Clarification Text Regarding the Processing
of Customers’ Personal Data

This Clarification Text has been prepared by Başpınar Otomotiv (“Company”) to explain for what purposes the personal data of our customers (individual/corporate) is processed, through which methods it is collected, to whom it may be transferred, and your rights within the scope of the Personal Data Protection Law No. 6698 (“KVKK”).

Our Company attaches great importance to the privacy, security and ownership rights of personal data; it processes your data in compliance with KVKK, limited to its purpose, proportionately and by taking the highest level of administrative/technical security measures.

1) Processed Personal Data

Your personal data may be obtained directly from you, through digital request and order forms on our website, face-to-face meetings held at our workplace (gallery), or information and documents submitted by you within the scope of vehicle purchase-sale, customs clearance and import processes.

1.1. Data that may be processed if you are an individual customer or vehicle owner:

• Name-surname, Turkish Republic identity number (or foreign identity number/passport number)
• Date and place of birth
• E-mail address, phone number, residence/delivery address
• Customer reference and request number

1.2. Data that may be processed if you are a corporate customer or company official/employee:

• Name-surname, title / position, authorized person information
• Turkish Republic identity number, Tax Office and Tax Identification Number
• Company phone number, corporate e-mail address, company address
• Customer/Company reference number

1.3. Additional data that may be processed within the scope of vehicle procurement, purchase-sale, import and customs clearance relationship:

• Financial Data: Bank account information (IBAN), payment, collection and disbursement receipt information, information on checks/promissory notes.
• Legal and Official Documents: Signature circulars, powers of attorney, signature declarations, passport photocopy (when required for international import processes).
• Vehicle and Registration Data: Vehicle registration certificate information, chassis and engine numbers, license plate information, vehicle appraisal/condition reports, customs declarations and import registration documents.
• Digital Communication Data: IP address, browser information and system logs used in forms on our website.
• Communication Records: Phone call recordings (for communication and service quality purposes), and profile and messaging information if communication is established through social media or messaging lines (WhatsApp, etc.).

1.4. Data processed within the scope of digital request forms and website solutions:

• The vehicle criteria, brand, model, optional equipment preferences, budget range, IP address from which the form was submitted and system logs that you transmit through vehicle request and order forms on our website.

1.5. Credit card payment or deposit transactions:

• If payment is made by credit card, card information is absolutely not stored or retained in our Company systems. For security and transaction confirmation purposes, only limited data legally permitted, such as the cardholder’s name-surname, the first 6 and last 4 digits of the card and the expiration date, may be stored. Payment transactions are carried out through the relevant licensed payment service providers and banks.

2) Purposes of Processing Personal Data

Your personal data may be processed for the following purposes in accordance with the principles in Article 4 of KVKK and the processing conditions in Article 5:

2.1. Imported vehicle procurement, special order and second-hand vehicle sales processes:

• Researching and procuring the luxury, prestigious, classic or specially equipped vehicles of your dreams from abroad through the global network,
• Creating and presenting a vehicle portfolio suitable for customer requests,
• Preparing vehicle purchase-sale agreements, deposit agreements and undertakings,
• Carrying out appraisal, condition verification and originality control processes of vehicles.

2.2. Customs clearance, international logistics and official registration operations:

• Following and carrying out customs clearance and taxation processes (SCT, VAT, etc.) in accordance with international classic or premium vehicle regulations,
• Organizing special closed logistics and VIP transport insurance processes for the transportation of vehicles to Turkey,
• Carrying out TSE, TÜVTÜRK, inspection, registration, license certificate and license plate printing procedures on your behalf before official authorities.

2.3. Finance, accounting and invoicing processes:

• Collecting vehicle sales and import fees, issuing invoices, carrying out Accounting and Tax Procedure Law processes,
• Opening collection/disbursement receipts and current accounts, tracking past order and financial transaction records.

2.4. Customer relations, support and request management:

• Evaluating digital vehicle request forms on the website and contacting customers quickly,
• Receiving and resolving requests, complaints, after-sales support and feedback.

2.5. Marketing, communication and customer experience (including permission-based marketing):

• Making satisfaction calls in order to increase customer satisfaction and measure service quality,
• Providing information about personalized luxury vehicle portfolios, current stocks and automotive trends,
• If you have explicit consent, sending commercial electronic communications (SMS/e-mail), carrying out target audience determination and segmentation activities.

2.6. Legal obligations and protection of rights:

• Fully fulfilling legal obligations before notaries, the General Directorate of Security (Traffic Registration), the Ministry of Trade, Customs Directorates and Tax Offices,
• Fulfilling the burden of proof in possible legal disputes, establishing, exercising and protecting the rights of our Company and our customers.

3) Transfer of Personal Data

Our Company may transfer your personal data to third parties only limited to the purposes specified above, in accordance with the conditions stated in Articles 8 and 9 of KVKK.

3.1. Recipient groups to whom transfers may be made domestically:

• Our financial advisor, contracted banks and payment service providers for carrying out financial processes, taxation and financial obligations,
• Authorized customs consultancy firms, tracking agents and agencies with whom we cooperate for the follow-up of vehicle registration, license plate, registration certificate and notary procedures and customs clearance processes,
• VIP closed-body logistics companies and insurance companies from which services are received for the safe transportation of vehicles,
• Corporate appraisal centers for determining the technical condition of vehicles,
• The Message Management System (İYS) within the scope of legal obligations,
• Our law office and legal advisors for the follow-up of legal processes,
• Legally authorized public institutions, judicial authorities, police departments and tax offices.

3.2. Transfer abroad within the scope of KVKK Article 9:

• In special order and import processes, to the relevant business partners abroad for the purpose of contacting the vehicle’s manufacturer, distributor or authorized dealer abroad and questioning the vehicle’s past story and originality before international authorities,
• It may be transferred, in accordance with legal legislation, to corporate communication, cloud storage or messaging systems of foreign origin used in communication and operation processes (with the customer’s request or approval) (e.g. WhatsApp, Microsoft 365, e-mail servers, etc.).

4) Methods of Collecting Personal Data and Legal Grounds

Your personal data is collected in physical or electronic environments within the scope of digital forms on our website, e-mail submissions, phone calls, face-to-face contract and offer processes carried out in our gallery, and vehicle registration/delivery steps.

Your personal data is processed based on the following legal grounds within the scope of KVKK Article 5:

• KVKK Art. 5/2-a: Being clearly stipulated by laws (obligations arising from the Turkish Commercial Code, Tax Procedure Law, Highway Traffic Law and similar legislation).
• KVKK Art. 5/2-c: Provided that it is directly related to the establishment or performance of a contract, processing personal data belonging to the parties of the contract is necessary (Vehicle purchase-sale, order and import agreements).
• KVKK Art. 5/2-ç: Being mandatory for the data controller to fulfill its legal obligation (Issuing invoices, official institution notifications, customs registrations).
• KVKK Art. 5/2-e: Data processing being mandatory for the establishment, exercise or protection of a right.
• KVKK Art. 5/1: The existence of your explicit consent in terms of marketing, campaign notifications and commercial electronic communication sending.

5) Your Rights as the Data Subject (KVKK Art. 11)

Within the scope of KVKK; you have the right to learn whether your personal data has been processed, to request information if it has been processed, to learn the purpose of processing and whether it is used in accordance with its purpose, to know the third parties to whom it has been transferred domestically/abroad, to request correction if it has been processed incompletely/incorrectly, to request deletion/destruction if the reasons for processing have ceased to exist, to object to a result arising against you through analyses by automated systems, and to request compensation for damages due to unlawful processing.

In this context, in order to exercise your legal rights, you may submit your requests together with documents verifying your identity via the [email protected] e-mail address below or in writing to the physical address of our Company. Your applications will be concluded free of charge as soon as possible and within 30 days at the latest, depending on the nature of the request. (If the transaction requires an additional cost, the fee in the tariff determined by the KVKK Board may be applied.)

6) Data Controller (Company Information)

Data Controller: Başpınar Otomotiv

Phone: 0534 073 48 04

E-mail: [email protected]

Address: Maslak Atatürk Oto Sanayi Sit. 2. Kısım, 34. Sk. No:1404 D:1403, 34485 Sarıyer/İstanbul