General Clarification Text within the Scope of the Law on the Protection of Personal Data

1. Identity of the Data Controller

As Eurasia Tunnel Operation Construction and Investment Co. (“The Eurasia Tunnel” or “the Company”), we process your personal data and sensitive personal data with utmost care and high precision. Within this framework, we would like to inform you about how your data are processed and with whom and under which conditions they are shared.

2. Collection and Processing of Personal Data, Purposes of Processing

  • If you are an employee/contact person/partner/authorized officer of our real person customer or legal or real person trader customer (tunnel user) and, in some cases, a relative/representative of our customer:

    • When you pass through the Eurasia Tunnel (“the Tunnel”), your physical location safety data and plate number through the camera records for ensuring safety; when you have a problem in the Tunnel (accident, breakdown, health etc.), your identifying and contact details for the purpose of responding to and solving such problem, your plate number, physical location safety data and health data for being able to help you in terms of the health problem you have in that time, when you use the telephone available in the Tunnel in case of an emergency, your identifying details, plate number and voice call records for the management of emergency processes and your identifying details, contact details and plate number for the purpose of sending notifications about usage related changes regarding your passages through the Tunnel, information updates and alternative payment channels,
    • In case of illegal passage through the Tunnel, your identifying and contact details, plate number, your data on the vehicle registration document for the provision of debt information to you and for the follow-up of legal proceedings as well as any customer transactions (such as the information on passage through the Tunnel), physical location safety, finance (IBAN) data and voice call records,
    • Your identifying and contact details for ensuring and measuring customer satisfaction and accordingly, for the performance of a survey, assessment of and response to any complaints and requests, your physical location safety, finance (IBAN) data, information on your passage through the Tunnel, your voice call records and, if submitted by you, certificate of death, scrappage record of your vehicle, prosecution investigation document (concerning the theft of the vehicle/plate) and your health data (furthermore, your religion and blood group data available on your identity card may be indirectly obtained through the copy of your identity card/driving licence),
    • Your identifying and contact details, social media account data and plate for the purpose of launching campaigns, notifications and sweepstakes and giving the prizes as a result of the sweepstake through social media platforms, and
    • Your identifying and contact details, customer transaction data, plate number, legal proceeding data and, if required, your visual data for the purpose of carrying out and monitoring business activities, receiving and assessing any recommendations for the improvement of business processes, conducting activities for ensuring business continuity, performing finance and accounting procedures, following legal affairs, providing information to competent persons, authorities and organizations upon request and managing data security processes will be able to be processed
    will be able to be processed in a limited manner in order to carry out the abovementioned activities in compliance with the applicable legislation and the policies and procedures of the Eurasia Tunnel. Moreover, your personal data will be able to be transferred to physical archives and information systems and thus, be stored both in digital and physical media.
  • If you are an authorized signatory/employee/contact person of our real person traders or legal person suppliers/consultants/business partners:

    • Your identifying and contact details, finance data (IBAN), SSI service scheme, professional experience, legal proceedings, visual and audio records, your transaction security data (furthermore, your religion and blood group data which are available in identity cards and directly obtained through the copies of identity cards/driving licences will be able to be processed) for the purpose of managing contractual processes, performing goods and service procurement processes within the scope of the activities of our Company, managing access authorizations and communication activities, carrying out and monitoring business activities, performing business continuity activities, managing customer satisfaction related requests and complaints, conducting legal, financial and accounting procedures, managing information security processes and retention and archive processes, providing information to competent persons, authorities and organizations upon request, conducting corporate communication activities and managing organizations and events, and
  • If you are an authorized signatory/employee/contact person of our real person traders or legal person subcontractors:

    Your identifying and contact details, personnel information, finance data, professional experience, visual and audio records, physical location safety data, legal proceedings, your transaction security data and health, criminal conviction and safety precautions data mong your sensitive data as well as your religion and blood group data available in your identity card and your religion and blood group data that are indirectly obtained through the copy of your identity card/driving licence for the purpose of managing contractual processes, ensuring physical location safety, managing and monitoring access authorizations and business activities, ensuring business continuity, performing legal, financial and accounting activities, managing information security processes and retention and archive processes, providing information to competent persons, authorities and organizations upon request and managing organizations and events including production procedures will be able to be processed in a limited manner in order to carry out the abovementioned activities in compliance with the applicable legislation and the policies and procedures of the Eurasia Tunnel. Moreover, your personal data will be able to be transferred to physical archives and information systems and thus, be stored both in digital and physical media.

    Moreover,

    • If you visit our Company and/or registered offices, your identifying, contact and physical location safety data for the purpose of ensuring physical location safety and establishing visitor records,
    • If you make use of the wireless network connection provided by our Company, your identifying, contact and transaction security data for the purpose of keeping the logs in electronic environment in order to fulfil the obligations arising from the applicable legislation under the Law No. 5651 and managing information security processes,
    • If you contact with us through our call centre, your identifying and contact details and voice record for the purpose of meeting amount information requests and complaints, managing customer relations and ensuring customer satisfaction
    will be able to be processed in a limited manner for the performance of activities in compliance with the applicable legislation and the policies and procedures of the Eurasia Tunnel. Moreover, your personal data will be able to be transferred to physical archives and information systems and thus, be stored both in digital and physical media.

3. The Persons to Whom the Processed Personal Data May Be Transferred and the Purposes of Such Transfer

Your collected personal data will be able to be transferred to governmental agencies and institutions, audit firms, law offices, banks, courier companies, public relations and social media agencies, real persons or legal persons subjected to private law whose services are procured by us or with whom we are in collaboration including our domestic and foreign business partners and suppliers, controlling corporations of our Company for the sake of ensuring compliance with the policies and procedures of the Company and the group of companies with whom the Company is associated and to the systems of the domestic and foreign firms rendering technology services for the purposes set forth in article 2 of this Clarification Text, according to the applicable Law and related legislation, due to the reasons requiring the transfer and in a limited manner to these reasons.

4. Method and Legal Basis of Personal Data Collection

In compliance with the purposes provided in article 2 of this Clarification Text and with the fundamental principles set forth in the Law, your personal data are collected from your direct complaint forms, e-mails, mails, telephone or fax channels, call centre, website and social media accounts that are made either verbally or in writing with automatic or non-automatic methods, from any applications or requests submitted to us, from respective competent authorities and organizations and any applications and systems used by the Company, closed circuit camera systems, from the scrappage record of your vehicle, if it is scrap, and from the firms whose services are procured by you on the basis of and in a limited manner to the legal obligation of the data controller establishment, exercise or protection of the right, performance of the agreement and the legal bases of legitimate interests of the data controller provided in article 5 of the Law.

5. Your Rights for Personal Data Protection

Within the frame of the legislation on the protection of personal data, you are entitled to learn whether your personal data are processed or not; request information on this regard, if they are processed; learn the purpose of processing and if they are used by us in accordance with these purposes; learn any third parties in Turkey and abroad to whom they are transferred; request the correction thereof if they are incompletely or incorrectly processed and, in case of transfer, the notification of such correction to any third parties to whom they have been transferred; request the deletion or destruction of the same if the conditions of processing are eliminated and, in case of transfer, notification of such deletion or destruction to any third parties to whom they have been transferred; raise an objection if you consider that it results against you due to the analysis of the processed data exclusively through automatic systems and request the indemnification of your loss if you incur a loss as a result of unlawful processing of the same. You can submit your requests within the scope of article 11 of the Law regulating the rights of data subjects personally and in writing to the Operation and Maintenance Building of the Eurasia Tunnel located at the address of Barbaros Mahallesi Dr. Eyüp Aksoy Caddesi No: 9 34662 Üsküdar, İstanbul, Turkey against your identity confirmation through the form available at https://www.avrasyatuneli.com/_assets/pdf/kvkk-basvuru-formu.pdf pursuant to the “Notification on the Procedures and Principles for Application to the Data Controller” or by sending an e-mail to our Company at avrasyatuneli@hs01.kep.tr or at veri.sorumlusu@avrasyatuneli.com with your safe electronic or mobile signature or by other means specified in the Law and applicable legislation after your identity is confirmed.

Your Company will finalize any application requests within not later than 30 (thirty) days depending on the nature of the request according to article 13 of the Law. In the event that this procedure requires a cost, the tariff designated by the Personal Data Protection Board will be applied. If the request is rejected, the reason(s) of such rejection will be justified in writing or electronically.

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