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Protection of Personal Data

PDPL CLARIFICATION TEXT


Purpose of the Clarification and Data Controller

The purpose of this Personal Data Protection and Processing Clarification Text (Clarification Text) is to fulfill the disclosure obligation brought by Article 10 of the Law on Protection of Personal Data No. 6698 (Law or PDPL), regarding the processing of personal data obtained and/or received from third parties during the use of the website located at www.otorento.com.tr, managed by Otorento Tourism Organization and Limited Company (OTORENTO).


Additionally, it aims to transparently clarify the methods of collection, purposes of processing, legal reasons, and rights regarding the personal data entered into Otorento.com.tr by the Users themselves through their positive actions or collected by OTORENTO related to the use of Otorento.com.tr.


As Otorento.com.tr, we are committed to ensuring the collection, storage, and sharing of personal data in accordance with the law and protecting privacy by taking the highest level of security measures possible. To achieve this purpose, users' personal data are processed under the scope and conditions detailed below.


Otorento.com.tr provides car rental services. Within this activity, your personal data are processed in the context of the commercial activities conducted by Otorento.com.tr, as stated in this Clarification Text. The personal data we process vary depending on the Otorento.com services and processes you use, and this clarification text is designed to make you aware of all processing activities prepared according to the services and processes you use.


Otorento may update and change the provisions of this Clarification by publishing them on Otorento.com.tr at any time. Updates and changes will be effective from the date of publication on Otorento.com.tr.


Data Controller

Otorento Tourism Organization Limited Company is responsible for determining the purposes and means of processing your personal data, and for establishing and managing the data recording system, in relation to all data processing activities concerning you.

Your Personal Data Processed According to Processes

Your Data Processed According to Processes

You can learn which data is processed how during which process by selecting from the section on the left side, regarding your personal data processed according to the processes, the purposes of processing, legal reasons, and transfer information; here, you can also find information on how your personal data are obtained, what your rights related to the processing of your data are, and how you can apply to Otorento to exercise these rights.


Your Data Processed According to Processes


Website Visit

If You Visit Our Website

Related Person

You, whose personal data are processed by Otorento, are identified as a Visitor (Internet) due to your visit to our website, and you are also recognized as the Related Person by the Law.


Your Processed Personal Data, Purposes of Processing, and Legal Reasons

Personel Data

Purposes of Processing

Legal Reason

Website Traffic Information

(Connection Time, Visited Page, IP Address, etc.)

Conducting Activities in Compliance with Regulations, Creating and Monitoring Visitor Records, Conducting Information Security Processes, and Storage and Archiving Activities

Due to Explicitly Provided by Law, pursuant to Article 5/2a of PDPL, the Responsibilities of the Provider in the Law No. 5651 on Regulating Broadcasts Made on the Internet and Combating Crimes Committed through These Broadcasts (Article 4)

Cookie Information

Conducting Marketing Analysis and Advertising / Campaign / Promotion Processes

Due to our legitimate interests, pursuant to Article 5/2f of PDPL


Transfer of Your Personal Data

Your personal data can be transferred to relevant authorities without the need for disclosure obligations and without seeking your explicit consent, in cases requested under Article 28/1 of PDPL.

Besides, in unforeseeable circumstances, your personal data can also be transferred to public institutions specified in the laws (such as administrative authorities like Ministries) within the limits and for the purposes specified by law, if requested as clearly stated in the laws.

Apart from our legal obligations that do not require disclosure and your explicit consent; some information related to your actions, choices, and preferences on the website processed through third-party cookie providers can be transferred via cookies. For detailed information, you can review the 'Information on Cookies'.

Due to the necessity of processing personal data of the parties to a contract, which is directly related to the establishment or execution of a contract as regulated under Article 5/2c of the PDPL:Conducting Storage and Archiving Activities and Managing and Monitoring Activities Related to Members


Conducting Storage and Archiving Activities and Managing and Monitoring Activities Related to Members

In accordance with the Otorento Website User Agreement to be concluded/has been concluded with you; 


Identity (Surname, Name, Turkish ID Number, Date of Birth, Gender, Not a Turkish Citizen), Communication (Phone Number (Mobile), Email Address, Permission for Commercial Electronic Communication), Travel Information (Flight Details), Transaction Security (User ID, Password), Legal Process (Clarification Text Read Information, Explicit Consent Approval, Data Deletion Request)


For the Purpose of Conducting Information Security Processes

If you log in via Facebook or Google:

Identity (Surname, Name), Communication (Email Address), Transaction Security (User ID, Username), Visual and Audio Records (Photograph)


Due to the necessity for the data controller to fulfill their legal obligations as specified under PDPL Article 5/2c:



For the Purposes of Conducting Communication, Advertising, and Marketing Processes, and Conducting Storage and Archiving Activities

In accordance with the Regulation on Commercial Communication and Commercial Electronic Messages - Approval Records (Article 13);

Communication (Permission for Commercial Electronic Communication)

For the Purposes of Conducting Product/Service Production, Operation, and Sales Processes, and Conducting Storage and Archiving Activities

In accordance with the Regulation on Service Providers and Intermediary Service Providers in Electronic Commerce - Obligation to Store Electronic Records (Article 11/2): 

Identity (Surname, Name, Gender), Communication (Phone Number (Mobile), Email Address), Finance (Payment Information), Customer Transaction (Records related to e-commerce)


If you have given your explicit consent under PDPL Article 5/1



For the Purposes of Conducting Communication, Advertising, and Marketing Activities

If you request the sending of commercial electronic messages:

Communication (Permission for Commercial Electronic Communication)






Membership

If You Are Registering as a Member on the Website

Related Person

You, whose personal data are processed by Otorento due to your membership on the website, are identified as the Person Receiving Products or Services and also recognized as the Related Person by the Law.

Your Processed Personal Data, Purposes of Processing, and Legal Reasons

Transfer of Your Personal Data

Your personal data can be transferred to relevant authorities without the need for disclosure obligations and without seeking your explicit consent, as requested within the scope of PDPL Article 28/1. Additionally, in unforeseeable circumstances, your personal data can be transferred to public institutions specified in the laws (such as administrative authorities like Ministries) within the limits and for the purposes specified by law, if clearly stated and requested in the laws.

Outside our legal obligations that do not require disclosure and your explicit consent;

If you wish to log in to the website or mobile application via Facebook or Google, your login details can be shared with Google or Facebook providers located abroad for the purpose of carrying out your identity verification processes.


Car Rental

If You Wish to Rent a Car

Related Person

You, whose personal data are processed by Otorento due to your inquiry about renting a car, are identified as the Person Receiving Products or Services and also recognized as the Related Person by the Law.

Your Processed Personal Data, Purposes of Processing, and Legal Reasons

Personal Data

Purposes of Processing

Legal Reason

Identity (Surname, Name, Turkish Identification Number, Date of Birth), Communication (Phone Number (Mobile), Email Address), Customer Transaction (Pick-up Location, Drop-off Location, Pick-up Date, Drop-off Date, Pick-up Time, Drop-off Time, Rented Vehicle Information, Added Assurances, Purchased Additional Services, Rental Conditions)


  • For the purposes of conducting service operations and sales processes, and for conducting storage and archiving activities,

under PDPL Article 5/2c, directly related to the establishment or performance of a contract, necessitating the processing of personal data belonging to the parties of the contract,

in accordance with the Website Use (Inquiry) Agreement to be entered into with you, and

due to the necessity for the data controller to fulfill its legal obligations under PDPL Article 5/2ç,

pursuant to the obligation to retain electronic records as stipulated in the Regulation on Service Providers and Intermediary Service Providers in Electronic Commerce (Article 11/2).

Identity on the Invoice (Surname, Name, Turkish ID Number), Address (Province, District), Customer Transaction (Sold Product/Service, Amount)

  • For the purposes of conducting financial and accounting tasks, sales processes of goods/services, and storage and archiving activities

due to the necessity for the data controller to fulfill its legal obligations under PDPL Article 5/2ç,

pursuant to the obligation to issue invoices and delivery notes under the Tax Procedure Law (Law No: 213) (Article 230/1 clause 5 and Article 232/1); the obligation to issue e-archive invoices under the General Communiqué of the Tax Procedure Law (sequential No:433) (Article 3/b); and the obligation to preserve tax-related books and documents under the Tax Procedure Law (Article 253).


Transfer of Your Personal Data

Your personal data can be transferred to relevant authorities without the need for disclosure obligations and without seeking your explicit consent, as requested within the scope of PDPL Article 28/1.

Additionally, in unforeseeable circumstances, your personal data can be transferred to public institutions specified in the laws (such as Ministries and other administrative authorities) within the limits and for the purposes specified by the law, if explicitly requested in the laws.

Outside of our legal obligations that do not require disclosure and do not require your explicit consent;

The table below shows your personal data that are transferred, the recipients, and the purposes of the transfer.

Recipient / Purpose

Data

To the Car Rental Company for the purpose of providing car rental services

Identity (Surname and Name), Communication (Phone Number (Mobile) and Email Address), Travel Information (Flight Number), Customer Transaction (Pick-up Location, Drop-off Location, Pick-up Date, Drop-off Date, Pick-up Time, Drop-off Time, Rented Vehicle Information, Added Assurances, Purchased Additional Services, and Rental Conditions);

To the E-Invoice Integrator for the purpose of issuing e-invoices

Identity (Surname, Name, and Turkish ID Number), Address (Province and District), Customer Transaction (Sold Product/Service and Amount);

Your personal data will be transferred. 

Additionally, the identity information of the person renting the vehicle and information related to the rented vehicle will be transferred to the General Directorate of Security for the purpose of providing information to authorized persons and institutions by the car rental company.

Communication

If You Are Contacting Us Through the Contact Form on Our Website

Related Person

You, whose personal data are processed by Otorento, are identified as a Visitor and also recognized as the Related Person by the Law, due to your visit to our website and your desire to contact us through the contact form.

Your Processed Personal Data, Purposes of Processing, and Legal Reasons

Personal Data

Purposes of Processing

Legal Reason

Identity

(Name, Surname)

Contact

(Email address, phone number)

Customer Transaction

(Your message, Related service)

  • Conducting Communication Activities

  • Conducting Customer Relationship Management Processes

  • Conducting Service Operation Processes and

  • Conducting Storage and Archive Activities Purposes


In accordance with Article 5/2c of the Law on the Protection of Personal Data (KVKK), it is necessary for the processing of personal data belonging to the parties of the contract, provided that it is directly related to the establishment of the contract, and in accordance with Article 5/2f of the KVKK due to our legitimate interests.

Transfer of Your Personal Data

Your personal data may be transferred to the relevant authorities without the obligation to inform and without requiring your explicit consent, within the framework of Article 28/1 of the Law on the Protection of Personal Data (KVKK) when requested.

In addition, in unforeseen circumstances, your personal data may be transferred to public institutions specified in the laws (administrative authorities such as Ministries) within the scope of the purposes and limitations specified in the law, when requested as explicitly stated in the laws.

Apart from our legal obligations that do not require informing you and obtaining your explicit consent; it is possible to share your personal data with our relevant suppliers for the purpose of conducting transactions depending on your request.


If you are contacting us via WhatsApp.

We kindly ask you to read the Clarification Text on the Processing of Personal Data below to review in detail our purposes for processing your personal data and your rights in this context. 

a) Data Controller

In accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”) your personal data is processed by .... (“Company”) as the data controller, within the scope described below.

Categories and Types of Personal Data Subject to Processing

Purposes of Processing Your Personal Data

Methods and Legal Grounds for Collecting Your Personal Data

Identity Information: Name-Surname 

Execution of Goods/Services Sales Support Processes, Execution of Customer Relationship Management Processes, Follow-up of Requests/Complaints

Your personal data, automatically collected through the Company's WhatsApp chatbot conversations, are processed based on the legal ground "Processing of data 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" as specified in Article 5 of the KVKK.

Contact Information: Mobile PhoneEmail Address

Execution of Goods/Services Sales Support Processes, Execution of Customer Relationship Management Processes, Follow-up of Requests/Complaints

Your personal data, automatically collected through the Company's WhatsApp chatbot conversations, are processed based on the legal ground "Processing of data 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" as specified in Article 5 of the KVKK.

Other - User Transaction Information: Requests, Complaints, and other information to be determined by the user

Execution of Goods/Services Sales Support Processes, Execution of Customer Relationship Management Processes, Follow-up of Requests/Complaints

Your personal data, automatically collected through the Company's WhatsApp chatbot conversations, are processed based on the legal ground "Processing of data 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" as specified in Article 5 of the KVKK.

b) Purposes, Methods, and Legal Grounds for Processing Personal Data

c) To Whom and for What Purposes Your Processed Personal Data May Be Transferred

Your personal data may be transferred to the following third parties for the purposes specified below:

Domestic Third Parties

Categories and Types of Personal Data That May Be Transferred

Purpose of Transfer

All Our Suppliers

All personal data listed in section b above

Execution of Goods/Services Sales Support Processes, Execution of Customer Relationship Management Processes, Follow-up of Requests/Complaints



Methods of Obtaining Your Personal Data

Your personal data is obtained through digital environments via Otorento.com.tr website by automatic or partially automatic methods. These acquisition processes occur through methods such as entering the website, filling out forms, or collecting some of your information through cookies.

Automatic data processing refers to processing activities that occur spontaneously without human intervention, carried out by devices such as computers, phones, through software or hardware features based on pre-prepared algorithms. Partially automatic data processing, on the other hand, is a personal data processing activity that involves human influence but is carried out through devices such as computers, similar to automatic data processing.

Your Rights Regarding Your Personal Data


To exercise your rights regarding your personal data, you must first apply to the data controller. According to Article 14 of the Law, it is not possible to directly file a complaint with the Personal Data Protection Board.


According to the law, regarding your personal data:

a) You have the right to learn whether your personal data is being processed or not.

b) If your personal data has been processed, you have the right to request information about it.

c) You have the right to learn the purpose of processing your personal data and whether they are used in accordance with that purpose.

ç) You have the right to know the third parties to whom your personal data are transferred, whether domestically or abroad.

d) If your personal data is incomplete or incorrectly processed, you have the right to request their correction.

e) If the reasons requiring processing cease to exist, you have the right to request the deletion or destruction of your personal data.

f) You have the right to request the third parties to whom your personal data have been transferred to be informed about the transactions made pursuant to subparagraphs (d) and (e).

g) You have the right to object to any negative consequences arising from the analysis of your processed data solely through automatic systems.

ğ) In case you suffer damage due to the unlawful processing of personal data, you have the right to request compensation for the damage by applying to our company, the data controller.


You can exercise these rights by applying to our company, the data controller.


Method of Application to the Data Controller

You can submit your application using one of the following methods:

Written Application: You can send your application in writing to the address: Göztepe, Pembe Köşk Apt, Fahrettin Kerim Gökay Cd 246/5 A Blok, 34730 Kadıköy/İstanbul.

Electronic Application:

a. You can submit your application using a secure electronic signature or mobile signature.

b. You can send an email to "info@otorento.com.tr" using the email address you previously provided and registered in our system.

Your application must include the following information:


Your name, surname, and signature if the application is in writing,

For Turkish citizens, your Turkish Republic identification number (T.C. kimlik numarası), or for foreigners, your nationality, passport number, or if available, your identification number,

Your residential or business address for notification purposes,

If available, your email address, telephone, and fax number for notification,

It is mandatory to specify the subject of your request, and if applicable, relevant information and documents related to the subject should be attached to the application.

Your application will be processed within thirty days, and:

(i) You will be informed if your request is accepted or

(ii) It may be rejected with an explanation of the reasons.


For more detailed information on the procedures and principles to be followed when making the application, you can refer to the "Communiqué on Principles and Procedures for Application to the Data Controller" by the Personal Data Protection Authority (https://www.resmigazete.gov.tr/eskiler/2018/03/20180310-6.htm).





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Fahrettin Kerim Gökay Cad. Pembe Köşk Apt. No:246/5 A Blok Göztepe / İstanbul

info@otorento.com.tr

444 30 09

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Fahrettin Kerim Gökay Cad. Pembe Köşk Apt. No:246/5 A Blok Göztepe / İstanbul

info@otorento.com.tr

444 30 09

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