Privacy Policy

Last Updated: 26.09.2024

Doc Version	Date
1	26.09.2024

The “EVC Wizard” mobile application and Web Config UI website(“Application”) has been designed by Vestel Ticaret Anonim Şirketi (“We”, “Our”, “Us”, or “Company”) for the purpose of enabling various settings of the EVC charger (“Appliance”). The objective of the Privacy Policy (“Policy”) is to outline the terms and conditions pertaining to the handling of data shared by the users (“User(s)”) during account creation or acquired from the Appliance during the usage of the Application.

We place the highest priority on personal data security. In line with this commitment, the processing of your personal data is carried out in strict compliance with the General Data Protection Regulation (“GDPR”), the Turkish Personal Data Protection Law No. 6698 (“TDPL”), and the local legislation in your country of residence.

If you are a resident of the European Economic Area (EEA) or if your personal data is processed as part of activities within the EEA, the GDPR applies to the processing of your personal data. Similarly, if you are a Turkish citizen or if your personal data is processed in Turkey, the processing of your personal data is subject to the TDPL.

Within the context of this Policy, the term "Personal Data" refers to any piece of information that can be used, either directly or indirectly, to identify you on a personal level.

If you have any questions about this Policy or your personal data, you can contact Us using the details in the "Contact Information" section. Upon contacting Us, your personal data will be processed to efficiently address your request and any subsequent queries. Once your request is resolved, pertinent data will be duly erased.

Please note that this Policy may be revised from time to time, typically when new features are introduced or updates to the Application are made. You can access the updated Policy via the Application.

1. PERSONAL DATA COLLECTED

a) Directly Provided Personal Data: This includes the information you submit when logging into Our Application;

Your User ID and Password

b) Appliance-Connected Personal Data: This covers the information provided by the Appliance that you connect to through Our Application;

Hardware and Software Information of the Appliance, Log Records of Users' Actions on the Appliance (Changes made to the Appliance settings).

c) Personal Data Provided from the Application and Smart Device: This includes information provided through the Application and your smart device on which you use the Application; Hardware and Software Information of the Application and Smart Device, Log Records of Users' Actions on the Application and Smart Device (Changes made in the Application settings, records regarding Users' consents)

The personal data of Users is exclusively collected from the Application, the Appliance and the smart devices on which the Application is used.

* The User ID and Password information (including QR Code) contained in the User Manual are unique to you. We strongly recommend that you do not share this information with third parties and change it after purchasing the product.

2. THE PURPOSE OF COLLECTING PERSONAL DATA AND LEGAL BASIS

We process your personal data for the following purposes:

1. Logging into the Application and performing account management operations.

• Legal Basis: The data processing is necessary for the performance of a contract to which you are a party or to take steps requested by you prior to entering a contract (Art. 6 (1) lit. b GDPR; Art. 5 (2) lit. c TDPL).

2.  Providing assistance, maintenance and technical support services for your Appliance.

•  Legal Basis: The data processing is necessary for the performance of a contract to which you are a party or to take steps requested by you prior to entering a contract (Art. 6 (1) lit. b GDPR; Art. 5 (2) lit. c TDPL).

3. Improving the Appliance usage experience of the User and developing the services as well as creating new services.

• Legal Basis: The data processing is necessary for the purposes of the legitimate interests pursued by Us, 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 the protection of personal data (Art. 6 (1) lit. f GDPR; Art. 5 (2) lit. f TDPL).

1. PROCESSING LOCATION INFORMATION OF THE USERS

If the Users approve, approximate location information is processed by Vestel for the purpose of developing products and services by statistically determining in which cities the Application is used.

You can easily stop the Application from accessing your location by going to the location services settings on your phone and your other smart devices.

• Legal Basis: The processing of your location information is only permitted if you provide explicit consent (Art. 6 (1) lit. a GDPR; Art. 5 (1) TDPL).

2.2 DOWNLOADING APPLIANCE LOGS

If you would like to store the log records related to actions performed on the Appliance on your smart device, you can download these records to your smart device. We need your consent to proceed with this process.

• Legal Basis: This process is only permitted if you provide explicit consent (Art. 6 (1) lit. a GDPR; Art. 5 (1) TDPL).

3. PARTIES TO WHOM PERSONAL DATA IS TRANSFERRED

Your personal data will be shared only with the following persons and for the following purposes:

• Suppliers from whom services are provided in terms of software, maintenance, and security, as well as hosting personal data within the scope of information technologies.
• Personal data may be shared with third parties for the purpose of providing assistance, maintenance and technical support services for your Appliance.
• Personal data may be shared when it is reasonably necessary to comply with any law, regulation, or valid legal notification (e.g., summons or writs notified to Us) or a request made by an official or regulatory agency, fulfill service use conditions or sales conditions, ensure the security or integrity of the service, and/or protect the rights, properties, or safety of Us, Our employees, users, or third persons.
• Personal information may be shared with Our legal advisor to protect Our or third parties' legal rights.
• We may disclose or transfer your personal data in relation to any sale, merger, bankruptcy, asset sale, or restructuring of Our company. Please note that your personal data will be processed by another company, and this Privacy Policy will continue to apply for your personal data transferred to such a company in such cases.

4. DATA RETENTION

We process 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 Our business interests and comply with applicable laws and regulations.

5. RIGHTS OF DATA SUBJECTS

You have certain rights in relation to your Personal Data, depending on the applicable data protection and privacy laws. If you would like further information in relation to these or would like to exercise any of them, please contact Us. You have the following rights and may send to Us a request for exercising any of these rights:

1. Right of access.  You have a right of access to any Personal Data we hold about you.  You can ask Us for a copy of your Personal Data, confirmation as to whether your Personal Data is being used by Us, details about how and why it is being used and details of the safeguards which are in place if we transfer your information outside of the EEA, UK, Serbia or Switzerland.
2. Right to rectify and update (correct or complete) your information:  You have a right to request a rectification and an update to any of your Personal Data which is out of date or incorrect.
3. Right to erase/delete your information:  You have a right to ask Us to delete any Personal Data which we are holding about you in certain specific circumstances.  -

We will pass your deletion request onto other recipients of your Personal Data unless that is impossible or involves disproportionate effort.  You can ask Us who the recipients are, using the contact details set out this Privacy Policy.

4. Right to restrict the processing and use of your information: You have a right to ask Us to restrict the way that we process your Personal Data in certain specific circumstances.  You can ask Us for further information on these specific circumstances by contacting Us using the details set out in this Privacy Policy.  

We will pass your request onto other recipients of your personal data unless that is impossible or involves disproportionate effort.  You can ask Us who the recipients are using the contact details set out at the start of this Privacy Policy.

5. Right to stop direct marketing: You have a right to ask Us to stop using your personal data for direct marketing purposes.  If you exercise this right, we will stop using your personal data for this purpose.
6. Right to data portability: You have a right to ask Us to provide your personal data to you or a third-party provider of services. 
7. Right to object.  You have a right to ask Us to consider any valid objections which you have to Our use of your Personal Data where we process your personal data based on Our or another person's legitimate interest.
8. Right to withdraw your consent. You have a right to withdraw any consent that you have given Us.
9. Right to give instructions for after your death (if you are located in France): You have the right to provide instructions on the use (retention, erasure and communication) of your Personal Data after your death. These instructions can be general or specific. You can amend or revoke these instructions at any time.
10. Right to request compensation (if you are located in Bosnia and Herzegovina, Turkey, Serbia or Sweden): You have the right to request compensation for any damage arising from the unlawful processing of your personal data.

6. 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 Holland B.V. is Our GDPR representative in Europe for Our EU-based data subjects. You can get in touch with them at vmh@vestel.com.tr If you have any GDPR-related questions or want to exercise your GDPR rights, Vestel Holland B.V. is here to help.

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