Article version 2018.97.0

PRIVACY NOTICE REGARDING PROCESSING OF VOLVO CAR TURKEY OTOMOBİL LİMİTED ŞİRKETİ’S CUSTOMERS

Effective from:

Published at:

Our dear Customers; On behalf of Volvo Car Turkey Otomobil Limited Şirketi (“Volvo” or “Company”), we would like to inform you on our practices and your rights within the scope of Law on Personal Data Protection no. 6698 (“KVKK”).

Within the framework provided under Article 10 of KVKK titled “Obligation of Data Controller to Inform” and Article 11 titled “The Rights of Data Subject”, by providing you with this Privacy Notice (“Privacy Notice”), we hereby would like to inform you on which purposes your data will be processed; to whom and with what purposes your processed data can be transferred; the method and legal reason of collecting personal data; and your other rights set out under Article 11 of KVKK.

Volvo places particular importance on ensuring privacy and security of the personal data that you provide us. In that regard, within the scope of information security standards and procedures, we take the technical and administrative safety measures necessary to safeguard your personal data against unauthorized access or loss, misuse, disclosure, alteration or destruction. Such safety measures are provided at a level appropriate to the possible risks, taking into account the technological resources. If personal data are damaged or retained by third parties as a result of attacks on the website and the system, even though Volvo has taken the necessary information security measures, Volvo will immediately inform you and the Personal Data Protection Board.

1. Credentials of the Data Controller

Data Controller is Volvo Car Turkey Otomobil Limited Şirketi, which is registered at the İstanbul Trade Registry under no. 422515, with Mersis no. 0925011785500014, located at Fatih Sultan Mehmet Mahallesi Poligon Caddesi Buyaka 2 Sit. 2. Kule No:8 B/14 K:4 34771 Tepeüstü Ümraniye-İstanbul.

2. Purposes of Processing of Personal Data

Your personal data are processed based on one or more of the personal data processing conditions specified in Article 5 of KVKK or based on your explicit consent, in accordance with the personal data processing principles specified in Article 4 of KVKK and other obligations imposed by the relevant legislation.

Your personal data can be processed within the personal data processing conditions and purposes set out in Articles 5 and 6 of KVKK based on purposes such as:

  • Carrying out the necessary work by our business units and/or partners in order to benefit our Customers from the products and services offered by our Company;
  • Creating and managing customer records;
  • Carrying out evaluation, analysis and risk management studies concerning Customers within the legal limits;
  • Customizing the products and services offered by our Company according our Customer’s liking, usage habits, and needs and making suggestions;
  • Making announcements on changes that may occur in our terms of service and electronic services;
  • Ensuring legal and commercial security of our Company and the persons with whom it has business relations;
  • Planning the work carried out with our business partners, authorized dealers, authorized services and suppliers;
  • Organization and follow-up of techniques such as vehicle test drive; - Determination and implementation of our Company’s commercial and business strategies;
  • Conducting market research and analysis, included customer satisfaction surveys;
  • Resolving customer complaints and processing data access or rectification requests;
  • Ensuring participation in competitions, prize draws, similar promotions and loyalty programs and managing such activities;
  • Creating and updating efficiency reports by obtaining information regarding customer-based developments;
  • In the event that an application is lodged for credit opportunities offered by the credit provider companies that we have contracted with for our products and/or services; follow-up, planning and implementation of credit evaluation transactions to be made by credit providers;
  • Facilitating the social media sharing function;
  • Planning and realizing customer-specific sales and marketing activities;
  • Follow-up and execution of legal procedures and communication processes with public authorities;
  • Planning information security processes, creating and managing information technologies infrastructure;
  • Pursuing business and operations, carrying out Company activities and procedures;
  • Managing customer relations and monitoring corporate governance activities;
  • Fulfillment of warranty obligations, monitoring car insurance and other insurance processes;
  • Carrying out financial, accounting and financial transactions including sales-related invoicing; realization of risk management;
  • Fulfillment of obligations regarding after-sales support; carrying out and follow-up of processes related to damage or accident, valuation, loss of value and other processes;
  • Sales and marketing of Volvo passenger and commercial vehicles along with their spare parts;
  • Contacting potential customers at fairs, roadshows, exhibitions, sponsorships and similar potential customer events organized in order to increase brand awareness; planning active visits and events and thus identifying potential consumers and informing consumers about campaigns;
  • Obtaining necessary information and approvals in line with the requests and inspections of regulatory and supervisory institutions and official authorities;
  • Identifying and defending legal rights; protecting activities, rights, privacy, security or property of ours or our business partners’ and/or yours or others’ such property; and applying available remedies or limiting our damage;
  • Building processes with you as our customers regarding the contractual procedures such as sales, pre-sales support, leasing; execution and follow-up of all necessary transactions; commencement, evaluation and conclusion of car leasing customers’ leasing applications, making risk assessment, execution of contractual procedures, in short, planning and execution of operational processes with respect to leasing;
  • Making risk management, ensuring business continuity, follow-up of contract processes or legal requests;
  • Planning and organizing activities in order to conduct market research, ensure and/or increase loyalty to products and services.

3. To Whom and For What Purposes Your Processed Data May Be Transferred

Provided that sufficient and effective measures are taken in accordance with the security and privacy principles determined in the legislation in order to ensure fulfillment of the above-mentioned purposes, your personal data can be transferred abroad and can be shared with our business partners at home or abroad, particularly Volvo and its direct and indirect subsidiaries, suppliers, shareholders, authorized dealers, logistics companies; event companies, digital agencies, call center service providers, audit companies, banks, financial institutions, insurance companies, consultancy firms assisting in areas such as law, tax etc., insurance companies and other business partners, our subsidiaries, third parties residing in Turkey and abroad from whom support is received in areas such as storage, archiving, information technologies (server, hosting, program, cloud computing), security, call center, sales and marketing; legally authorized public authorities and private individuals and institutions, and Volvo group companies located abroad within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of KVKK.

4. The Method and Legal Reason of Collection of Personal Data

Your personal data; All information and documents provided directly to Volvo by you, what you share in telephone or e-mail correspondences, during your visit to our workplace, at promotional and sponsorship events, through our other business partners or our authorized dealers and services, gathered from institutions and organizations or contracted dealers with which Volvo cooperates, from public authorities such as Turkish National Police or Risk Center or from any other third parties; on the condition that it is lawful, are collected by Volvo through your visits to our website, mobile applications and other similar channels either by automatic or non-automatic means, in written, oral or verbal media by means of Cookies and similar technologies by our Company’s general management, authorized dealers, authorized services, call center, Volvo’s and/or contracted institutions’ websites; and, for Volvo to ensure its activities, they are processed within the scope of the processing conditions and purposes specified under Articles 5 and 6 of KVKK and in accordance with the principles and procedures set out in other relevant legislation, due to lawful reasons mentioned herein this Privacy Notice and to fulfill our legal obligations.

5. Your Rights under KVKK

As per Article 11 of KVVK, you have the right to apply to Volvo and;

  • to learn whether your personal data are processed or not; - to request information if your personal data are processed;
  • to learn the purpose of your data processing and whether this data is used for intended Purposes;
  • to know the third parties to whom your personal data is transferred at home or abroad,
  • to request the rectification of the incomplete or inaccurate data, if any, and to request notification of such transactions made to that end to third parties whom your personal data have been transferred;
  • to request the erasure or destruction of your personal data if the reasons which require processing of personal data disappear, despite being processed in accordance with the Law No. 6698 and other legislation, and to request notification of such transactions made to that end to third parties whom your personal data have been transferred;
  • to object to the processing, exclusively by automatic means, of your personal data, which leads to an unfavorable consequence for you; - to request compensation for the damages arising from unlawful processing of your personal data.

As per Article 13 of KVKK, you can lodge your application to use your above-mentioned rights, by sending it to our e-mail address at info@volvocarturkey.com with secure electronic signature or by physically delivering a hand signed petition along with your identifying documents to us at Fatih Sultan Mehmet Mahallesi Poligon Caddesi Buyaka 2 Sit. 2. Kule No:8 B/14 K:4 34771 Tepeüstü Ümraniye-İstanbul or sending them to that address through a public notary. You can access the application form regarding your request at www.volvocars.com.tr. Volvo will conclude your requests regarding your rights free of charge as soon as possible and within 30 (thirty) days at the latest, depending on the nature of your request. If an additional cost is incurred by Volvo for the conclusion of the request, the fees in the tariff determined by the Personal Data Protection Board may be requested by Volvo. In cases where your personal data are processed with explicit consent, we would like to emphasize that if you withdraw your explicit consent, you will be removed from the membership/loyalty program where such explicit consent-based processing is required and you will not be able to benefit from the advantages you have benefited due to such processing as of the relevant date. You can always follow the changes within the scope of legislation and our practices regarding personal data from the relevant page of our website.

The User/Users accept and declare that that the correctness and up-to-date preservation of the information they share on the website is important for them with respect to exercising their rights over their personal data within the meaning of the Law on the Protection of Personal Data No. 6698 and other relevant legislation, and that they will be entirely responsible for providing false information.

Your personal data processed for the purposes specified herein this Privacy Notice will continue to be used upon they are anonymized by us once the purpose that requires processing under the relevant provisions of KVKK disappears and the periods determined by law as per Article 138 of the Turkish Penal Code passes.

Volvo may make changes to this Privacy Notice at any time. These changes will become effective immediately upon the posting of the amended new Privacy Notice on www.volvocars.com.tr.

You can forward all your requests with regards to KVKK to our e-mail address at .

You can use this document for your applications.