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Data Privacy Policy

  • Updated

LETGO SERVICES B.V. and LETGO MOBİL İNTERNET SERVİSLERİ VE TİCARET A.Ş.

DATA PRIVACY NOTICE IN RELATION TO THE PROTECTION AND PROCESSING OF PERSONAL DATA 

 

  1. Data Controller 

 

Pursuant to the Personal Data Protection Law numbered 6698 (the “PDPL”), by this Data Privacy Notice in Relation to the Protection and Processing of Personal Data (“Data Privacy Notice”), we, as Letgo Services B.V. and Letgo Mobil İnternet Servisleri ve Ticaret A.Ş. (together, the “Letgo Companies”), would like to inform you, our valued customers, under our obligation to inform pursuant to the PDPL in our capacity as Data Controller. 

Personal data under the PDPL means any and all information in relation to a real person, who is identified or identifiable (“Personal Data”), and sensitive personal data, which is a special type of Personal Data, means the data in relation to race, ethnic origin, political opinion, philosophical belief, religion, religious sect or other belief, appearance, attire, memberships to associations, foundations or unions, health, sexual life, criminal convictions and security measures and biometric and genetic data (“Sensitive Personal Data”). In this context, the definition of Personal Data also includes your Sensitive Personal Data. 

  1. Method of Collection of Personal Data and the Legal Bases of Processing

Your Personal Data is collected, in connection with the transactions entered with the Letgo Companies and for the purpose and within the scope indicated in Section 4 below, by way of the below-mentioned methods and via third parties, which the Letgo Companies are contracted with, by automated or non-automated means, verbally, in writing and/or in electronic form:

  1. By way of the memberships and all your visits including chat/messaging done through the websites or application which belongs to the Letgo Companies (together as ‘’Letgo Platform’’),

  2. Through the information which you provide in writing during the pre-pricing and inspection appointment processes that you conduct via Letgo Platform,

  3. Through the contact form, which you provide via Letgo Platform regarding the loan application processes,

  4. Through the information, which you provide verbally and/or in writing during your visits to Otoplus locations,

  5. Through the information, which you provide verbally or in writing, or in various documents before the notary public during the vehicle purchase and sale transactions, 

  6. By means of the requests and complaints, which you provide verbally to our Call Center and in writing to the Customer Services’ e-mail address,

  7. By means of the video surveillance system, which is located in Otoplus locations, 

  8. Through the third person, from which Letgo Companies receive services with respect to their customers and with which Letgo Companies have a contractual and business relationship. 

Additionally, the Letgo Platform collects and processes location data, which may be accessed and collected while the application is in use or in the background, even when the app is closed, to enhance the user experience by enabling features such as displaying nearby listings and relevant advertising. This location data is collected for the purposes of providing personalized content, facilitating transactions, and supporting advertising functionalities in accordance with applicable data protection laws. Letgo Companies do not share this location data with unauthorized third parties.

The legal bases set forth in Articles 5 and 6 of the PDPL in relation to the processing of Personal Data are as follows: 

 

  1. Your explicit consent,

  2. Being explicitly provided for by the laws,

  3. Being necessary for the protection of life or physical integrity of the person himself/herself or of any other person, who is unable to express his/her consent due to the physical disability or whose consent is not deemed legally valid,

  4. Processing of personal data in relation to the establishment or performance of an agreement,

  5. Being required for the fulfilment of our legal obligations,

  6. Being made public by the data subject himself/herself,

  7. Being required for the establishment, exercise, or protection of a right, and

  8. Provided that your fundamental rights and freedoms are not violated, being required for our legitimate interests.

 

  1. Your Personal Data Collected

The Personal Data collected from you, are the data processed for the purposes of processing indicated in Section 4 below.

 

  1. Purposes of Processing of Personal Data

Your Personal Data are processed by the Letgo Companies with your explicit consent or under other circumstances legally allowed under the PDPL for the purposes below:

  1. Creating and using the memberships (sign-in and login) of the customers through the Letgo Platform as well as verification of the information provided (identity information, contact information (including phone numbers), transaction security information, visual and audio record information (including customer’s images), (Legal basis: Performance of an agreement, processing of personal data being required for establishment, exercise, and protection of a right)

  2. Carrying out listing processes at Letgo Platforms as well as conducting sales of bump up and top listing features in the Letgo Platform in regard to the sales of the customers’ products (identity information, contact information (including phone numbers), customer transaction information, transaction security information), (Legal basis: Performance of an agreement, processing of personal data being required for the establishment, exercise, and protection of a right)

  3. Issuing shipping invoices and fulfilling tax and other legal obligations for the purpose of carrying out the activities in compliance with the legislation following the purchase of products by the customer (identity information, contact information, customer transaction information), (Legal basis: Being explicitly provided for by the laws, being required for the fulfillment of our legal obligations, the performance of an agreement, processing of personal data being required for the establishment, exercise and protection of a right)

  4. Obtaining pre-pricing proposal and conducting inspection service appointment process with respect to vehicle purchase and sale transactions via the Letgo Platform (identity information, contact information (including phone numbers), customer transaction information, vehicle information, transaction security information), (Legal basis: Performance of an agreement, processing of personal data being required for the establishment, exercise, and protection of a right)

  5. Conducting TSE inspection services processes of the vehicles that the customer wants to sell to Letgo Companies (identity information, contact information, customer transaction information, vehicle information), (Legal basis: Establishment and performance of an agreement, processing of personal data being required for the establishment, exercise, and protection of a right)

  6. Carrying out the processes with respect to the purchase of the vehicles of the customers by the Letgo Companies (identity information, contact information, financial information, customer transaction information, legal transaction information, vehicle information), (Legal basis: Establishment and performance of an agreement, is required for the fulfillment of our legal obligations, processing of personal data being required for the establishment, exercise and protection of a right)

  7. Carrying out the processes with respect to sale of vehicles to the customers, which belong to the Letgo Companies (identity information, contact information, financial information, customer transaction information, legal transaction information, vehicle information), (Legal basis: Establishment and performance of an agreement, processing of personal data being required for the establishment, exercise and protection of a right, is required for the fulfillment of our legal obligations)

  8. Informing customers through Letgo Companies call center for the purpose of carrying out the loan application processes, inviting customers to Otoplus locations, and directing them to the relevant financial institutions (including financing companies and banks) in line with customer requests (identity information, contact information, financial information, profession information, customer transaction information), (Legal basis: Explicit consent)

  9. Providing information to financial institutions for the execution of loan processes regarding the vehicles of Letgo Companies to be purchased by the customers through loans issued by the contracted financial institutions (including financing companies and banks) (identity information, contact information, financial information, profession information, customer transaction information, vehicle information, legal transaction information), (Legal basis: Explicit consent)

  10. Issuing e-invoice or e-archive invoice and fulfilling tax and other legal obligations following the processes with respect to the vehicle sale to the customers or vehicle purchase for the purpose of carrying out the activities in compliance with the legislation (identity information, contact information, customer transaction information, vehicle information), (Legal basis: Being explicitly provided for by the laws, being required for the fulfillment of our legal obligations, the performance of an agreement, processing of personal data being required for the establishment, exercise and protection of a right) 

  11. Carrying out the replacement and return processes with respect to the vehicles, with which the customers are not satisfied as part of the support services after the sale of the product (identity information, contact information, customer transaction information, vehicle information, legal transaction information, finance information), (Legal basis: Performance of an agreement, is required for the fulfillment of our legal obligations, establishment, exercise, and protection of a right) 

  12. Carrying out photoshoot, video shoot, and interview processes with the customers after sales in order to be used in Letgo Platform, social media platforms (including Instagram, Twitter, Youtube, etc.), to be used in offline instore TVs located in Otoplus locations or in PR events held by Letgo Companies or for the Letgo Companies internal information (identity information, contact information, vehicle information, visual and audio records information), (Legal basis: Explicit consent)

  13. Sending out electronic commercial messages (in the form of telephone, SMS, MMS, e-mail (standard or customized) or in other forms) as part of carrying out advertisement/campaign/special offer processes, product marketing processes, and communication activities (identity information, contact information, customer transaction information, transaction security information, marketing information), (Legal basis: Explicit consent)

  14. Carrying out all marketing activities including carrying out marketing analysis, standard or customized marketing through segmentation by way of analyzing transaction habits and tendencies, all Customer Relationship Management (CRM) activities, surveys of all processes (including all customer satisfaction surveys) with respect to and including the Letgo Platform (including purchased products) and/or vehicle sales service and inspection services for the purposes of feedback and research (identity information, contact information, marketing information, customer transaction information, transaction security information, vehicle information), (Legal basis: Explicit consent)

  15. Sending out commercial electronic messages (in the form of SMS) in order to direct the customers to evaluate, rate, and/or write a review on Otoplus locations and the provided services on social media platforms (such as Google, etc.) to improve the Letgo Companies services (identity information, contact information, marketing information, customer transaction information), (Legal basis: Explicit consent)

  16. Maintaining the safety of the Otoplus locations for the purpose of ensuring physical location safety and workplace health and safety (physical location safety information, visual and audio record information), (Legal basis: is required for the fulfillment of our legal obligations, processing of personal data being required for the establishment, exercise, and protection of a right) 

  17. Carrying out customer relationship management processes and in that respect ensuring follow-up of customers’ requests/complaints (identity information, contact information, marketing information, vehicle information, transaction security information, financial information, customer transaction information), (Legal basis: Performance of an agreement, is required for the fulfillment of our legal obligations, processing of personal data being required for the establishment, exercise, and protection of a right)

  18. Following up and conducting legal matters within the scope of the conduct on the legal platforms of the complaint processes by the customers (identity information, contact information, customer transaction information, legal transaction information, transaction security information, marketing information), (Legal basis: processing of personal data being required for the establishment, exercise, and protection of a right, is required for the fulfillment of our legal obligations legitimate interest)

  19. Informing authorized persons, institutions, and organizations for the fulfillment of legal obligations and for complying with the requests by the authorized administrative institutions (identity information, contact information, physical location security information, customer transaction information, financial information, transaction security information, marketing information, visual and audio record information, legal transaction information), (Legal basis: Being required for the fulfillment of our legal obligations)

 

  1. To Whom and For What Purpose Personal Data May be Transferred

The Letgo Companies may transfer and/or make available your Personal Data, within Turkey or abroad, in accordance with your explicit consent or under other circumstances legally allowed (for the purposes and within the scope of the legal bases specified in Section 4) to the group companies of the Letgo Companies, with which collaborations are made and/or from which services are received, to companies, from which consultancy and support is received in fields such as insurance, security, software, marketing (including user experience (UX) and market research agencies), law, inspection, finance (including financing companies and banks), logistics and tax, to financial institutions with which collaborations are made, to social media companies that Letgo Companies are collaborating for marketing purposes, and to third parties from which support services are received in relevant other fields in relation to the activities of the Letgo Companies within the scope of the purposes specified above (companies providing support in sending SMS and e-mail, providing of e-invoice, e-archive services, CRM (Customer Relationships Management) and cloud computing, back-up etc.) and to authorized institutions and organizations and official public institutions and organizations, and, if requested, to judicial authorities and relevant police forces for the purposes of resolution of legal disputes, fulfilment of obligations arising from legislation.  

 

  1. Rights of the Data Subject Under Article 11 of the PDPL

 

As a data subject, you may request at any time from the Letgo Companies, in its capacity as data controller, your rights specified below pursuant to article 11 of the PDPL.

In this regard, the rights you have are as follows:

  1. to learn whether any of the personal data is processed,

  2. to request information in relation to the activities if your personal data is processed,

  3. to learn the purposes of the processing of the personal data and whether these personal data are used in compliance with these purposes, 

  4. to be informed on the third parties within the country or abroad, that your personal data are transferred to,

  5. in case personal data are processed incompletely or inaccurately, to request the rectification of such incomplete or inaccurate data and to request that the action taken in this regard be notified to the third parties to which personal data are transferred,

  6. even though the personal data are processed in compliance with the PDPL and other relevant provisions of law, in case the bases for processing cease to exist, to request the deletion, destruction, or anonymization of the personal data within 30 (thirty) days pursuant to the provisions of the Regulation on Deletion, Destruction or Anonymization of Personal Data and to request that the action taken in this regard be notified to the third parties to which personal data are transferred,

  7. to object to the unfavorable results which may occur as a result of analyzing of personal data by automated means, and

  8. in case any damages due to unlawful processing of the personal data are suffered, to request compensation for the damage.

The requests specified above shall be conveyed to the Letgo Companies in their capacity as a data controllers in writing or by way of other methods to be determined by the Personal Data Protection Board (“Board”).

In this regard, you may deliver your request in relation to your above rights by using the e-mail address provided below, which may change from time to time, by using your registered electronic mail (REM) address, by using the electronic mail address with a secure electronic signature or mobile signature or the electronic mail address which was previously notified by you to the Letgo Companies and which is registered in the system of the Letgo Companies (by attaching documents which identify you) or you may deliver by hand with a wet signed petition or send your request via notary public by including documents which identify you to our mailing address, which, again is provided below and which may change from time to time.

The request, which you will make to use the rights specified above that you have as a data subject, and which includes the explanations in relation to the right you request to use, the issue requested by you must be clear and comprehensible, the matter requested by you must pertain to you or, in case you are acting on behalf of another person, you must specifically be authorized and such authorization must be documented and the request must include your identity and address information.

The Letgo Companies conclude the requests in the request form as soon as possible and at the latest within 30 (thirty) days free of charge (in case there is not any cost). However, if the transaction requires an additional cost, the fee determined by the Board may be charged. In case the replies to the requests exceed 10 (ten) pages, a transaction fee of TL 1.00 (one) will be charged per page. In case the reply is requested in a recording medium such as a CD or flash disc, a fee will be requested as per the cost of the requested recording medium.

Data Controller: Letgo Services B.V. and Letgo Mobil İnternet Servisleri ve Ticaret A.Ş. 

Mailing address: Ayazağa Mahallesi, Azerbaycan Caddesi, 2B Blok, No:3K İç Kapı No:13 Sarıyer, İstanbul

E-mail address: privacy@letgo.com

REM address: letgo@hs03.kep.tr 

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