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YES CAR RENTAL AND TOURISM INVESTMENTS INC

CUSTOMER CLARIFICATION TEXT ON PROTECTION AND PROCESSING OF PERSONAL DATA

1. Data Officer

As Yes Car Rental and tourism investments Inc (‘Company’) - acting as Data Officer, we would like to inform our valued customers within the framework of our clarification obligation as per the Personal Data Protection Law No. 6698 (“KVKK”) with this clarification text on the protection and processing of this personal data (“clarification text”). 

Within the scope of KVKK, personal data refers to any information (“Personal Data”) of an identified or identifiable natural person, while Sensitive Personal Data -as a special type of this personal data- refers to race, ethnic origin, political opinion, philosophical belief, religion, sect, or other beliefs, costume and clothing, association or trade union membership, health, sexual life,  biometric data related with criminal convictions and security measures, and genetic data(“Sensitive Personal Data”). In this context, the definition of personal data also covers your Sensitive Personal Data. 

Within the scope of the Clarification Text “

Gürbaşlar Group

” refers to Gürbaşlar Automotive Industry and Trade Inc, Kavi Construction Industry and Trade Inc, Gürbaşlar Insurance Brokerage Services and Tourism Investments Company Limited and other companies which are owned by the real person's partners of Yes Car Rental and Tourism Investments 

[AAZ1]

Inc.

1. Method of Collecting Personal Data and Legal Grounds For Processing

Your personal data is collected in connection with your transactions with the company and for the purpose and scope set out in Section 4 below, by automatic or non-automatic means, oral, written and electronic means, and through the following methods and third parties with whom the company has an agreement.

1. As a result of your rental transactions at Enterprise Turkey sales points, verbally or in writing,
2. By means of visits, membership, registration and rental transactions that you have made through the company's websites,
3. Sales made at contracted outlets where the company expert works, through company employees located here and information forms filled out ,
4. Oral and written complaints made by customers to the global or Customer Contact Center through all sales points or social media and complaint platforms,
5. Through customer relationship management programs (CRM) and other customer programs,
6. Through the security cameras systems located at Enterprise Turkey sales points,
7. Through third parties from whom the company purchases services in relation to its customers and with whom it is contracted for a business relationship.

The legal reasons stated in 5th and 6th articles of the KVKK regarding the processing of Personal Data are as follows: 

1. If your explicit consent is available,
2. If it is explicitly prescribed in laws,
3. If it is mandatory for the protection of his/her or someone else's life or body integrity for person who is unable to disclose his consent due to actual impossibility or whose consent is not granted legal validity,
4. If personal data is processed in connection with the establishment or execution of a contract, 
5. If it is mandatory for the fulfillment of our legal obligations,
6. If it is publicized by the person concerned,
7. If data processing is mandatory for the establishment, exercise or protection of a right, and
8. If it is mandatory for our legitimate interests, provided that it does not harm your fundamental rights and freedoms.

1. Your Personal Data Collected

The Personal Data that we collect from you is your data that we process pro rata to the processing purposes specified in Section 4 below.

1. For What Purpose Personal Data will be Processed

Your Personal Data is processed by the company for the following purposes, based on your explicit consent or in other cases permitted legally under the scope of the KVKK:

1. Execution of the contractual and sales process with the customers under the scope of handling activities in compliance with the legislation and billing in this sense, and execution of other financial and accounting operations for the fulfillment of legal obligations(identification and contact information, customer transaction information, financial information, vehicle information), (legal grounds: being explicitly prescribed in laws, performance of the contract, when data processing is mandatory for the constitution, preservation and use of a right of property)
2. Rental and operational processes within the scope of the relationship with the customer made the execution of logistics activities (identification and contact information, location information, customer transaction information, financial information, vehicle information)
3. Communicating with the customer to provide support regarding the rental relationship, in order to manage the lease and / or commercial relationship with the customer (identification and contact information, customer transaction information, location information, financial Information, request/complaint management information, vehicle information), (legal grounds: performance of the contract, legitimate interest)
4. In cases where the customer or additional authorized driver is considered to pose a risk for future rentals as a result of an event within the scope of the rental relationship that involves the customer or authorized driver, keeping the information of such persons in the company records  (identification and contact information, customer transaction information, additional driver information), (legal grounds: performance of the contract, legitimate interest)
5. Within the scope of Ad/campaign/promotion processes and related communication activities, execution of the process of sending commercial electronic messages (campaign, advertising promotion, such as telephone, SMS, MMS, standard e-mail or in other ways) (identification and contact information, location information, customer transaction information, marketing information, vehicle information), (legal grounds: explicit consent)
6. Conducting marketing processes and analysis of products and services (identification and contact information, location information, customer transaction, marketing information, vehicle information), (legal grounds: express consent)
7. The execution of the customer satisfaction activities, including survey via telephone procedures (identification and contact information, marketing information, customer transaction information, request/complaint management information, vehicle information), (legal grounds: explicit consent)
8. Execution of procurement processes of vehicles within the scope of rental relationship (identification and contact information, location information, financial Information, vehicle information), (legal grounds: execution of contract)
9. Ensuring the safety of physical space (identification and contact information, location, physical space, safety information, visual and audio recordings), (Legal grounds: fulfillment our legal obligations, when data processing is mandatory for constitution, preservation and use of a right)
10. Execution of customer engagement processes including the membership via the website and sending a welcome e-mail pursuant to membership (identification and contact information, transaction safety information, marketing information), (legal grounds: explicit consent)
11. Execution of customer relationship management and follow-up and in-house reporting[AAZ4] of customers' request/complaints in this context, (identification and  contact information, location information, customer transaction information, transaction security information, financial information, request/complaint management information) (Legal grounds: the fulfilment of the contract, the fulfilment of our legal obligations, constitution, preservation and use of a right, when revealed by the relevant person)
12. Follow-up and execution of legal processes (identification and contact information, location information, customer transaction information, legal transaction information, physical location security information), (legal grounds: performance of the contract, establishment, constitution, use and preservation of a right, legitimate interest)
13. Execution of communication activities with customers for the purpose of managing customer relationships through the company's experts (identification and contact information, location information, customer transaction information, marketing information, vehicle information), (legal grounds: the performance of the contract, legitimate interest, explicit consent)
14. Providing information to authorized persons, institutions and organizations in the context of fulfilling legal obligations and requests of administrative authorities (identification information, contact information, location information, legal transaction information, customer transaction information, physical location security information, transaction security information, financial information, audio and visual records information, vehicle information), (legal grounds: fulfillment of our legal obligations, legitimate interest)

In addition, credit card and debit card information are processed (within the framework of security measures) for the purpose of completing payment transactions by our licensed partnet companies. 

1. To Whom and for What Purpose Personal Data may be Transferred

The company can transfer and / or grant access to customer's personal data domestically and abroad based on explicit consent (and within the framework of the purposes set out in Article 4) to the following entities: - service providers from which it receives security services and third parties from whom it receives support in other areas related to the activities of the Company (cloud computing, companies providing information technology support and similar);  during the rental relationship, and after the rental relationship in order to carry out the marketing processes; - Gürbaşlar Group companies as being part of the same economic integrity (belonging to the same / common real persons), for reasons such as securing availability of personnel services of whom are benefited from jointly, in connection with the rental relationship involving Gürbaşlar Group's common systems and other operational requirements; - authorized bodies and organizations in order to resolve legal disputes and fulfill legislative obligations and, upon request, to judicial authorities and / or relevant law enforcement agencies.The company may transfer overseas and/or grant access to its customers' contact information, location information, transaction information, legal, customer, process information, process safety information, financial information, marketing information, visual and auditory records, information request/complaint management information, vehicle information, as the Company utilizes information technology services located abroad, and because it has a franchising the relationship of the Enterprise Group [Enterprise Turkey, Enterprise EHI (EMEA) Ltd with which Enterprise Turkey has a franchising contract, and all (direct or indirect) subsidiaries and affiliates of Enterprise Holding, Inc (including EAN Data Services UK Limited and TSD Rental LLC)]

[1]

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1. Rights of the Owner of Personal Data under Article 11 of the KVKK

As the owner of personal data, in accordance with Article1 of the KVKK, you can request the following rights from the company acting as the data officer.

The rights you have in this context are as follows:

1. Knowing whether personal data is processed,
2. Requesting information if personal data has been processed,
3. Knowing the purpose of processing personal data and whether it is used for its purpose,
4. Knowledge of third parties -domectic or abroad- to whom personal data is transferred,
5. Requesting correction of the personal data if it is incomplete or incorrectly processed and request that the transaction made in this framework be notified to the third parties to whom the personal data is transferred,
6. Requesting deletion, destruction or anonymization of personal data within 30 (thirty) days, although it has been processed in accordance with the provisions of KVKK and other relevant laws, in case the reasons for processing disappear, and notification of related actions to third parties to whom personal data have been transferred, pursuant to the Regulations on the Deletion, Destruction or Anonymization of Personal Data,
7. Disputing adverse consequences emerging from analysis of the processed data exclusively through automated systems,
8. Requesting recovery of damages in case of damage due to unlawful processing of personal data.

The above-mentioned requests shall be forwarded to the company as data officer in writing or by other methods to be determined by the Personal Data Protection Board (‘Board’).

In this context, you may convey your requests related with above-mentioned rights via e-mail, which is given below and may change on occasion, from your registered electronic mail address, or your other email addresses bearing safe electronic signature or mobile signature, or through an email address that you have notified to the Company and registered to the Company's system (by attaching documents revealing your identity), or deliver by hand or through a notary public to our postal address below, which may also change from time to time, with documents identifying you and a wet signed petition.

In the application that you will make as the owner of the personal data to exercise your rights mentioned above and that contains the description of the right you intend to use; the issue you request must be clear and understandable, the issue must be related directly with you, or if you are acting on behalf of someone else, you must be specifically authorized to do so and certify this authority, and the application must contain your identity and address information.

The company concludes the claims contained in the application as soon as possible and no later than thirty days, free of charge (if there is no cost), depending on the nature of the request. However, if the transaction requires an additional cost, a fee may be charged in the tariff to be determined by the Personal Data Protection Board. If the answers to the applications exceed 10 (ten) pages, a transaction fee of $ 1.00 (one) will be charged for each page. If the answer is requested to be given in a recording medium such as a CD, flash memory, a fee will be charged according to the cost of the desired recording medium.

Data Officer               : Yes Car Rental and Tourism Investments Inc

Postal address          : Tem Otoyolu Kavacık Kavşağı, Gürbaşlar Plaza Kat:1 Rüzgarlıbahçe Beykoz İstanbul

E - mail address        : kvkk@enterprise.com.tr

YES CAR RENTAL AND TOURISM INVESTMENTS INC

EXPLICIT CONSENT AND APPROVAL TEXT FOR PERSONAL DATA PROTECTION 

Yes Car Rental and Tourism Investments Inc ("

Renting Comapny

") may process the customer's identity information, contact information, location information, marketing information, customer transaction information, vehicle information data in order to assist with the reservation and rental of vehicles, to carry out loyalty processes to the company and its products and to prepare in-house reports, to make phone calls and calls regarding customer satisfaction or information, and for marketing and customer relationship management analysis purposes. Marketing and customer analysis purposes involve sending commercial electronic message, analyzing customer's personal data for the purposes of customer relationship management, managing customer loyalty programs, increasing customer loyalty, planning and executing sales and marketing strategies, and fitting our products and services to customers' interests, needs and habits by making use of the personal data of customers. The company can transfer and / or grant access to customer's personal data domestically and abroad based on explicit consent to the following entities: - service providers from which it receives security services and third parties from whom it receives support in other areas related to the activities of the Company (cloud computing, companies providing information technology support and similar);  during the rental relationship, and after the rental relationship in order to carry out the marketing processes; - 

Gürbaşlar Group

 companies as being part of the same economic integrity (belonging to the same / common real persons), for reasons such as securing availability of personnel services of whom are benefited from jointly, in connection with the rental relationship involving Gürbaşlar Group's common systems and other operational requirements; - authorized bodies and organizations in order to resolve legal disputes and fulfill legislative obligations and, upon request, to judicial authorities and / or relevant law enforcement agencies.Furthermore, the company may transfer and/or grant access of the personal data of the customer mentioned above (based on consent) to 

Enterprise Group

 companies and to third party service provider (for example customer relationship management firms and companies that provide information services) in order the data be to used by the 

Group 

for the purposes mentioned above for the reason of maintaining the franchise relationship with the 

Enterprise Group

. Within the scope of this Explicit Consent Text,  “

Gürbaşlar Group

” refers to Gürbaşlar Automotive Industry and Trade Inc., Kavi Yapı Construction Industry and Trade Inc., Gürbaşlar Insurance Brokerage Services Limited Company and other companies owned by the real person partners of Yes Car Rental and Tourism Investments Inc; “

Enterprise Group

” refers to Enterprise Turkey, the EHI Franchising (EMEA) Ltd Company who has a franchising contract with Enterprise Turkey, and all direct or indirect subsidiaries and affiliates of Enterprise Holding Inc (including EAN Data Services UK Limited and TSD Rental LLC)

 .The customer agrees that he/she has read, understood the Clarification Text on the Protection of Personal Data and the processing of his/her personal data  for the purposes in this text and consents to the transfer of personal data to companies within the Enterprise Group located outside Turkey, as stated in the Clarification Text on the Protection of Personal Data.

Name: Date:Signature:

Customer's Approval On Electronic Commercial Messages

Customer agrees to receive electronic commercial messages (commercial messages, including but not limited to sales, special offers, promotions, invitations, advertisements and surveys) from 

Enterprise Group

 and companies within the Enterprise Group. “

Enterprise Group

” refers to Ehi Franchising (EMEA) Ltd with whom Enterprise Turkey has a franchising contract, and all direct or indirect subsidiaries and affiliates of Enterprise Holding, Inc. (including EAN Data Services UK Limited and TSD 

Rental LLC). A list of entities within Enterprise Group can be found here: 

https://www.enterprise.com/en/privacy-policy.html?icid=footer.legal-_-privacy-_-ENUS.NULL#DataControllers

 and https://www.enterprise.com/en/privacy-policy/licensees.html.

Name: Date:Signature: