article 10 of Law No. 6698 on the Protection of Personal Data regarding the use of personal data obtained and/or collected from users and third parties during the use of the internet site located at(managed by) Otorento Tourism and Organization Limited Company. otorento.com.tr In addition, it aims to transparently inform users about the methods of collecting personal data related to the use of OTORENTO by users or their positive actions, processing purposes, legal reasons, and rights. (OTORENTO) OTORENTO, which mediates the car rental service, works for the rental of vehicles of various car rental companies by users. Within this activity, personal data may be processed in accordance with the provisions stated in this Information Text, as necessary for the functioning of OTORENTO.(KVKK) OTORENTO takes the highest level of security measures possible to ensure the lawful collection, storage, and sharing of personal data and to protect its confidentiality. To achieve this purpose, users' personal data is processed in the scope and conditions described in detail below.

Company reserves the right to update and change these Information provisions at any time through OTORENTO. The updates and changes made by Company will be effective as of the date of publication on OTORENTO.

OTORENTO takes the highest level of security measures to ensure the lawful collection, storage, and sharing of personal data, as well as to protect its confidentiality. In order to achieve this purpose, users' personal data is processed within the scope and conditions detailed below.

Company may update and modify these Information provisions at any time by publishing them on OTORENTO. The updates and changes made by Company will be effective as of the date of publication on OTORENTO.

A. Data Controller

In accordance with the Law on the Protection of Personal Data, your personal data will be collected and processed within the scope described below by Company as the data controller.

B. Collected Personal Data

Company collects various static and dynamic data from users through the methods listed below. The data collected by Company depends on the services and features used by users.

Under this heading, the following groups of data, which are considered personal data and special categories of personal data in accordance with the Information Text, are processed within the scope of the Services provided by Company. Unless explicitly stated otherwise, the terms 'personal data' and 'special categories of personal data' in the Information Text include the following information:

Identity and Contact Information: Name, surname, mobile phone, email address, invoice information, TR ID number, etc.

Identity Verification Information: User's membership information, passwords used to verify identity and provide access to the account.

Demographic Data: Date of birth, age, gender, marital status, interests, travel information, preferred language data.

Usage Data and Favorites: Data collected from your devices through various software and technological tools, including but not limited to reasons for calling the company or call centers, reservation codes, voice recordings, search information for car rental destinations, date and time data of OTORENTO usage, viewed car rental locations, dates, times, delivery and return locations and addresses, data specified in relevant advertisements or banners for users to be directed to the relevant product and for product suppliers to contact users, filtering, sorting, prioritization options, last login date to OTORENTO, membership type, collected points, visited websites, viewed page count, visit duration, entered search terms, information about visited flights, errors and similar issues that occur during service usage.

Cookie Data: Browser information, IP and port data, browser movements, browser selection information, and any data that can be obtained through cookies.

Payment Data: Credit card data, invoice and payment information (name, surname, billing address, TR ID number, tax identification number), samples of invoices sent to members and receipts for payments received from members, payment number, invoice number, invoice amount, invoice issue date, and similar data.

Survey Responses: Responses given to periodic surveys organized by Company within OTORENTO, as well as responses given to surveys conducted by real and legal persons in collaboration with Company.

Travel Data: Flight information searches, interested destination data, reservation information, travel date and time information, meal preferences, flight insurance data, delay and ticket usage data, disability and illness data, baggage data, preferred airline data.

Where are Personal Data Stored and Processed?

Your personal data that we obtain may be stored in another country where Company or its affiliates, subsidiaries, or service providers with facilities are located, either domestically or abroad, and may be processed in accordance with the purposes stated in this Information Document and in proportion to these purposes.

The personal data collected within the scope of this Information Document will be processed in accordance with the provisions specified herein and the legislation in force in the country where the data is stored and processed, including the prescribed security measures.

C. Purposes of Processing Personal Data

Your personal data will be processed within the scope of the purposes specified in this Information Document and the User Terms and Conditions, in accordance with the Principles and Processing Conditions stipulated in Law No. 6698 on the Protection of Personal Data and detailed below:

In accordance with the contractual obligations arising from the contracts concluded with third parties, including real and/or legal persons in relation to Company and the activities carried out with them, and the legal and commercial obligations within the scope of the applicable legislation, Company will process the personal data in accordance with the purposes and conditions of personal data processing specified in Articles 5 and 6 of Law No. 6698 for the purpose of fulfilling these obligations, establishing rights, protecting rights, conducting legal and commercial evaluations, conducting legal and commercial risk analyses, carrying out legal compliance processes, conducting financial affairs, fulfilling legal requirements, fulfilling the decisions of authorized institutions and organizations, responding to their requests.

Retention Period of Personal Data

Company will retain the personal data it obtains for the period necessary to fulfill the purpose of processing, as specified in this Privacy Notice and the Terms of Use Agreement, in order to enable Users to benefit from the Service in the best possible way and to fulfill the obligations arising from the nature of the Terms of Use Agreement.

In addition, Company may retain personal data for the duration of the statutory limitation periods, to the extent necessary, for the purpose of conducting administrative or judicial proceedings within the scope of any disputes arising from the Terms of Use Agreement.

D. Persons to Whom Processed Personal Data May Be Transferred and Purposes

Company may share the personal data of the User and the new data obtained using this personal data or the personal information entered by the Users themselves through positive actions with external service providers, airlines, airport administrations, national and international civil aviation regulatory and supervisory organizations, airline coordination organizations, law firms, research companies, call centers, software companies for complaint management and security, agencies, consulting firms, companies in the printing sector, banks, social media platforms, and other third-party individuals and/or legal entities, as well as authorized institutions, organizations, authorities, administrative and judicial bodies, in accordance with the legal obligations and in order to fulfill the legal and commercial obligations arising from the contracts concluded by Company with business partners/customers/suppliers for the purpose of performing contractual obligations, establishing rights, protecting rights, conducting legal and commercial evaluations, conducting legal and commercial risk analyses, conducting legal compliance processes, conducting financial affairs, fulfilling legal requirements, fulfilling the decisions of authorized institutions and organizations, responding to their requests, and for the purposes specified in the processing purposes section of Law No. 6698, Articles 5 and 6.

In addition, the User's Name and Contact Information may be shared with payment service providers in accordance with the framework agreement to be confirmed during the payment stage and for the purpose of performing identity verification in accordance with the Regulation on Measures Regarding the Prevention of Laundering Proceeds of Crime and Financing of Terrorism published in the Official Gazette dated 9 January 2008 and numbered 26751.

Your personal data obtained through cookies placed on your device may be shared with third parties within the scope and purposes specified in this Privacy Notice.

Company may transfer personal data to third parties both domestically and internationally within the scope of the mentioned categories and purposes, limited to and proportionate with these purposes.

E. Method of Collecting Personal Data and Legal Basis

Company collects your personal data in order to work more efficiently and provide you with the best experience. Your data is collected using the following methods:

For the purpose of online behavioral advertising and marketing, Company may associate the user's behavior on the site with a cookie stored in the browser, even if they are not registered users, and perform activities such as defining remarketing lists based on metrics such as the number of pages viewed, visit duration, and goal completions.

The personal data collected through these methods may be processed and shared within the scope and purposes specified in this Privacy Notice, in accordance with the conditions and purposes of personal data processing specified in Articles 5 and 6 of Law No. 6698.

Legal Basis for Collecting Personal Data

The Membership Agreement, Terms of Use, and the performance, establishment, and protection of rights based on these documents rely on Company's legitimate interest in collecting the necessary data to carry out its activities related to OTORENTO, especially to prevent fraud and provide services.

F. Our Measures and Commitments Regarding Data Security

Company is committed to protecting personal data securely. It implements technical and administrative measures using various methods and security technologies to prevent the unlawful processing and access of personal data and to ensure the preservation of personal data.

Company will not disclose the personal data it obtains to third parties and will not use it for purposes other than processing, in accordance with this Privacy Notice and the provisions of Law No. 6698. Company declares that it will perform the necessary warning and supervision activities to ensure that third-party service providers comply with the commitments under this Privacy Notice when sharing personal data of Users with such external service providers.

If links to other applications are provided through OTORENTO, Company does not bear any responsibility for the privacy policies and content of the linked applications.

The User undertakes to ensure that the information subject to this Privacy Notice is complete, accurate, and up to date, and to promptly inform Company through the contact address in case of any changes. Company will not be responsible for any liability arising from the User's failure to provide up-to-date information.

G. Rights Listed in Article 11 of Law No. 6698

As personal data owners, if you submit your requests regarding your rights to Company through the methods described below, Company will finalize the request as soon as possible and within a maximum period of thirty days, free of charge, depending on the nature of the request. No fee will be charged for a response of up to ten pages. A processing fee of 1 Turkish Lira will be charged for each page exceeding ten. If the response is provided in a recording medium such as a CD or flash drive, the fee requested by Company will not exceed the cost of the recording medium.

The right to object to the occurrence of a result against the person as a result of the analysis of the processed data exclusively through automated systems

In this context, as personal data owners;

You can submit your request regarding the exercise of the above-mentioned rights in Turkish, by hand, with identity verification documents, to the address of Otorento Turizm ve Organizasyon Limited Şirketi, as the data controller, at 'Fahrettin Kerim Gökay Cad. Pembe Köşk Apt. No: 246/5 A Blok Göztepe/İstanbul', or through other methods determined by the Personal Data Protection Authority.

Company reserves the right to verify your identity before responding.

In your application;

are mandatory, and if applicable, any information and documents related to the subject should be attached to the application.