Privacy and PDPL Policy
Thank you for choosing us and the tripy mobile app (“App”).
We attach importance to the privacy and security of your personal data. For this reason, with this Privacy and Personal Data Protection Policy (“Policy”), we would like to transparently explain how and why we collect, use, store and share your personal data, as well as inform you about your rights and preferences to share your personal data with us.
Your Personal Data We Collect
We process some of your personal data when you become a member of the Application, purchase services through the Application, log in to the Application and use the Application/service. We process your personal data within the framework of the purposes specified in this Policy and also in accordance with the Personal Data Protection Law No. 6698 (“PDPL”).
In order to use the Application, you must register with the Application. Your personal data that we collect and store during your registration to the Application and use of the Application/service are as follows:
Name-surname, date of birth, Turkish ID number/passport number, user name, nationality, phone number, e-mail address, membership information, customer ID, IP address, user transaction records, phone ID information for the purposes of providing services through the Application, creating a membership record, execution of the user agreement, identity verification, verification of competence to use the vehicle, and ensuring the security of the Application and users.
We process your data consisting of name-surname, e-mail address, phone number, application usage data, location information, device ID, complaint and suggestion records, credit/bank card number, wallet balance, payment amount and payment method for the purposes of providing services through the Application, charging, collection, payment and execution of customer relations processes.
We collect your personal data consisting of name-surname, Turkish ID number, telephone number, address, credit/debit card number, debt amount, invoice number, payment amount and payment method for the purposes of carrying out invoicing processes and tracking financial and accounting affairs.
Correspondence with judicial authorities, information in the case file, date of becoming a member, customer ID, complaint and suggestion records, vehicle usage details, call center records, location data, payment information and application usage information are processed for the purposes of managing, auditing and improving services and operations, conducting strategic planning processes, ensuring service, operation and application security, detecting fraudulent or illegal activities, preventing and detecting fraud and abuse, conducting internal audit, internal control, legal, finance, reporting and internal operations.
We use your name-surname, e-mail address, telephone number, location data and legal transaction information for the purposes of reporting possible accidents that may occur during the use of the Service and informing the relevant public institutions and organizations.
We process your membership information, customer ID, complaints and suggestions, travel details, vehicle usage details, call center records, name-surname, e-mail address, phone number, location data for the purposes of creating individual campaigns for Users, offering special opportunities, determining the target audience, conducting activities to increase user experience, personalizing the Application, conducting direct and personalized marketing activities.
Apart from these, we may process your personal data consisting of name-surname, telephone number and e-mail address in order to contact you for promotional and advertising purposes within the presence of your explicit consent and transfer them to third party service providers from whom we receive services. We may use your personal data in order to inform you about the service and your account in cases such as our inability to provide service due to maintenance and arrangements to be made in the Application, delayed access to the service. Since such notifications are not for commercial purposes and are related to your use of the Application, it is not possible to cancel them.
Your personal data is transferred to the company from which we receive server (storage) services for the purposes of storing and storing your personal data.
Exceptional Circumstances where Explicit Consent is Not Required for the Processing and Transfer of Your Personal Data
Within the scope of PDPL, your personal data may be processed and transferred based on your explicit consent or for reasons that do not require explicit consent regulated in Article 5, Paragraph 2 of PDPL. In this context, while providing our services within the scope of the Application, there are cases where we do not need to obtain explicit consent from our users and are considered within the scope of the exception. These exceptional cases are listed below:
- According to Article 5, Paragraph 2, Subparagraph (c) of the PDPL, “the processing of personal data of the parties to the contract is necessary, provided that it is directly related to the establishment or performance of the contract.”
- According to Article 5, Paragraph 2, Subparagraph (ç) of the PDPL, “it is mandatory to fulfill the legal obligation of the data controller.”
- According to Article 5, Paragraph 2, Subparagraph (e) of the PDPL, “data processing is mandatory for the establishment, exercise, or protection of a right.”
- According to Article 5, Paragraph 2, Subparagraph (f) of the PDPL, “data processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.”
Your Rights
In accordance with Article 11 of the PDPL, within the scope of the processing of your personal data:
(i) Learn whether your personal data is being processed,
(ii) Request information regarding the processing of your personal data,
(iii) Learn the purpose of processing your personal data and whether they are being used in accordance with the purpose,
(iv) Learn the third parties to whom your personal data is transferred, both domestically and abroad,
(v) Request the correction of your personal data if it is incomplete or inaccurate,
(vi) Request the deletion or destruction of your personal data in accordance with the conditions set forth in the PDPL,
(vii) Request that the third parties to whom your personal data has been transferred are notified of the correction, deletion, or destruction of your incomplete or inaccurate personal data,
(viii) If you believe that a result has emerged against you as a result of the analysis of your processed data exclusively through automated systems, you may object to the outcomes of the automated processing,
(ix) If you suffer damage due to unlawful processing of your personal data, you have the right to request compensation for the damage.
When you wish to exercise your rights listed in Article 11 of the PDPL, please follow the procedures and principles stated in the “Notification on the Procedures and Principles for the Application to the Data Controller” dated 10.03.2018, and submit the relevant documents proving your identity along with the “Data Subject’s Application Form in accordance with the PDPL” available on our website [tripy.mobi].
- You can apply in person with a wet signature to the address: Bahçelievler Mah. 323/1 Cad. C Blok Gazi Üniversitesi Teknokent Binası No:10/50c/101 Gölbaşı / Ankara / Turkey.
- You can apply via your registered email address with the secure electronic signature or mobile signature by sending it to the KEP (Registered Electronic Mail) address: [email protected].
- You can also send your application by email to: [email protected].
Requests submitted via the form will be responded to as soon as possible, and no later than thirty days, free of charge, depending on the nature of the request. However, if the process requires an additional fee, a charge may be applied based on the rate determined by the Personal Data Protection Board.
Changes to Our Policy
The effective date of this Policy is indicated below. If there are changes to the services we provide, we may update this Policy. Changes and updates to the Policy will be available on the Application and website, and you will be informed about the changes. Using the Application following changes or updates to the Policy will mean acceptance of the updated agreement. To see the most recent update to this Policy, please refer to the “Last Updated” section below.