Disclosure on Processing of Personal Data under KVKK

This Disclosure has been prepared by K-C TEKS.OTO.NAK.İTH.İHR.TUR.SAN.VE TİC.LTD.STİ ("KC Filo") as data controller, pursuant to the Turkish Personal Data Protection Law No. 6698 ("KVKK") and the Communiqué on Principles and Procedures to be Followed in Fulfilling the Obligation to Inform, to explain the purposes for which your personal data is processed, the legal grounds relied upon, with whom data may be shared, and your rights.

1. Identity of the Data Controller

Company: K-C TEKS.OTO.NAK.İTH.İHR.TUR.SAN.VE TİC.LTD.STİ
Trading as: KC Filo
Address: Atatürk Oto Sanayi Sitesi 2. Kısım No: 614–615, Maslak, Sarıyer / İstanbul
E-mail: info@kcfilo.com
Phone: +90 212 286 65 67

2. Personal Data Processed

Within the scope of its services, KC Filo may process the following categories of personal data:

• Identity data: Name, surname
• Contact data: Phone number, e-mail address, company address
• Corporate data: Company name, tax identification number, tax office
• Vehicle & operational data: Vehicle plate, lease duration, annual mileage preference, request description
• Technical data: IP address, browser type and version, session information (anonymised)
• Visual and document data: Photos and documents uploaded via online service forms (damage, penalty notice, document submission)

3. Purposes of Processing

Your personal data is processed for the following purposes:

• Evaluating quote requests and ensuring customer communication
• Establishing and performing operational leasing contracts
• Handling maintenance, damage, tyre and other fleet management requests
• Fulfilling legal obligations and notifications to official authorities
• Ensuring website security and the sound operation of technical infrastructure
• Managing complaints and applications

4. Legal Basis for Processing

Your personal data is processed on the following legal grounds under Article 5 of KVKK:

• Art. 5/2-(c): Directly related to the establishment or performance of a contract — leasing applications and contract processes
• Art. 5/2-(ç): Fulfilment of a legal obligation — tax, social security, traffic legislation requirements
• Art. 5/2-(f): Legitimate interest, provided it does not harm the fundamental rights and freedoms of the data subject — site security, statistical analysis
• Art. 5/1 — Explicit Consent: Only for non-mandatory processing not covered by the above grounds

5. Data Transfers

Under Article 8 of KVKK, your personal data may be shared with the following parties only to the extent necessary:

• Insurance companies and agents within the scope of services
• Authorised maintenance, service and tyre suppliers
• E-mail and communication infrastructure service providers
• Lawyers, financial advisors and auditors (subject to confidentiality obligations)
• Relevant public authorities and judicial bodies (where legally required)

Your personal data is not transferred outside Turkey under any circumstances.

6. Retention Periods

Your data is deleted, destroyed or anonymised when the purpose of processing ceases to exist, subject to applicable statutory retention periods:

• Contract-related data: 10 years after contract expiry
• Invoice and accounting records: 10 years (Tax Procedure Law Art. 253)
• Occupational health and safety records: 10 years
• Quote-only records (applications that did not become contracts): 2 years
• Technical and log data: 1 year

7. Rights of Data Subjects (KVKK Art. 11)

Under Article 11 of KVKK, you have the following rights:

• To learn whether your personal data is being processed
• To request information if your personal data has been processed
• To learn the purpose of processing and whether it is being used in accordance with that purpose
• To know the third parties to whom personal data has been transferred domestically or abroad
• To request correction of incomplete or inaccurate personal data
• To request deletion or destruction under Article 7 of KVKK
• To request notification of correction and deletion to third parties to whom data has been transferred
• To object to a result arising against you through automated analysis of processed data
• To claim compensation for damages arising from unlawful processing

8. How to Exercise Your Rights

To exercise the above rights, you may submit a written request, together with documents establishing your identity, via the following channels:

• E-mail: info@kcfilo.com
• Post / in person: Atatürk Oto Sanayi Sitesi 2. Kısım No: 614–615, Maslak, Sarıyer / İstanbul

Your request will be concluded free of charge within 30 (thirty) days at the latest, in accordance with Article 13 of KVKK. Where a request entails additional cost, a fee may be charged according to the tariff determined by the Personal Data Protection Authority.

9. Updates to this Disclosure

KC Filo reserves the right to update this Disclosure in line with changes to KVKK and related legislation or developments in data processing activities. The current version is always available on this page.