Privacy Notice for Customers Regarding Processing of Personal Data

As Stellantis Otomotiv Pazarlama A.Ş. (“Stellantis” / “Company”), we respect data subjects and the personal data we process as we carry out our operations and activities, and we exercise the utmost care regarding the security of personal data within the framework of current legislation and universal values. In this regard, as Stellantis, we value the security and confidentiality of all personal data belonging to the customers of our Company.

Stellantis carries out personal data processing activities in accordance with the provisions of Law No. 6698 on the Protection of Personal Data (“KVKK”).

Data Controller

Subparagraph (a) of paragraph 1 of Article 10 of the KVKK, titled “Obligation of Data Controller to Inform”, sets out the requirement to provide information on the identity of the data controller. Under subparagraph (ı) of paragraph 1 of Article 3 of the KVKK, data controller is defined as “the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data filing system”. Stellantis will act as the “data controller” for the purposes of the KVKK. In this context, the “identity of the data controller” is Stellantis, which has been established in accordance with the laws of the Republic of Türkiye to operate in the social, cultural, and economic fields, is located at Barbaros Mahallesi Begonya Sk. Nidakule Ataşehir Batı Apt. No:1 / 2 Ataşehir/ISTANBUL, and continues its operations without interruption.

Personal Data Subject to Processing

Your personal data may be collected by Stellantis directly from you through forms or the Chatbot on our website, including your name, surname, email address, telephone number, requests sent to us, information about the vehicle you are interested in, and the dealer and city where you would like to see the vehicle.

Purposes of Processing Personal Data

Stellantis processes the aforementioned personal data in accordance with the personal data processing principles specified in Article 4 of the KVKK, based on one or more of the personal data processing conditions specified again under the KVKK. The personal data processed by Stellantis are treated in accordance with the obligations set forth in all relevant legislation, including the Turkish Code of Obligations, the Turkish Commercial Code, the Law on Consumer Protection, the Law on the Regulation of Electronic Commerce, and the Regulation on Commercial Communication and Commercial Electronic Messages. Accordingly, your personal data may be processed by the Company for the following purposes (“Purposes”) and for purposes of legal compliance.

 

-                For managing customer relations, responding to your requests, creating online appointments, and responding to your requests for obtaining information regarding vehicles in this context; for communicating with you regarding maintenance, support, and service requests related to the vehicle you have purchased; and for determining the mutual rights and obligations of both our Company and you, based on the legal ground of establishing and executing a contract,

-                For recommending and promoting the products and services offered by Stellantis in accordance with your usage habits and needs; for engaging in personal marketing activities; for carrying out marketing operations; for sending commercial electronic communications for promotional, marketing, campaign, and discount purposes; and for carrying out activities aimed at customer satisfaction and experience based on the legal ground of the existence of your explicit consent,

-                For keeping commercial records related to products and services; for fulfilling obligations arising from the Turkish Code of Obligations, the Turkish Commercial Code, the Law on Consumer Protection, the Law on the Regulation of Electronic Commerce, the Regulation on Commercial Communication and Commercial Electronic Messages, and other legislation, based on the legal ground of fulfilling legal obligations,

-                For resolving disputes and legal cases; for asserting legal rights, filing lawsuits, or defending lawsuits; and for fulfilling the burden of proof in a potential dispute, based on the legal grounds of the obligation of data processing for the establishment, exercise, and protection of a right,

Your personal data may be processed in an anonymized way for the purposes of internal reporting and statistical studies.

Recipients to Whom Personal Data May Be Transferred and the Purposes of Such Transfers

Under certain circumstances, the Company may transfer your processed personal data to third parties in accordance with the national legislation, primarily Articles 8 and 9 of the Law, in order to realize the above-mentioned Purposes.

 

Your collected personal data may be transferred to legally authorized public institutions and legally authorized private persons; to our dealers, suppliers, and business partners from whom we receive services to carry out our operational processes, such as software, chatbot, call center, vehicle assistance, and tow truck services; and to the subsidiaries of Stellantis, within the framework of the data processing conditions set out in Article 5 of the Law and in accordance with the rules regarding the transfer of personal data specified in Article 8 of the Law, for the purpose of fulfilling legal obligations.

 

Your personal data may be transferred to our third-party business partner from whom we receive call center/SMS/email/push notification sending services, for the purpose of sending you commercial electronic communications within the scope of promotional, advertising, and marketing activities, provided that you have given your explicit consent. Your personal data may also be transferred to the Message Management System to fulfill our legal obligations under the Regulation on Commercial Communications and Commercial Electronic Messages. At the same time, your personal data in question is transferred to our business partner from whom we receive services, provided that you have given your explicit consent, so that commercial electronic messages can be sent to you and the consents received can be stored within the scope of our legal obligations.

 

Furthermore, your personal data may be transferred, with your explicit consent, to the foreign subsidiaries of Stellantis, acting as data processors, due to the fact that the infrastructure of our website is provided by the foreign subsidiaries of Stellantis. Moreover, your personal data may be transferred, with your explicit consent, to software and social media companies located abroad, for the purposes of conducting our digital marketing processes, carrying out personalized marketing activities specific to you, and providing you with the necessary support when you contact us via WhatsApp Business.

 

Additionally, your personal data may be transferred to third parties, such as supervisory authorities, courts, law firms or legally authorized public institutions, to the extent necessary to ensure compliance with applicable laws or, if legally permitted, to exercise, assert or defend legal claims.

 

Methods and Legal Grounds for the Collection of Your Personal Data

Throughout the process, your personal data may be collected directly from you by Stellantis through the forms on our website for the purpose of carrying out the activities listed above. Personal data is collected and processed verbally, in writing, or electronically, through automatic or semi-automatic means, based on the legal grounds specified under the headings “Purposes of Processing Personal Data” and “Recipients to Whom Personal Data May Be Transferred and the Purposes of Such Transfers” within the scope of the personal data processing conditions and purposes specified under Article 5 of the KVKK. Your personal data processed by Stellantis may be updated and processed.

Rights of Data Subjects under Article 11 of the KVKK:

Pursuant to Article 11 of the KVKK, the rights of natural persons whose personal data is processed are as follows:

·                Learn whether their personal data has been processed,

·                Request relevant information if their personal data has been processed,

·               Learn the purpose of personal data processing and whether the personal data has been used for the intended purpose,

·               Learn the domestic or overseas third parties to which personal data were transferred,

·               Request correction in case of missing or incorrect processing of personal data and request notification of such transaction to third parties to which personal data were transferred,

·               Request erase or destruction of personal data if reasons for processing disappear, even if the personal data was processed in compliance with the KVKK and other relevant legal provisions, and request notification of such transaction to third parties to which personal data were transferred,

·               Object to a result to the detriment of the person himself/herself that emerged due to analyzing the processed data solely through automated systems,

·               Request indemnification of damages incurred due to unlawful processing of personal data.

You can submit your requests regarding the rights stated above by filling out the application form available here and sending it to the email addresses kvkkcikistalebi@stellantis.com & kvkk@stellantis.com or mailing it to the address Barbaros Mahallesi Begonya Sk. Nidakule Ataşehir Batı Apt. No:1 / 2 Ataşehir/ISTANBUL. We will conclude your requests as soon as possible and within thirty days at the latest, depending on the nature of your request, and at no cost to you; however, if the process requires an additional expense, a fee may be charged in accordance with the tariff to be determined by the Personal Data Protection Board.