Hedef Filo

It is our duty to protect the personal information and ideas you share with us by filling out forms on Hedeffilo.com. The principles below define how we evaluate and process this personal information and ideas.

Personal Data Protection Disclosure (Information Notice) and Privacy Policy

Identity of the Data Controller

As the data controller, Hedef Araç Kiralama ve Servis Anonim Şirketi (the “Company”), operating at Ofishane Merkez Mahallesi Cendere Caddesi No:22 Floor:12-13 34400 Kağıthane / Istanbul, hereby presents the following information to you within the scope of its obligation to inform, in order to ensure compliance with the Personal Data Protection Law (“Law”) regarding the personal data obtained from our customers/potential customers.

Purposes for Which Personal Data Are Processed

Your personal data may be collected physically and electronically, in accordance with the fundamental principles stipulated in the Law and the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law, due to your status as a Company customer, for reasons stipulated by law and for the performance of the contractual relationship, within the framework of carrying out our activities and operating and improving our services. The personal data you provide on this site, listed below (collectively referred to as “Your Data”);

Data related to your visit to and use of the site, (Data such as your IP address, geographical location, web browser type, referral source, duration of visit, and number of page/content views during your visit to our site)

Data related to all kinds of transactions and applications you perform through the site,

Data you provide to receive offers and to benefit from online (via web browser or application) services as well as operational and financial services, (Identity data including Turkish Identification Number, Temporary Turkish Identification Number, driver’s license information, passport information, tax number; contact data including phone number, e-mail address, address; vehicle data; suggestion and complaint data)

By the Company;

To recognize your computer when you visit the site and thus personalize the site to make your visit more efficient,

To understand your eligibility to receive an offer and to contact you regarding the matter,

To send offers until the contract process,

To obtain the information required for you to enter the credit committee process,

To communicate the collateral requests that will be requested from you as the output of the credit committee,

To receive feedback from you on these matters,

To share the contract with you for the purpose of establishing the contract. In the event that a contract is established following the provision of the relevant offer, the information mentioned above will also be used for the following purposes:

To carry out the offer preparation process and notify contract approval,

To manage the vehicle rental process and return procedures,

To carry out operational processes related to the vehicle during the rental period,

To perform invoicing during the rental period,

To inform the customer prior to the end of the contract.

Use of Cookies on the Website

Cookies are used on this website. A cookie is a text file sent by a web server to a web browser and stored by the browser; this file is sent back to the server every time the browser requests a page, thereby allowing the web server to recognize and track your browser. We state that we may send cookies to be stored on your computer’s hard drive and that we may use the information obtained from these cookies for site administration and to improve site usability. In addition, our advertising providers may also send you cookies. Most browsers have settings to block cookies. For this, you may review your browser’s help files. However, we would like to point out that if you do not accept cookies, you may significantly reduce usability when using many websites, including our site.

To Whom and For Which Purposes the Processed Personal Data May Be Transferred

Your collected data may be transferred, limited to the purposes explained in Article 2 of this Information Notice, to dealers, e-mailing companies, assistant companies, archiving companies, consultancy firms, insurance companies, suppliers, and legally authorized public institutions and private persons, within the framework of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law, and limited to the purposes stated in the Personal Data Protection and Processing Policy prepared by the Data Controller and published on www.hedeffilo.com and this Information Notice. In addition, your personal data may be transferred within the framework of Articles 8 and 9 of the Law, provided that necessary security measures are taken and limited to the purposes written in this Information Notice.

Security of Personal Data

In accordance with the relevant legislation in force, the Company, as the data controller, has assumed responsibility for establishing the necessary organization and taking and adapting technical measures to protect the confidentiality and integrity of information. In line with this obligation, we inform you that we periodically update our data processing policies. Necessary measures will be taken to prevent the loss, misuse, and alteration of your personal information and ideas. However, since data transmission over the internet is inherently insecure, the security of such data transmission cannot be guaranteed by us. Keeping your password confidential is your responsibility. The site administration cannot access your password without your information and consent.

Method and Legal Basis of Personal Data Collection

Your data may be collected through automatic or non-automatic means, due to the performance of a contractual relationship or for other reasons stipulated by law. Your data are collected by the Company through legal grounds aimed at fulfilling the purposes specified in Article 2 of this Information Notice, which constitute the basis for your disclosure of data to us. Your data collected on these legal grounds may be processed by the Company without obtaining your explicit consent, in accordance with Articles 5/2(c) and (e) of the Law, provided that it is directly related to the establishment or performance of a contract, and that processing personal data of the parties to the contract is necessary, and that it does not harm your fundamental rights and freedoms, and where data processing is mandatory for the legitimate interests of the Company. Based on your explicit consent, your data may also be processed and transferred for the purposes specified in Articles 2 and 3 of this Information Notice pursuant to Article 5/1 of the Law.

Rights of the Data Subject

Pursuant to Article 11 of the Law, employees whose personal data are processed may apply to Hedef Filo to submit requests regarding the following matters:

To learn whether personal data are processed,

To request information if personal data have been processed,

To learn the purpose of processing personal data and whether they are used in accordance with their purpose,

To know the third parties to whom personal data are transferred domestically or abroad,

To request correction of personal data if they are processed incompletely or inaccurately and to request notification of such correction to third parties to whom the personal data have been transferred,

To request deletion, destruction, or anonymization of personal data if the reasons requiring their processing cease to exist and to request notification of such action to third parties to whom the personal data have been transferred,

To object to the emergence of a result against the data subject through analysis of processed data exclusively by automated systems,

To request compensation for damages in case personal data are processed unlawfully.

Requests arising from the Law shall be made via the “Personal Data Subject Application Form.” In accordance with Article 13 of the Law, Hedef Filo shall conclude application requests free of charge as soon as possible and within no later than 30 (thirty) days depending on the nature of the request, except for the fee determined by the Board if the process requires an additional cost. In case the request is rejected, the reason(s) for rejection shall be justified in writing or electronically. In order to exercise your rights stated above, you may submit your request, including the necessary information to identify your identity and explanations regarding the right you request to exercise as specified in Article 11 of the Personal Data Protection Law, by filling out the Personal Data Subject Application Form available at www.hedeffilo.com and delivering a signed copy of the form in person to Ofishane Merkez Mahallesi Cendere Caddesi No:22 Floor:12-13 34400 Kağıthane / Istanbul, or by sending it to the Company’s registered e-mail address hedefarac@hs02.kep.tr (KEP) using a secure electronic signature, mobile signature, or the electronic mail address previously notified to the data controller by the relevant person and registered in the data controller’s system.

Copilot Mobile App - Account Deletion

To delete your account in the Copilot mobile application, you can follow these two methods:

Method 1: Via the Application

1. Open the Copilot application.

2. Go to the Settings menu.

3. Click on the "Delete My Account" option within the Account section.

4. Complete the confirmation steps.

Method 2: Via E-mail

If you do not have access to the application, you can send an e-mail to kvkk@hedeffilo.com with the subject line "Copilot Hesap Silme Talebi"(Copilot Account Deletion Request). Your request will be processed within 30 days.

Data Handling

Deleted Data:

Profile Information (Name, Surname, Phone, E-mail)

Point Records

Notification and Application Preferences

Legally Retained Data:

Billing records: 5 years (Tax Procedure Law Art. 253)

Contract records: 10 years (Turkish Code of Obligations Art. 146)

Internet traffic information: 1–2 years (Law No. 5651)

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### Contact Information

* **E-mail:** kvkk@hedeffilo.com

* **KEP (Registered E-mail):** hedefarac@hs02.kep.tr

* **Address:** Ofishane Merkez Mahallesi Cendere Caddesi No:22 Kat:12-13 34400 Kağıthane / İstanbul

* **Data Controller:** Hedef Araç Kiralama ve Servis Anonim Şirketi

Personal Data Protection and Privacy Policy