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Regarding the Processing of Personal Data

Drivee SafeCall System User Information Notice

Data Controller

Drivee Technology Automotive Fleet Leasing Trade Joint Stock Company

Gursel Mah. Imrahor Caddesi No:29 Premier Campus Plaza A Block Office 87 Kagithane / Istanbul

As Drivee Technology Automotive Fleet Leasing Trade Joint Stock Company ("Drivee"), this information notice has been prepared to inform employees and authorized persons of entities receiving products or services about the processing, storage, and transfer of personal data through the Drivee SafeCall System in accordance with the Law on the Protection of Personal Data No. 6698 ("KVKK") and related legislation.

1. Which Personal Data Are Processed?

A. Regarding employees who receive products or services within activities carried out through the Drivee SafeCall System

The following personal data categories are processed for employees of customers receiving products or services:

Special categories of personal data require a higher level of protection compared to other data categories.
In accordance with the KVKK, additional disclosure is provided for processing special categories of personal data.

Identity Information
Processed Data:
• Full name
• Vehicle plate information
• Gender
• Date of birth
• Driver's license number
• Signature
• Signature circular
• Marital status
• Turkish ID number
Processing Purposes:
• Management of emergency response processes
• Management of information security processes
• Management of access authorizations
• Carrying out activities in compliance with legislation
• Management of finance and accounting affairs
• Management of communication activities
• Execution and supervision of business activities
• Execution of goods and services sales processes
• Execution of post-sales support services
• Execution of goods and services production and operation processes
• Execution of customer relationship management processes
• Execution of customer satisfaction activities
• Execution of contract processes
• Tracking requests and complaints
• Execution of supply chain management processes
• Providing information to authorized persons, institutions, and organizations
Legal Grounds:
Your identity data is processed under Article 5 of the KVKK based on the following legal grounds:
• Explicitly stipulated by laws
• Necessary for the establishment or performance of a contract directly related to the data subject
• Necessary for the data controller to fulfill its legal obligation
Collection Methods:
• Printed forms
• Information systems and electronic devices
• Email
• Electronic systems and applications
• Data subject declaration
• Existing data usage
• Phone
• Contracts

Contact Information
Processed Data:
• Full name
• Email address
• Phone number
Processing Purposes:
• Management of emergency response processes
• Management of information security processes
• Management of access authorizations
• Carrying out activities in compliance with legislation
• Management of finance and accounting affairs
• Management of communication activities
• Execution and supervision of business activities
• Execution of goods and services sales processes
• Execution of post-sales support services
• Execution of goods and services production and operation processes
• Execution of customer relationship management processes
• Execution of customer satisfaction activities
• Execution of contract processes
• Tracking requests and complaints
• Execution of supply chain management processes
• Providing information to authorized persons, institutions, and organizations
Legal Grounds:
Your contact data is processed under Article 5 of the KVKK based on the following legal grounds:
• Explicitly stipulated by laws
• Necessary for the establishment or performance of a contract directly related to the data subject
• Necessary for the data controller to fulfill its legal obligation
Collection Methods:
• Printed forms
• Information systems and electronic devices
• Email
• Electronic systems and applications
• Data subject declaration
• Existing data usage
• Phone
• Contracts

Personal Information
Processed Data:
• Company information
• Employment start date
• Employment end date
• Position and title
• Personal rights and benefits information
• Request information
Processing Purposes:
• Execution of access authorization processes
• Execution of communication activities
• Execution and supervision of business activities
• Execution of goods and services sales processes
• Execution of post-sales support services
• Execution of goods and services production and operation processes
• Execution of contract processes
• Execution of supply chain management processes
Legal Grounds:
Your personal information is processed under Article 5 of the KVKK based on the following legal ground:
• Necessary for the establishment or performance of a contract directly related to the data subject
Collection Methods:
• Printed forms
• Information systems and electronic devices
• Email
• Electronic systems and applications
• Data subject declaration
• Existing data usage
• Contracts

Financial Information
Processed Data:
• IBAN information
Processing Purposes:
• Management of finance and accounting affairs
• Execution of communication activities
• Execution and supervision of business activities
• Execution of goods and services sales processes
• Execution of goods and services production and operation processes
• Execution of customer relationship management processes
• Execution of contract processes
Legal Grounds:
Your financial data is processed under Article 5 of the KVKK based on the following legal ground:
• Necessary for the establishment or performance of a contract directly related to the data subject
Collection Methods:
• Email

Transaction Security Information
Processed Data:
• Network traffic data
• Device IMEI number
• Device MAC address
• IP address
• Website login and logout records
• Username and password information
• Log records
Processing Purposes:
• Execution of information security processes
• Execution of access authorization processes
• Execution of activities in compliance with legislation
• Execution and supervision of business activities
• Execution of communication activities
• Execution of goods and services production and operation processes
• Execution of contract processes
Legal Grounds:
Your transaction security data is processed under Article 5 of the KVKK based on the following legal grounds:
• Explicitly stipulated by laws
• Necessary for the data controller to fulfill its legal obligation
Collection Methods:
• Information systems and electronic devices
• Electronic systems and applications
• Data subject declaration
• Existing data usage

Physical Facility Security Information
Processed Data:
• CCTV records
Processing Purposes:
• Execution of audit and ethics activities
• Ensuring physical facility security
• Execution and supervision of business activities
• Ensuring security of movable property and resources
• Ensuring security of data controller operations
Legal Grounds:
Your physical security data is processed under Article 5 of the KVKK based on the following legal ground:
• Necessary for the legitimate interests of the data controller, provided that fundamental rights and freedoms are not harmed
Collection Methods:
• CCTV devices

Visual and Auditory Recordings
Processed Data:
• Photographs
• Audio records
Processing Purposes:
• Execution of emergency management processes
• Execution of access authorization processes
• Execution and supervision of business activities
• Execution of communication activities
• Execution of post-sales support services
• Execution of goods and services production and operation processes
• Execution of customer relationship management processes
• Execution of customer satisfaction activities
• Execution of contract processes
• Tracking requests and complaints
• Providing information to authorized persons, institutions, and organizations
Legal Grounds:
Your visual and auditory recordings are processed under Article 5 of the KVKK based on the following legal grounds:
• Necessary for the establishment or performance of a contract directly related to the data subject
• Necessary for the legitimate interests of the data controller, provided that fundamental rights and freedoms are not harmed
Collection Methods:
• Electronic systems and applications
• Data subject declaration
• Existing data usage
• Phone

Family Member Information
Processed Data:
• Family member identity and contact information (name, surname, gender, phone, address, relationship type)
Processing Purposes:
• Execution and supervision of business activities
• Execution of post-sales support services
• Execution of goods and services production and operation processes
• Execution of contract processes
Legal Grounds:
Your family member information is processed under Article 5 of the KVKK based on the following legal grounds:
• Necessary for the establishment or performance of a contract directly related to the data subject
• Necessary for the legitimate interests of the data controller, provided that fundamental rights and freedoms are not harmed
Collection Methods:
• Electronic systems and applications
• Data subject declaration
• Existing data usage

Customer Transaction Information
Processed Data:
• Vehicle information (plate, brand-model, daily mileage, vehicle score, inspection and maintenance, tire, fuel, motor vehicle tax)
• Device serial number
• Access and entry authorization
• User status information
• Customer number
• Travel information (trip count, risky driving count, first/last trip date, last signal date, max distance, max duration, start/end, trip duration, distance, alarm count, trip score, average speed, trip detail, accident and warning data)
• Driver score information
• Driving information (idle time, maximum idle time, total mileage, turning, speed and braking data)
• Chassis number
• Request and complaint information
Processing Purposes:
• Execution of access authorization processes
• Execution of communication activities
• Execution and supervision of business activities
• Execution of post-sales support services
• Execution of goods and services production and operation processes
• Execution of customer relationship management processes
• Execution of customer satisfaction activities
• Execution of contract processes
• Tracking requests and complaints
• Execution of supply chain management processes
Legal Grounds:
Your customer transaction data is processed under Article 5 of the KVKK based on the following legal ground:
• Necessary for the establishment or performance of a contract directly related to the data subject
Collection Methods:
• Printed forms
• Electronic systems and applications
• Email
• Data subject declaration
• Existing data usage
• Contracts
• Phone

Location Information
Processed Data:
• Current location data
Processing Purposes:
• Execution of emergency management processes
• Execution of communication activities
• Execution and supervision of business activities
• Execution of post-sales support services
• Execution of customer relationship management processes
• Providing information to authorized persons, institutions, and organizations
Legal Grounds:
Your location data is processed under Article 5 of the KVKK based on the following legal ground:
• Necessary for the establishment or performance of a contract directly related to the data subject
Collection Methods:
• Drivee device
• Electronic systems and applications

Other Information (Emergency Contact)
Processed Data:
• Emergency contact information (name, surname, degree of kinship, email, phone, address)
Processing Purposes:
• Execution of emergency management processes
• Execution of access authorization processes
• Execution and supervision of business activities
• Execution of post-sales support services
• Execution of goods and services production and operation processes
• Execution of contract processes
Legal Grounds:
Your emergency contact data is processed under Article 5 of the KVKK based on the following legal grounds:
• Necessary for the establishment or performance of a contract directly related to the data subject
• Necessary for the legitimate interests of the data controller, provided that fundamental rights and freedoms are not harmed
Collection Methods:
• Electronic systems and applications
• Data subject declaration
• Existing data usage

Health Information (Special Category)
Processed Data:
• Blood type
• Allergic reactions
• Chronic diseases
• Surgeries
• Medications used
• Health insurance number and provider
• Health documents and explanatory information
Processing Purposes:
• Execution and supervision of business activities
• Execution of post-sales support services
• Execution of goods and services production and operation processes
• Execution of contract processes
Legal Grounds:
Your health data is processed under paragraph 2 of Article 6 of the KVKK based on the following legal ground:
• Explicit consent
Collection Methods:
• Electronic systems and applications
• Data subject declaration
• Existing data usage

B. Regarding authorized persons of entities receiving products or services within activities carried out through the Drivee SafeCall System

The following personal data categories are processed for authorized representatives of customers receiving products or services:

Identity Information
Processed Data:
• Full name
• Signature
• Signature circular
• Stamp
• Turkish ID number
• Tax identification number
Processing Purposes:
• Execution of information security processes
• Execution of access permissions
• Execution of activities in compliance with legislation
• Execution of finance and accounting affairs
• Tracking and execution of legal affairs
• Execution of communication activities
• Execution and supervision of business activities
• Execution of goods and services sales processes
• Execution of post-sales support services
• Execution of goods and services production and operation processes
• Execution of customer relationship management processes
• Execution of customer satisfaction activities
• Execution of contract processes
• Tracking requests and complaints
• Providing information to authorized persons, institutions, and organizations
Legal Grounds:
Your identity data is processed under Article 5 of the KVKK based on the following legal grounds:
• Explicitly stipulated by laws
• Necessary for the establishment or performance of a contract directly related to the data subject
• Necessary for the data controller to fulfill its legal obligation
Collection Methods:
• Printed forms
• Information systems and electronic devices
• Official channels
• Email
• Electronic systems and applications
• Data subject declaration
• Existing data usage
• Phone
• Contracts

Personal Information
Processed Data:
• Working hours information
• Position and title information
• Request information
Processing Purposes:
• Execution of access permissions
• Execution of activities in compliance with legislation
• Execution of finance and accounting affairs
• Execution and supervision of business activities
• Execution of communication activities
• Execution of goods and services sales processes
• Execution of post-sales support services
• Execution of goods and services production and operation processes
• Execution of contract processes
Legal Grounds:
Your personal information is processed under Article 5 of the KVKK based on the following legal ground:
• Necessary for the establishment or performance of a contract directly related to the data subject
Collection Methods:
• Email
• Electronic systems and applications
• Data subject declaration
• Existing data usage
• Contracts

Financial Information
Processed Data:
• Bank account information
• IBAN information
• Payment information
• Collateral information
Processing Purposes:
• Execution of activities in compliance with legislation
• Execution of finance and accounting affairs
• Tracking and execution of legal affairs
• Execution of communication activities
• Execution and supervision of business activities
• Execution of goods and services sales processes
• Execution of goods and services production and operation processes
• Execution of customer relationship management processes
• Execution of contract processes
• Providing information to authorized persons, institutions, and organizations
Legal Grounds:
Your financial data is processed under Article 5 of the KVKK based on the following legal ground:
• Necessary for the establishment or performance of a contract directly related to the data subject
Collection Methods:
• Printed forms
• Email
• Data subject declaration
• Existing data usage
• Phone

Transaction Security Information
Processed Data:
• Network traffic data
• Device IMEI number
• Device MAC address
• IP address
• Website login and logout records
• Username and password information
• Log records
Processing Purposes:
• Execution of information security processes
• Execution of access permissions
• Execution of activities in compliance with legislation
• Execution of assignment processes
• Execution and supervision of business activities
• Execution of communication activities
• Execution of goods and services production and operation processes
• Execution of contract processes
Legal Grounds:
Your transaction security data is processed under Article 5 of the KVKK based on the following legal grounds:
• Explicitly stipulated by laws
• Necessary for the data controller to fulfill its legal obligation
Collection Methods:
• Information systems and electronic devices
• Electronic systems and applications
• Data subject declaration
• Existing data usage

Physical Facility Security Information
Processed Data:
• CCTV recording data
Processing Purposes:
• Execution of audit and ethics activities
• Ensuring physical facility security
• Execution and supervision of business activities
• Ensuring security of movable property and resources
• Ensuring security of data controller operations
Legal Grounds:
Your physical security data is processed under Article 5 of the KVKK based on the following legal ground:
• Necessary for the legitimate interests of the data controller, provided that fundamental rights and freedoms are not harmed
Collection Methods:
• CCTV devices

Visual and Auditory Recordings
Processed Data:
• Audio records
Processing Purposes:
• Execution of communication activities
• Execution of post-sales support services
• Execution of customer relationship management processes
• Execution of customer satisfaction activities
• Tracking requests and complaints
Legal Grounds:
Your visual and auditory recordings are processed under Article 5 of the KVKK based on the following legal grounds:
• Necessary for the establishment or performance of a contract
• Necessary for the legitimate interests of the data controller, provided that fundamental rights and freedoms are not harmed
Collection Methods:
• Phone

Customer Transaction Information
Processed Data:
• Vehicle information (brand-model, daily mileage, vehicle score, inspection and maintenance, tire, fuel, and motor vehicle tax information)
• Travel information (alarm count, average speed, travel duration, travel detail warning information)
• Contract information (contract type, subject and amount, start and end dates)
• Request and complaint information
Processing Purposes:
• Execution of access rights
• Execution of communication activities
• Execution and supervision of business activities
• Execution of post-sales support services
• Execution of goods and services production and operation processes
• Execution of customer relationship management processes
• Execution of customer satisfaction activities
• Execution of contract processes
• Tracking requests and complaints
Legal Grounds:
Your customer transaction data is processed under Article 5 of the KVKK based on the following legal ground:
• Necessary for the establishment or performance of a contract
Collection Methods:
• Electronic systems and applications
• Email
• Data subject declaration
• Existing data usage
• Phone

2. To Whom and For What Purposes Can Your Personal Data Be Transferred?

Your personal data may be transferred domestically, in a limited and proportionate manner, for the following recipient groups and purposes:

Authorized Public Institutions and Organizations:
• Management of emergency processes
• Execution and supervision of business activities
• Execution of activities in compliance with legislation
• Providing information to authorized persons, institutions, and organizations

Suppliers:
• Management of emergency processes
• Execution of access authorizations
• Execution of activities in compliance with legislation
• Execution of finance and accounting affairs
• Tracking and execution of legal affairs
• Execution and supervision of business activities
• Execution of communication activities
• Execution of goods and services sales processes
• Execution of post-sales support services
• Execution of goods and services production and operation processes
• Execution of contract processes
• Execution of supply chain management processes

Natural Persons or Private Law Legal Entities:
• Execution of communication activities
• Execution and supervision of business activities
• Collection and evaluation of recommendations for improving business processes
• Execution of post-sales support services
• Execution of customer relationship management processes
• Execution of customer satisfaction activities
• Tracking requests and complaints

Business Partners:
• Execution of communication activities
• Execution and supervision of business activities
• Execution of post-sales support services
• Execution of customer relationship management processes

Transfers are made in compliance with Article 8 of the KVKK (or Article 9 for international transfers), only to the extent necessary for the relevant purpose, and with required technical and administrative safeguards.

3. How Long Will Your Personal Data Be Stored?

If a retention period is specified in legislation, your personal data is stored for at least that period. If no specific period is provided, your personal data is stored for a reasonable period determined in connection with processing purposes, and in a limited and proportionate manner.

4. What Are Your Rights Regarding Your Personal Data as the Data Subject?

Regarding your personal data, you have the right to:

  • Learn whether your personal data is processed
  • Request information if your personal data has been processed
  • Learn the purpose of processing and whether data is used in line with that purpose
  • Know third parties to whom your personal data has been transferred domestically or abroad
  • Request correction if your personal data is incomplete or inaccurate
  • Request deletion or destruction under KVKK conditions
  • Request notification of correction/deletion/destruction to transferred third parties
  • Object to unfavorable outcomes arising from automated analysis and request compensation if damage occurs due to unlawful processing

5. How Can You Exercise Your Rights as the Data Subject?

You may submit your applications and requests regarding personal data through the Data Subject Application Form using one of the following methods:

  • By sending a wet-signed petition with an ID copy to: Gursel Mah. Imrahor Caddesi No:29 Premier Campus Plaza A Block Office 87 Kagithane / Istanbul
  • By applying in person to Drivee Teknoloji Otomotiv Filo Kiralama Ticaret A.S. with a valid identity document
  • By sending via registered electronic mail (KEP) with secure electronic signature or mobile signature to: drivee.teknoloji@hs01.kep.tr
  • By signing with mobile signature or secure electronic signature and sending to: info@drivee.io
  • By sending from the email address previously declared by the data subject and registered in our systems to: info@drivee.io
  • Applications must include full name, signature (if written), Turkish ID number (or nationality and passport/ID number for foreigners), notification address, email address if available, phone/fax, and request details.
  • The request subject and the right to be exercised must be stated clearly and understandably; supporting documents must be attached.
  • If applying on behalf of another person, a documented authorization (power of attorney) is required. For special category data, specific authorization is required under relevant legislation.
  • Applications by unauthorized third parties on behalf of others are not processed.

6. How Soon Will Your Requests Be Answered?

Your requests are evaluated and answered as soon as possible and within 30 days at the latest after reaching Drivee. Responses are delivered by post, email, or if possible via the same method used in the request. If evaluation requires an additional cost, the fee determined by the Personal Data Protection Board tariff applies.