As a customer of Koluman Otomotiv Endüstri Anonim Şirketi (“KOE”), your personal data is collected, processed, and transferred by KOE, acting as the data controller, in accordance with the Personal Data Protection Law No. 6698 (“KVKK” or the “Law”), under the conditions explained in detail below. With this text, KOE informs you, as its customer, about the processes of collection, processing, and transfer of your personal data, as well as your rights within the scope of the Law.
KOE acts as the ‘data controller’ as defined in Article 3/1-(ı) of the Law in the processes of processing your personal data, determining the purposes and means of processing.
As the data controller, KOE is obliged to establish and manage the data recording system and to take administrative and technical measures regarding data security. Within this scope, KOE may also have your data processed by third parties acting as ‘data processors’ as defined in Article 3/1-(ı) of the Law.
As a KOE customer, your personal data in the categories detailed below are processed.
| Data Category | Data Types |
|---|---|
| Contact | E-mail, phone number |
| Vehicle and Telematics Data | E-mail, password, account creation information, real-time location (GPS), speed, route, battery/voltage information, EBS / ABS / ROP / VDC / TPMS sensor data, axle loads, brake pressures, door status, fault codes, service history, telematics unit connection/status information, etc. |
| Operational and Support Data | Service requests and service notes, support communication contents, billing and transaction records, etc. |
| Technical Data | Device ID, IP address, application version, log records, error reports, etc. |
Your personal data is collected by KOE, within the scope of the legal grounds and processing purposes explained below, through the information and documents you provide in order to log in to the Koluman Smart application and website; via online accounts such as e-mail addresses created on behalf of your vehicle; automatically or non-automatically, verbally, in writing, or electronically.
Personal data collected by KOE is processed, primarily by KOE, in accordance with the principles set forth in Article 4 of the Law and based on the data processing condition specified in Article 5/II-c, for the purposes of providing vehicle tracking and telematics services; conducting vehicle performance monitoring and fault detection processes; planning maintenance and service activities; project development; ensuring security; detecting misuse and fraud; managing customer accounts and providing user support; carrying out billing, operational, and internal process management; and fulfilling legal obligations.
Your personal data collected by KOE may be transferred, for the purposes explained in this text, to KOE’s authorized personnel, service providers, shareholders, legally authorized public institutions, and private individuals, within the framework of the personal data processing conditions and purposes specified in Article 8 of the Law, and to the extent permitted and required by other applicable legislation, including but not limited to those listed above.
Your personal data collected by KOE are processed within the scope of the purposes explained in this text, except for obligations arising from legal regulations, for the period necessary for the purpose for which they are processed during and after the login process to the Koluman Smart application and website, or for the maximum period stipulated by the laws (180 days). After the expiration of the specified period, your personal data are deleted, destroyed, or anonymized in accordance with Article 7 of the Law.
As a data subject, pursuant to Article 11 of the Law, by applying to KOE as the data controller, you have the right to:
You may submit your requests regarding these rights by filling out the “Koluman Otomotiv Endüstri Anonim Şirketi Personal Data Processing Application Form” available at https://www.kolumanotomotiv.com/tr/kurumsal and using the methods specified in the form.
SINCERELY,
KOLUMAN OTOMOTİV ENDÜSTRİ ANONİM ŞİRKETİ
We, as Koluman Otomotiv, place great importance on the security of your personal data shared with us. Accordingly, we exercise the utmost care to ensure that your cookie data is processed and protected in compliance with the applicable laws. You may access detailed information regarding cookies in our Cookie Policy.