Personal Data Processing For Marketing Activities Information Notice Relating To The Processing Of Personal Data

Effective from: 2018-04-07
Published at: 2026-02-18

This information notice is provided by Volvo Car Turkey Automobile Ltd. Şti. (hereinafter referred to as Volvo Car Turkey, the Company, or the Data Controller), located at “Fatih Sultan Mehmet Mah. Poligon Cad. Buyaka2 Sitesi No:8B Kule2 Kat:4 Tepeüstü Ümraniye – İstanbul,” acting in its capacity as data controller, in accordance with Article 10 of the Personal Data Protection Law No. 6698 (hereinafter referred to as the Law) and the provisions of the Communique On Principles And Procedures To Be Followed In Fullfillment Of The Obligation To Inform, in order to inform you about the processing of your personal data.

a) Types of Personal Data We Collect and Our Purposes for Processing Personal Data

Your personal data specified in this information notice is obtained and processed in accordance with Articles 5 and 6 of the Law, in a manner that is lawful, fair, and transparent, and for specific, explicit, and legitimate purposes, in accordance with the principle of purpose limitation.

Our company takes the necessary care to ensure that the personal data it processes is accurate and up-to-date. In summary, your personal data is used to carry out the marketing processes of the products and services our company offers to our customers and potential customers, to make plans to ensure you obtain the maximum benefit, to inform you of opportunities specific to you regarding our products and services, to carry out promotional and advertising activities, to managing customer satisfaction and loyalty initiatives, to sending consumer surveys, to ensuring our activities comply with applicable legislation, to providing information to legally authorized institutions and organizations, to following up on legal matters and exercising our right of defense when necessary.

Detailed information regarding sending survey and discounts, campaigns, promotional activities, market research, and analysis is provided below under two separate headings. This enables us to process data, conduct general commercial transactions, and improve the consumer experience.

a. Sending Survey

Your personal data, including identity, contact, customer transaction, marketing, and transaction security information;  is procesed for the purposes of conducting activities related to surveys on customer satisfaction and corporate reputation, evaluating customer satisfaction with the vehicles they have purchased, assessing customer opinions regarding Volvo Car Turkey dealers and authorized service centers where they purchased vehicles and/or services, and obtaining information regarding complaints expressed by customers in surveys; to contact you for the purpose of conducting surveys to evaluate consumer performance through segmentation, to evaluate and report your responses to the surveys, and to plan improvement efforts to increase satisfaction and our corporate reputation in our products and services covered by the survey in line with your responses.

b. Discounts, Campaigns, Promotional Activities, Market Research and Analysis

Your identity information, contact information, marketing information, customer transaction information, and call center voice recordings are processed by our Company for the purposes of planning and executing the promotion and marketing processes of products and services within the scope of discount, campaign, and promotional activities, as well as market research and analysis studies; informing customers about discounts, campaigns, and other marketing advantages related to products and services; and planning and executing customer loyalty programs, planning and executing marketing strategies through market research and analysis activities for the sale and marketing of products and services, and contacting you for the purpose of providing information regarding discounts, campaigns, promotions, market research, and analysis studies conducted by our Company as part of its marketing activities.

In addition to the processing activities listed above, your contact data is processed for the purposes of displaying personalized advertisements via social media platforms and search engines, addressing, evaluating, and reporting all kinds of requests, complaints, questions, and opinions, taking the necessary actions by our Company in this regard, and conducting communication activities with you accordingly. 

c) Transfer of Your Personal Data

Your personal data may be transferred to our suppliers and business partners within the scope of the purposes specified above and for the purpose of ensuring the execution of the business, as well as to authorized public institutions and private individuals in order to fulfill our legal obligations as stipulated by law. In particular, for the purpose of fulfilling the purposes of personal data processing;

- Processors who generally support our activities, such as IT solution providers;

- The ability of our processors who support the provision of Consumer Surveys to use your personal data for any purpose other than providing the services on our behalf and in accordance with any applicable data processing agreement is limited by contract:

• Provision of Consumer Surveys.

• WhatsApp text communication.

• Maintenance Operations.

- Your personal data may be shared with Volvo Car Corporation, based in Sweden, and other companies within the same group of companies, if you have given your explicit consent;

- With our supplier located abroad, which operates in these areas for the purpose of carrying out storage activities and obtaining technical infrastructure services;

- To supplier companies providing call center services for the purpose of contacting you;

- To relevant dealers and/or authorized service centers for the purpose of evaluating the services provided by our dealers and authorized service centers serving you;

- For the purposes of conducting activities in accordance with applicable legislation, providing information to legally authorized institutions and organizations, following up on legal matters, and exercising our right of defense when necessary, your personal data may be transferred to relevant ministries, courts, enforcement offices, legally authorized private individuals and organizations, and legally authorized public institutions.

d) Method and Legal Basis for Collecting Your Personal Data

Our company collects your personal data from our website, through the contact and information request forms you fill out, through physical and digital environments via authorized dealers, through forms on social media accounts and search engines, and via email, telephone, SMS, and other devices, including telephone and call center conversations, and at events organized by or participated in by our company, through showrooms in physical and electronic environments, for the most practical and effective fulfillment of the purposes mentioned above.

Personal data collected by our company for the purposes and by the methods mentioned above may be processed and transferred based on the following legal grounds under Articles 5 and 6 of the Law:

All your personal data obtained in the context of conducting survey-related activities and specified above is processed by our Company based on the legal grounds of “your explicit consent” if you give your explicit consent, and is transferred to the persons and organizations specified above in the same manner if you give your explicit consent.

All of your personal data obtained by our company in the context of discount, campaign, and promotional activities, market research and analysis studies, and event management, as specified above, is processed based on the legal grounds of “your explicit consent” if you give your explicit consent, and is transferred to the persons and organizations specified above in the same manner if you give your explicit consent.

All your personal data processed for the purpose of ensuring the accuracy/up-to-date nature/integrity/uniqueness of your personal data, carrying out data governance processes, and, if you have given your explicit consent, carrying out marketing processes, as well as for the purpose of carrying out storage activities and obtaining technical infrastructure services, is transferred to supplier companies operating in these areas within the scope of the appropriate safeguards provided by the Law in accordance with the Law Article 5/2-f of the Law, which explicitly states “the existence of our legitimate interest” as the legal basis.

The processing of your personal data mentioned above is carried out for the purposes of planning and executing our company's commercial and/or business strategies, conducting risk analysis studies, performing, evaluating, and reporting internal audits, ensuring data governance, and executing information security processes, based on the legal grounds of “being expressly provided by the laws” as stated in Article 5/2-a of the Law, 5/2-ç of the Law, “fulfillment of our legal obligations,” and 5/2-f of the Law, “existence of our legitimate interest,” and are transferred to the persons and organizations mentioned above.

The processing of your personal data mentioned above is carried out for the purposes of ensuring that the activities specified above are conducted in accordance with applicable legislation, providing information to legally authorized institutions and organizations, following up on legal matters, and exercising our right of defense when necessary. This processing is based on the legal grounds set forth in Article 5/2-a of the Law, namely “being expressly provided for by law,” Article 5/2-ç of the Law, which states “fulfillment of our legal obligations,” and Article 5/2-e of the Law, which states “establishment, exercise, or protection of any right.”

e) Storage of Your Personal Data

Your feedback responses to consumer surveys will be stored for five (5) years from the moment you submit your response and will be anonymized at the end of this period. To protect the security of your responses, the feedback invitation provides you with a personalized survey that no one else can access. Security measures are in place on the survey website and our other data storage facilities to protect the information under your control from loss, misuse, and alteration. Only specific employees can access the personal information you provide to us. These individuals can only access the information for incident handling, data analysis, and quality control purposes.

f) Your Rights Regarding Your Personal Data

You, as the data subject, have the following rights under article 11 of the Law no. 6698:

•  the right to be informed of whether your personal data are processed or not,

•  if your personal data have been processed, the right to demand information thereon,

•  the right to learn the purpose of the processing of your personal data and whether such personal data are used in compliance with the purpose,

•  the right to know the third parties to whom your personal data are transferred within the country or abroad,

•  the right to request the rectification of the incomplete or inaccurate data, if any, and to request the reporting of such rectification to the third parties to whom the personal data have been transferred,

•  the right to request the erasure or destruction of your personal data if the reasons requiring the processing of your personal data cease to exist despite the performance of the processing in line with the Law no. 6698 and the provisions of other applicable laws, and the reporting of such erasure or destruction to the third parties to whom the personal data have been transferred,

•  the right to object to the occurrence of a result that is unfavourable for you by means of analysis of the data processed solely through automated systems,

•  the right to claim compensation for the damage arising from the processing of your personal data contrary to the Law no. 6698.

You may send your requests as to your rights in writing to our Company's address at “Fatih Sultan Mehmet Mah. Poligon Cad. Buyaka2 Sitesi No:8B Kule2 Kat:4 Tepeüstü Ümraniye – Istanbul” or by e-mail as per the "Communiqué on the Procedures and Principles for Application to the Data Controller". Your applications will be replied in writing or electronically in the shortest time possible and latest within 30 (thirty) days depending on the nature of the request. Your application will be handled free-of-charge. If, however, the requested process gives rise to any additional cost, the charges in the tariff set forth by the Personal Data Protection Board will be claimed from the applicant.