Last updated: 07.06.2023

This privacy statement establishes the rules for how any data and information processed by Vestel Ticaret Anonim Şirketi ("Vestel," "We," "Our", "Us", “Our Company”) during the use of the Vestel Drive Green Application ("Application") by users who have registered as members (the "Member(s)" of the Application) will be used in connection with the use of an electric vehicle charger (“Appliance”).

We, Vestel Ticaret Anonim Şirketi operate this Vestel Drive Green Application. Please use the contact information provided on the “Contact Information” field to get in touch with us.

If you get in touch with us, we will store and process the information you provide for the purpose of handling your enquiry and any follow-up questions. We will delete your information once your enquiry has been handled.

When we use the term “personal data”, we are referring to any information that can be used, directly or indirectly, to identify you personally. We process your personal data in accordance with the General Data Protection Regulation (“GDPR”).

This Policy may be updated to notify you when a new feature is installed, or the Application is updated. Your personal data will be processed in accordance with the old version of the Policy until you use the new features. If necessary, the updated Policy will be sent to you through the email address you provided.

1. PERSONAL DATA COLLECTED

Vestel collects information from Members who use the Application, such as details about the Appliance, including its MAC ID, hardware model, serial number, and Appliance settings. The company also collects information provided by Members when they sign up for the Application, such as their name, email, username, and password.

Additionally, Vestel collects information about interactions through the Application and Appliance, like grid voltage operating time and received current information during charging charging history, and any bugs, errors, or defects. All this information is used to enable Members to access the features and services of the Application.

2. THE PURPOSE OF COLLECTING PERSONAL DATA AND LEGAL BASIS

We, as well as our service providers, process your personal data for the following purposes

a) Creating and managing accounts and updating information as needed.

Legal Basis: The data processing is needed for the performance of a contract to which you are party or to take the steps requested by you prior to entering a contract (Art. 6 (1) lit. b GDPR).

b) Verifying your information to ensure accuracy and compliance with legal obligations.

Legal Basis: It is legal responsibility to ensure that personal data is accurate and up to date. Therefore, the data processing is necessary for compliance with a legal obligation to which we are subject (Art. 6 (1) lit. c GDPR).

c) Contacting you to provide assistance, maintenance or other services for your Appliance.

Legal Basis: The data processing is needed for the performance of a contract to which you are party or to take the steps requested by you prior to entering a contract (Art. 6 (1) lit. b GDPR).

d) Enabling you to use the services offered by the Application.

Legal Basis: The data processing is needed for the performance of a contract to which you are party or to take the steps requested by you prior to entering a contract (Art. 6 (1) lit. b GDPR).

e) Ensuring your satisfaction and responding to your requests, including complaints.

Legal Basis: The data processing is needed for the purposes of the legitimate interests pursued by Vestel, the controller, or a third party, except where those interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data (Art. 6 (1) lit. f GDPR).

f) Improving your Appliance usage experience and developing new services.

Legal Basis: The data processing is needed for the purposes of the legitimate interests pursued by Vestel, the controller, or a third party, except where those interests are overridden by the interests

or fundamental rights and freedoms of the data subject which require protection of personal data (Art. 6 (1) lit. f GDPR).

g) Making statistical evaluations to support product development and commercial activities.

Legal Basis: The data processing is needed for the purposes of the legitimate interests pursued by Vestel, the controller, or a third party, except where those interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data (Art. 6 (1) lit. f GDPR).

2.1 PROCESSING IP ADDRESS INFORMATION OF THE USERS

Vestel may determine and use the IP address of the User when required to detect the issues regarding the Appliance or the Application and to forthwith settle the issues that may arise. IP addresses may also be used to identify the User in a general way and to collect comprehensive demographic information.

Legal Basis: The data processing is needed for the purposes of the legitimate interests pursued by Vestel, the controller, or a third party, except where those interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data (Art. 6 (1) lit. f GDPR).

2.2 PROCESSING LOCATION INFORMATION OF THE USERS

If the Users approve, the location information of the Users is processed by Vestel for the following purposes:

(i) Obtaining address information so that you can use the nearest authorized service in case of a malfunction of your device,

(ii) During the installation process of your device, the wifi SSID information is required for your device to be controlled remotely by connecting over the internet, so that you can easily select by listing the nearest wifi devices.

Legal Basis: Your consent is required only for the processing of some of your personal data or the use of your processed personal data for certain purposes. As a result, your location data can only be processed with your permission (Art. 6 (1) lit. a GDPR)

You can always prevent the Application from accessing your location by going to your phone’s location services section.

2.3 PROCESSING PERSONAL DATA FOR MARKETING ACTIVITIES

If you give us your consent, your personal information is processed to send you push notifications about the marketing activities mentioned below through Application and is shared with our suppliers from whom We get service for this purpose:

Informing you about discounts, sales, advertisements, deals, campaigns, promotions, and special offers from both our Company and our business partners.
Conducting surveys and other activities for measuring customer satisfaction.

You can withdraw your consent by sending us an email using the provided in the contact details or from "Settings" section in the Application.

Legal Basis: The legal basis for the processing of your personal information for marketing purposes is your consent. As stated in this section, therefore, the processing of your personal data for marketing purposes is only permissible with your consent (Art. 6 (1) lit. a GDPR)

2.4 PROCESSING YOUR PERSONAL DATA WITHIN THE SCOPE OF SUPPORT FEATURE
Our Company strives to address any issues quickly and effectively you encounter while using the Application or Appliance. If you contact us through the user support section, We will promptly evaluate the problem and provide all necessary assistance to ensure your satisfaction.

To solve your complaints and improve customer satisfaction, We will process the information you provide in the support section, including your account information such as name, surname, email address, country and Appliance related information such as Serial Number, User ID and MAC ID and details about the problem you are experiencing and an image of malfunction.

If your issue requires technical support, We may need to share your personal data with third parties from whom we get service for this purpose, including your name, surname, address, and phone number. This is necessary only in cases where on-site intervention is required, and this process is done with the greatest of caution care to protect your privacy and security.

Legal Basis: The data processing is needed for the purposes of the legitimate interests pursued by Vestel, the controller, or a third party, except where those interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data (Art. 6 (1) lit. f GDPR), and

Legal Basis: The data processing is needed for the performance of a contract to which you are party or to take the steps requested by you prior to entering a contract (Art. 6 (1) lit. b GDPR).

2.5 PROCESSING OF YOUR PERSONAL DATA WITHIN THE SCOPE OF MAKE A SUGGESTION FEATURE The make a suggestion feature was created solely to identify the Appliance issues. Your specified personal information will only be used for product development, and you will not receive any feedback regarding the suggestion you encountered.

In this regard, your personal information, including information about your Appliances (Device ID, MAC ID, Local IP, Software Version, Model), will be processed and transferred to hosting providers.

Legal Basis: The data processing is needed for the purposes of the legitimate interests pursued by Vestel, the controller, or a third party, except where those interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data (Art. 6 (1) lit. f GDPR).

3. PARTIES TO WHOM PERSONAL DATA IS TRANSFERRED

We take the protection of your personal data seriously and only share it with select parties for specific purposes, including:

Suppliers who provide software, maintenance, and security services, and host personal data related to our information technologies.
Business partners with whom we have a contract to provide additional services through the Application or manage emails. These partners are responsible for protecting your personal data based on their contracts with us.
Regulatory or official agencies, as necessary, to comply with legal obligations or requests, fulfill service or sales conditions, ensure service security or integrity, and protect the rights, properties, or safety of Vestel, our employees, users, or third parties.
Our legal advisors, as necessary, to protect the legal rights of Vestel or third parties.
In the event of a sale, merger, bankruptcy, asset sale, or company restructuring, your personal data may be disclosed or transferred to another company. If this occurs, your personal data will continue to be processed in accordance with this Privacy Policy.

Rest assured that We take all necessary precautions to ensure that your personal data is protected and processed only for the purposes outlined above.

We may share anonymous data with Vestel Group companies without disclosing your identity for the development of customer, product, and service evaluations and analyses and the performance of various statistical evaluations. After the anonymization of such details and information, Vestel Group companies may also use the same for all kinds of income generating activities.

4. INFRASTRUCTURE OF ANALYTICS PROVIDERS

We may use third-party Web analytics services in connection with the services provided relating,

Mobile application performance metrics and crash reports.
Remote configuration for software update mechanism.
Mobile application installation statistics.
Sending push notifications to users.
Segment audience, report and intents and actions of customers.
Integration with third party services to facilitate the application.
Infrastructure Services to build and maintain the app.
Grow and engage user base.

5. DATA RETENTION

Vestel processes the personal data for as long as it is necessary to achieve the intended purposes pursuant to Section 2 above. The personal data collected for the purposes of Section 2, will be retained for the period strictly necessary to respond to data subjects' requests and pursue Vestel business interests and comply with applicable laws and regulations.

6. RIGHTS OF DATA SUBJECTS

As Data Subject, you have and, at any time and at no charge, can exercise the following rights:

to be informed on the purposes and methods of the processing of your Personal Data.
to access your Personal Data.
to ask for updating or rectification of the Personal Data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
to request erasure of your Personal Data. This enables you to ask us to delete or remove your Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing or where we are required to erase it to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
to restrict the processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish its accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
to object to the processing, wholly or partly, of your Personal Data where we are relying on legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your Personal Data which override your rights and freedoms.
where we are relying on consent to process your Personal Data, to revoke your consent freely and at any time.
to ask us to transfer your Personal Data to you or to a third party (so-called “data portability”). We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
to lodge a complaint to the Data Protection Authority if you believe that your personal data have been processed in violation of the applicable legislation (You can reach the respective Data Protection Authority.

7. CONTACT INFORMATION

The User who desires to request more information regarding our compliance with the legislation, to inform questions, concerns or complaints related to this Privacy Policy or to exercise the right of claim under the legislation, may contact us via the postal address Organize Sanayi Bolgesi, 45030 Manisa / Turkey, by sending an e-mail to the address vmh@vestel.com.tr or by calling the hotline 0850 222 4 123.

Vestel may amend the provisions of this Privacy Policy at any time. The provisions of the Privacy Policy which Vestel has amended shall enter into force on the date they are published.