Privacy Notice Pursuant to the Law on Personal Data Protection

1. Identity of Data Controller

As Avrasya Tüneli İşletme İnşaat ve Yatırım A.Ş. (hereinafter shall be briefly referred as "Avrasya Tüneli" or "the Company"), we process your personal data and your sensitive personal data with utmost care and diligence. Accordingly, we would like to inform you about methods processing of your data and parties that might receive such data as well as conditions of sharing your data. 

2. Collecting, Processing Personal Data and Purposes of Processing

Your personal data might be processed for offering the best Company services to you and for performing operational and maintenance works of the Eurasia Tunnel however the purpose might vary depending on the service or activity provided by our Company.

  • If you are our natural person customer or employee / contact person / partner / authorized officer of our legal entity or natural person commercial customer (tunnel user) and, in certain cases, if you are a relative / representative of our client
  • If you use the Eurasia Tunnel ("the Tunnel"): your physical space safety data and license plate number might be processed for assuring safety and through the video surveillance records as well as your ID and contact details, license plate number, physical space safety data and your health data to help you if you are having a health condition at that moment for responding to any incident (accident, malfunction, health problems etc.) or solving a problem in case of an incident taking place in the Tunnel; your ID data, license plate number and recording of your call for managing emergencies if you use  the emergency phones in the Tunnel; your ID, contact details and license plate number for informing you about the changes related to your tunnel passes and use, updated information as well as alternative payment channels.
  • If you pass the Tunnel by violating rules of passage; your ID and contact details, license plate number, your data on the vehicle license, customer transaction (such as tunnel pass info), physical space safety, financial (IBAN) data and record of your phone call for informing you about your debt and following up the legal formalities.
  • Your ID and contact details, physical space safety, financial (IBAN) data, tunnel pass data, records of your calls to the company, death certificate if submitted by you, your vehicle's scrap report and public prosecution office's investigation record (confirming the vehicle / license plate is stolen) and your health data for assuring and assessing customer satisfaction as well as doing customer satisfaction surveys and handling complaints and requests; (furthermore your religion and blood type details written on the ID cards might be indirectly obtained with the ID card / driver's license)
  • Your ID and contact details, social media account information and license plate number for offering and announcing campaigns, notices and sweepstakes and for sending gifts after such sweepstakes through the social media platforms.
  • Your ID, contact details, customer transaction, license plate and customer transaction data for conducting and supervising the business activities; receiving and reviewing suggestions for improvement of the business processes; assuring business continuity and conducting business activities; managing financial and accounting transactions; following up legal formalities and for informing the authorized persons, organizations and establishments if demanded and for running information security processes.

Furthermore;
Your following personal data might be processed for the following reasons however this processing shall be limited to the purposes specified in the regulation and must comply with the Eurasia Tunnel policy and procedures:

  • If you visit our company and / or workplaces; your ID, contact and physical space safety data for assuring physical security of the place and creating visitor logs
  • If you use the wireless network connection provided by our company; your ID, contact and transaction security details for keeping electronic logs and running information security processes as required for fulfilling our obligations arising from the regulation pursuant to the Law numbered 5651
  • If you contact us through our call center; your ID, contact, voice recording and amount details for handling requests and complaints, completing customer relationship management processes and assuring customer satisfaction.

Your personal data might be transferred to our Company's physical archives and IT systems and the data might be kept both in digital platforms and physical platforms.

3. Potential Recipients of Processed Personal Data and Purposes of Transfer

Your personal data might be collected and then transferred to the following parties for the purposes explained in Article 2 of this Privacy Note and also based on and limited to the incidents requiring such transfer under the Law and related regulation; government organizations and establishments, audit companies, law offices, banks, courier service companies, PR and social media agencies, natural personal or private law legal entities working for us and cooperating with us including our domestic and foreign business partners and suppliers, systems of firms providing technology services in and out of the country and also Company's affiliated group companies.

4. Method of Collecting Personal Data and Legal Reasons

Your personal data shall be collected from complaint forms submitted directly by you verbally or in writing through automated or non-automated methods, applications or requests forwarded to our company by e-mail, mail, phone, fax channels and through call center, website and social media accounts as well as toll collection systems, Aselsan pass systems, closed circuit surveillance systems and from record of scrap if your vehicle is scrapped and also from firms providing us services; this collection of your personal data shall be for the purposes listed in Article 2 of this Privacy Note and in accordance with the primary principles specified under the Law and provided that such collection, which must be based on and limited to legal obligations of the data controller; establishment, use or protection of the rights, performance of an agreement and legitimate interests of the data controller, as specified by Article 5 of the Law.

5. Rights for Personal Data Protection

You have the following rights under the regulation on Personal Data Protection; to learn whether your personal data has been processed or not; if processed, details of processing; to learn the purpose of processing your personal data and whether your data has been used for the intended purposes or not; to know the third party recipients that received your personal data in the country or abroad; to request the correction of the personal data processed incompletely or inaccurately, if any, and to request notification of the third parties, if your personal data has been processed; to request the erasure or destruction of your personal data if your personal data are no longer necessary in relation the purposes of processing, and, if transferred, to request notification of third party recipients; to object to the processing of your personal data if processed exclusively by automatic systems and leads to a result against your legitimate interests and also to request compensation of damages if you suffer from any damages due to illegal processing of your personal data.

If you want to make a request under Article 11 of the Law which governs the rights of the related person, you may use the form available on www.avrasyatuneli.com/kvkk and send the form personally to veri.sorumlusu@avrasyatuneli.com e-mail address in writing in accordance with the "Communique on Procedures and Principles of Application to the Data Controller" and your ID must be verified; or send it to our company's e-mail address avrasyatuneli@hs01.kep.tr or our company's veri.sorumlusu@avrasyatuneli.com e-mail address with your secure electronic or mobile signature or you may use the other channels listed in the Law and related regulation provided that your ID is verified.

In accordance with Article 13 of the Law, our company shall finalize your application and requests considering the nature of your request and within a maximum period of 30 (thirty) days. If this process requires any costs, the tariff announced by the Personal Data Protection Board shall be applied. If the request is denied, the reason / reasons of refusal shall be explained in writing or through the online platform.

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Information and Approval Form for Commercial E-mails

Eurasia Tunnel Operation Construction and Investment Joint Stock Company (“ATAŞ”) would like to send commercial e-mails to you to define the products and services offered within the scope of its marketing, promotion, advertisement and introduction activities, provide information about new products and services as well as any campaigns and promotions or inform you about other details and innovations considered to be attractive for our customers. We kindly request from you to complete the following text and give an approval to receive commercial e-mails from us.

The approval to be given by you for the delivery of commercial e-mails by ATAŞ is optional and at your discretion. If you give an approval for the delivery of commercial e-mails, you may subsequently reject to receive electronic e-mails from ATAŞ at your discretion as of your request without showing any justification thereof. Within this framework, ATAŞ shall fulfil your request to suspend the delivery of such e-mails through some or all communication channels on the basis of the options provided in the e-mails sent to you.

ATAŞ shall comply with all applicable legislations including but not limited to the Law on the Electronic Commerce Arrangements and the Directive concerning Commercial Communication and Commercial E-mails during the delivery of the abovementioned commercial e-mails to you.

I hereby declare that I give an approval for the delivery of commercial e-mails by Eurasia Tunnel Operation Construction and Investment Joint Stock Company ("ATAŞ") through the communication channels provided by me to define the products and services offered within the scope of its marketing, promotion, advertisement and introduction activities, provide information about new products and services as well as any campaigns and promotions or inform you about other details and innovations considered to be attractive for me as a customer.

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