VAGupdate

TERMS OF USE AND PRIVACY / PERSONAL DATA PROTECTION POLICY AND INFORMATION TEXT

Dear User, Welcome to the VAGupdate website https:/vagupdate.com.

“Terms of Use and Privacy / Personal Data Protection Policy and Information Text” regulates the provisions regarding the provision of information and services on our website to our valued users.

The following definitions are important for the use of VAGupdate’s https://vagupdate.com website.

Accordingly;

User/Users: Real persons who become members of the site by giving their personal data, the information requested by the contact forms on the site with their own explicit consent or who simply visit the site without giving their personal data,

Personal Data: Any information related to an identified or identifiable real person,

Processing of Personal Data: Any operation performed on data such as obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data, either fully or partially by automatic means or non-automatic means provided that it is part of any data recording system,

Site: The website located at https://vagupdate.com,

FSEK: Law No. 5846 on Intellectual and Artistic Works,

Law No. 5651: Law on the Regulation of Publications Made on the Internet and Combating Crimes Committed through These Publications,

Law No. 6698: Protection of Personal Data The Law,

refers to.

A- TERMS OF USE

TERMS OF USE, ACCESS, LIMITATION OF RISK AND LIABILITY, IP ADDRESSES AND COOKIES

1. https://vagupdate.com website and all documents on the site are the property of VAGupdate. These documents cannot be copied or reproduced except when necessary to be viewed in the on-line system. Regardless of the above, you can print out the pages of the site for your personal use. Regardless of the general principle stated above, VAGupdate may provide the opportunity to download wallpaper, screen saver and other programs from the site. Any legal responsibilities that may arise after any use that violates intellectual and industrial property rights related to the documents on this site belong to the user.

2. If you want to create a link with the site, this link should be directed to the https://vagupdate.com homepage. (https://vagupdate.com)

3. Although VAGupdate has taken precautions within the available means to ensure that the website is free of viruses and similar software, the user is responsible for providing their own virus protection system and providing the necessary protection to ensure ultimate security. In this context, the user accepts that they are responsible for all errors that may occur in their own software and operating systems and their direct or indirect consequences due to entering the https://vagupdate.com website.

4. All prices, information, pictures, descriptions and news (in short "information") on the https://vagupdate.com website are for promotional and informative purposes only. The user cannot claim that the "information" on the website is incorrect or that they have suffered damages based on this information. When the user intends to make a transaction by referring to the information, they are responsible for obtaining final and reliable information from VAGupdate and VAGupdate authorized dealers and accept that VAGupdate has no responsibility due to the information published on the website being out of date.

5. VAGupdate reserves the right to change the content of the site at any time, to change or terminate any service provided to users, and to delete user information and data registered on the https://vagupdate.com website at its own discretion. Although VAGupdate has taken every precaution to ensure that the website is error-free, it does not provide any guarantee regarding existing or potential errors on the site.

6. The information on the https://vagupdate.com website regarding VAGupdate authorized dealers, standard and optional features of the vehicles imported by VAGupdate, and the recommended sales prices for the authorized dealer are the information valid on the date of the last update. We kindly request that you contact VAGupdate and/or VAGupdate authorized dealers for final information on vehicles and VAGupdate authorized dealers. In this context, VAGupdate declares that the information on the website is not an offer of sale (unless otherwise expressly stated) and does not constitute a commitment on behalf of VAGupdate.

7. If a criminal complaint or official investigation request is received from official authorities against the user and/or if it is determined that the user has committed any electronic sabotage or attack that would prevent or change the operation of VAGupdate systems.

VAGupdate has the right to investigate the user's identity information and to notify legal authorities.

VAGupdate is responsible for ensuring the security of the VAGupdate website and all its sub-sites and other information systems. Scans aimed at detecting vulnerabilities that may be found in websites and other information technology systems, whether for commercial purposes, good faith or otherwise, and damaging systems by abusing vulnerabilities that may be detected, information leakage, etc. are illegal. In the event of such activities, sanctions may be imposed pursuant to Law No. 5651 on the Regulation of Publications Made on the Internet and Combating Crimes Committed Through Such Publications. In the event of such attempts, VAGupdate reserves the right to initiate legal proceedings with the type of attack, the time of the attack, the data collected within the scope of the law regarding the attacker, and to request penalties up to a fine or imprisonment as a result of the process.

8. In some cases, information that is not specific to you may be collected. Examples of this type of information include the type of internet browser you use, your operating system, and the domain name of the site you accessed via a link or advertisement to our site.

9. Information may be placed on your computer when you visit the site. This information will be in the form of a cookie or similar file and will help us in several ways.

Cookies are used to determine how you use the website/mobile application/mobile site, including where and from which devices you connect to electronic commerce platforms operated by VAGupdate, what content you view on the website/mobile application/mobile site, and how you use the website/mobile application/mobile site, such as the duration of your visit.

VAGupdate also uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to analyze how visitors use the website/mobile application/mobile site with statistical information/reports.

For more information about the use of Google Analytics (including rejection options), you can visit: https://www.google.com/intl/tr/policies/privacy/#infocollect

10. Matters to be Considered According to the Law No. 5846 on Intellectual and Artistic Works and Law No. 5651 on the Regulation of Publications Made on the Internet and Combating Crimes Committed Through Such Publications

User/Users acknowledge that there may be links on the website that provide access to another website or content, that VAGupdate is not responsible for their control, accuracy or adequacy, and that VAGupdate does not support these sites in any way or guarantee the accuracy of the information they contain, and that VAGupdate has no responsibility for the content on these sites, that they are not responsible for any material or moral, positive or negative and possible damages that they have suffered due to the use of these sites and/or content or the results of the decisions they have taken based on these content, or that they have not read the terms of use of the site or have read them but have not acted in accordance with them. They have accepted and declared that VAGupdate or any group company affiliated to it or its employees, managers, authorized persons or organizations have no legal or criminal responsibility for any damage or expense, and that the accuracy and/or adequacy of the information on the site is not guaranteed by VAGupdate.

User/Users have accepted and declared that there may be any writing, information, comment, opinion, news, image, picture, shape, graphic and other material belonging to VAGupdate or a third party or organization on the website, that VAGupdate has the legal rights regulated by the Industrial Property Law regarding these materials, and that these cannot be copied, changed, reproduced, published, sold or used or interfered with without the permission of VAGupdate.

All logos, brand and corporate emblems and model writings on vehicles published on this site are protected by the provisions of the Industrial Property Law and other relevant legislation. Logos cannot be copied or used in any way. User/Users are responsible for the legal and other liabilities of VAGupdate or any group company affiliated or connected to it or its employees, managers, authorized persons or organizations, from the use of information obtained from the presence of the VAGupdate logo or the pages of the website on another website in any way or from any content uploaded to the website by third parties or visitors, or from any content that does not create liability due to the use of the internet within the framework of general practices or they have accepted and declared that they have no criminal liability.

11. VAGupdate has the right to change, renew or cancel any article of the "Terms of Use" on the https://vagupdate.com website without notice. Every changed, renewed or repealed provision will be effective for all users on the date of publication.

12- Applicable Law, Authorized Courts and Enforcement Offices

This "Terms of Use and Privacy Policy" is subject to the Laws of the Republic of Turkey. In the event of any dispute or conflict, claim or demand regarding the matters included herein, the Istanbul (Çağlayan) Courts and Enforcement Offices will have jurisdiction.

13- Final Provision

The User/Users have irrevocably accepted, declared and undertaken that they have read the "Terms of Use and Privacy Policy" above before entering the website and that they will comply with all the matters stated above.

B- PRIVACY/PERSONAL DATA PROTECTION POLICY AND INFORMATION TEXT”

“This policy explains the principles of VAGupdate, as the Data Controller, regarding the processing of personal data that must be known by real persons whose personal data it processes, such as customers, visitors, website (https://vagupdate.com) users.”

With this Privacy/Personal Data Protection Policy and Information Text,

A. Introduction

The process and target managed by this Information Text and written Policies within the Company for the processing and protection of personal data; is to process and protect the personal data of the relevant persons whose records are kept with us in accordance with the legislation, primarily the Personal Data Protection Law No. 6698.

B. Definitions

Unless the content of this Disclosure Text requires otherwise:

Explicit Consent: Consent based on information and expressed with free will regarding a specific subject,

Personal Data: Any information regarding an identified or identifiable natural person (e.g. Name-surname, TR ID No., e-mail, address, date of birth, credit card number, bank account number - Therefore, the processing of information regarding legal entities is not within the scope of the Law).

Personal Data Owner: The natural person whose personal data is processed

Processing of Personal Data: Any operation performed on data, such as obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data, either fully or partially by automatic means or non-automatic means provided that it is part of any data recording system,

Special Personal Data: Data related to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, dress code, association, foundation or union membership, health, sexual life, criminal conviction and security measures, and biometric and genetic data,

Data Controller: The person who determines the purposes and means of processing personal data and manages the place where the data is systematically kept (data recording system).

C. Identity of the Data Controller

VAGupdate ("Company"), as the data controller, attaches great importance to the fundamental rights and freedoms of individuals and shows the utmost sensitivity to the processing of all personal data related to real persons affiliated with the Company, including those who benefit from our products and services, in accordance with the Law on the Protection of Personal Data No. 6698 ("KVKK"), which was published in the Turkish Goverment Official Gazette on April 7, 2016 and entered into force, and to ensuring their confidentiality and security.

D. Which Personal Data Do We Process?

Identity information: Your name and surname, date of birth, T.R. identity number.

Contact Information: Your e-mail address, telephone number, your residential address if you have notified us for communication, your social media account contact information, including all kinds of contact information you have provided to VAGupdate.

Product and Service Information: Your vehicle information including the vehicle license plate, model, transaction history and other information included in the vehicle registration certificate (registration document), from our Company It includes details of products and services you have requested and received in the past or currently.

Risk Management Information: IP address information.

Customer Transaction Information: Verbal/written or electronic information sent to VAGupdate within the scope of your requests and complaints regarding our products and services.

Request/Complaint Management/Reputation Management Information: Records regarding complaints and/or requests made by the relevant person via the website, mobile application, social media accounts or call center regarding the product or service purchased and the transactions made during the evaluation or management process of these requests.

Marketing Data: Your preferences or past experiences regarding our products or services, surveys, cookie records, campaign information, commercial electronic information you have provided

Marketing SMS, e-mail messages sent based on permission, or calls made by the call center, social media user information.

Financial Data: All information regarding billing and payment instruments.

Visual and Audio Data: Call center records, records recorded by cameras positioned at certain service points to ensure life, property and transaction security.

Legal Transaction and Compliance Data: Documents/information requested from judicial and administrative institutions, judicial processes initiated against and/or by VAGupdate (e.g. lawsuits and investigation files) and data regarding administrative/judicial processes.

E. Based on Which Data Processing Conditions and How Do We Collect Your Personal Data? For What Purposes Do We Use It?

Your personal data may be collected (i) through face-to-face meetings and printed forms at our dealers and services (“Physical Channels”), (ii) through call centers, e-mails, SMS and digital platforms (“Call Channels”), (iii) through our websites, mobile applications and communication, reservation and other request forms on these (“Digital Channels”) and (iv) through our social media accounts (“Social Media Channels”).

1. Provision of Our Products and Services to You, Our Customers

Our Company may process your identity, contact, product and service data based on the legal reason of establishing and fulfilling a contract in accordance with Article 5/2/c of ​​the KVKK in order to provide the services we undertake to provide to you, our valued customers, especially in the realization of sales and rental transactions, provision of our after-sales services to you, and provision of assistance services and replacement vehicles when necessary.

2. Product and Service Development Activities

In order to increase our effectiveness, understand our customers better and continuously improve our services, we process your personal data within the framework of our legitimate interests specified in Article 5/2/f of the KVKK, in a balanced and measured manner, within the framework of respect for your personal data. In particular, we carry out measurement and evaluation studies in order to constantly achieve better quality standards regarding the services we offer to you, and in this context, we create general reports and measurements using information in areas such as customer relations, complaint management and service. In light of your preferences, habits and feedback, we customize, renew and redesign our products and services in the most appropriate way for our customers (We do not create products specific to you and do not promote you without your explicit consent). Similarly, we use your personal data in the management of your requests from digital and social media channels, on the other hand, this information is not used for marketing and sending messages without your explicit consent.

3. Carrying out marketing activities and ensuring customer satisfaction

Our company; to determine marketing strategy, to produce statistical information, to create user profiles, to make singularization, to create a database and to list, report, verify, analyze and evaluate, to reach you through the communication channels you provide for your offers, information and callback requests from all channels, to manage customer/potential customer relations, to plan and/or execute membership transactions, to use in marketing activities such as campaigns, promotions, competitions, loyalty programs and raffles, to ensure that surveys and customer satisfaction researches and event activities are carried out, to create special offers for you, to plan and/or execute advertising, promotion and marketing activities on Digital Channels and Social Media Channels, to contact you upon your request and to send all kinds of communication and other communication messages regarding the requested product or service, to carry out personalized advertising applications (to provide and present you with various advantages in accordance with your likes and preferences and to display advertisements, promotions, sales, marketing, event management, information, promotion, campaign notification, data enrichment, cross-device targeting, data management platforms, social media platforms and search engines that are personally suitable for you). Your identity, communication, marketing and product and service data may be processed based on the legal reason of providing your explicit consent as stated in Article 5/1 of the KVKK.

In all cases, in the areas where we request your explicit consent (for all channels), we provide customized texts regarding the scope and purpose of the explicit consent and limit our processing activities to this. You may withdraw your explicit consent at any time.

4. Conducting Financial Operations

Our company; performs financial reporting, control, verification, analysis and evaluations, payment and/or refund transactions

In order to perform, fulfill tax and similar payment and reconciliation obligations, take precautions against financial fraud and abuse cases, your identity, product and service and financial data may be used based on the legal reasons that it is mandatory for the data controller to fulfill its legal obligations as set forth in Article 5/2/ç and 5/2/f of the KVKK and that data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person.

5. Legal Compliance Audit

While performing our services, we are obliged to fulfill our obligations arising from many different legislations. In particular, your vehicle, identity and contact information arising from consumer legislation, such as establishing and maintaining a contract, providing information on sales and service services, providing after-sales support services, providing assistance services and replacement vehicles when necessary, opening records regarding product safety and service status, making announcements and informing; your identity, contact and financial information, primarily for creating and maintaining invoices within the framework of our obligations arising from financial legislation; In insurance-related processes, it is possible to use your information, which must be stored and shared pursuant to legislation, based on the legal reason that our Company can fulfill its legal obligations stipulated in Article 5/2/ç of the KVKK.

F. With Whom and for What Purposes Can We Share Your Personal Data?

In some cases, we may need to share your personal data with third parties. In this context,

• In order to fulfill our legal obligations, with the relevant public institutions and our financial advisors regarding financial processes, with the service providers from whom we receive technical support due to obligations arising from consumer legislation;
• With the relevant authorized dealers and authorized services of VAGupdate in order to fulfill our obligations arising from the contract (you can access the current authorized dealer and service information of VAGupdate at https://vagupdate.com) and with VAGupdate, affiliates and subsidiaries and third-party service providers providing technical support for the same purposes; with insurance companies and agencies if it arises from a contract-specific basis, and with banks and other financial institutions if necessary upon your request; Within the scope of our legitimate interest, with consultants and other technical service providers from whom we provide services, VAGupdate affiliates and subsidiaries and third party service providers providing technical support
• In case of your explicit consent, the provision of goods and services offered by our Company, their sales, planning, monitoring and development of after-sales support services processes, marketing, campaign, event and personalized advertising activities, especially communication and promotion activities related to your explicit consent, your personal data, domestic and/or foreign third parties with whom VAGupdate has a contractual relationship in order to provide these services, the list of which can be accessed from https://vagupdate.com/ VAGupdate affiliates and subsidiaries, shareholders, manufacturers of vehicles imported by VAGupdate, affiliates of manufacturers and/or 3rd parties determined by these companies, VAGupdate authorized dealers and authorized services, VAGupdate and authorized We may share it with companies that process data on behalf of vendors/authorized services and provide research, promotion and consultancy services.

G. What are your rights regarding your personal data?

According to Article 11 of the KVKK;

• You have the right to learn whether your personal data has been processed,
• To request information about your personal data if it has been processed,
• To learn the purpose of processing your personal data and whether it is used in accordance with its purpose,
• To know the third parties to whom your personal data has been transferred domestically or abroad,
• To request correction of your personal data if it has been processed incompletely or incorrectly and to request notification of the transaction made within this scope to the third parties to whom your personal data has been transferred,
• To request deletion or destruction of your personal data if the reasons requiring processing are eliminated despite the fact that it has been processed in accordance with the provisions of the KVKK and other relevant laws and to request notification of the transaction made within this scope to the third parties to whom your personal data has been transferred,
• To object to the emergence of a result against the person by analyzing your processed data exclusively through automated systems,
• To request compensation for the damages incurred due to the unlawful processing of your personal data.

Law No. 6698 on the Protection of Personal Data According to Article 11 of the Law, you can submit your requests regarding your personal data to the attention of the Digital Transformation and Corporate Communications Department, together with information/documents proving your identity;

• You can send an e-mail to our company address with a written petition,
• You can send an e-mail from your KEP address to the Registered Electronic Mail (KEP) address registered on our company's website,
• You can send an e-mail to [email protected] with a secure electronic signature or from your e-mail address that you have notified to our company and registered in our system. Your application must be made in accordance with the 2nd paragraph of Article 5 titled "Application Procedure" of the "Communiqué on the Procedures and Principles of Application to the Data Controller". Your application will be evaluated by our company and a response will be given within 30 (thirty) days at the latest, depending on the nature of your request.

H. Measures Regarding the Protection of Personal Data

The protection of personal data is an important issue for VAGupdate. VAGupdate takes the necessary precautions to protect against unauthorized access to personal data or loss, misuse, disclosure, alteration or destruction of this information.

VAGupdate undertakes to keep your personal data confidential, to take all necessary technical and administrative measures to ensure confidentiality and security, and to show due diligence. In the event that personal data is damaged or passed on to third parties as a result of attacks on the website and system, despite VAGupdate taking the necessary information security measures, VAGupdate will immediately notify you and the Personal Data Protection Board of this situation.

I. Keeping Your Personal Data Accurate and Up-to-Date

User/Users accept and declare that they are aware that the accuracy and up-to-date maintenance of the information they share on the website is important for them to be able to exercise their rights on their personal data within the meaning of the Personal Data Protection Law No. 6698 and other relevant legislation, and that they will be fully responsible for any responsibilities arising from providing incorrect information.

K. Changes to Privacy/Personal Data Processing Information Text

VAGupdate may make changes to this “Terms of Use and Privacy/Personal Data Processing Information Text” at any time. These changes shall become effective immediately upon the posting of the new “Terms of Use and Privacy/Personal Data Processing Information Text” on the "vagupdate.com” website. You will be provided with the necessary information to be informed about the changes in this “Terms of Use and Privacy/Personal Data Processing Information”.