Trumore AI Radio Information Notice

Data Controller: Türkiye’nin Otomobili Girişim Grubu Sanayi ve Ticaret Anonim Şirketi (“Togg”)

Address: Muallimköy Mah. Deniz St. Bilişim Vadisi T.G.B. Site, Block 1.3.A, No. 143/9, Interior Door No. 105, Gebze/Kocaeli/Turkey

Introduction

At Togg, we place a high priority on the processing and protection of your personal data. This Information Notice is prepared in accordance with Article 10 of the Law No. 6698 on the Protection of Personal Data (“Law” or “KVKK”) and the Communiqué on the Procedures and Principles to Be Followed in Fulfilling the Obligation to Provide Information, and is intended to ensure that you, our users, are informed regarding the personal data processed and transferred during the provision of services within the scope of the Trumore AI Radio (“Trumore AIR”) application.

Identity information (first name, last name, date of birth); contact information (email address); and transaction security information (username, password) collected via electronic forms on the Membership and Profile Creation screens; as well as customer transaction information (Trumore ID; Apple Store ID; Google user information) collected through a third-party platform account when used to log in; solely for the purposes of creating a membership/account and establishing user profiles to use the Trumore AIR app, in accordance with Article 5, Paragraph 2 of the Law, which states, “The processing of personal data belonging to the parties to a contract is necessary provided that it is directly related to the establishment or performance of the contract”; if selected, other customer transaction information added during profile updates (biography, city of residence) is processed strictly for the purposes of personalizing your profile and app experience, and to provide personalized services and conduct activities aimed at customer satisfaction, in accordance with the legal grounds set forth in Article 5, Paragraph 2 of the Law, which states: "Processing of data is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.”

Limited to the purposes of personalizing your Trumore experience, creating an advanced profile (profiling), offering personalized products/services, campaigns, routes, and recommendations, conducting marketing, advertising, and promotional processes, and carrying out activities aimed at customer satisfaction

As part of the “Create Custom Playlists and Station Profiles” feature, customer transaction data obtained through the mobile app and your smart device (your vehicle’s location, traffic, weather) is processed with the limited purposes of personalizing your Trumore AIR experience, creating your profile, generating and presenting personalized content, and creating guidelines for custom melody composition, lyric writing, compositional architecture, and instrumentation, as well as carrying out activities aimed at customer satisfaction, in accordance with the provisions of Article 5, paragraph 2 of the Law “The processing of personal data belonging to the parties to a contract is necessary provided that it is directly related to the conclusion or performance of the contract” and “The processing of data is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.”

Your personal data is processed within the scope of the purposes listed above in accordance with Article 8 of the KVKK regarding domestic transfers and Article 9 regarding cross-border transfers, and by taking the necessary technical and administrative measures;

• If necessary, to fulfill our legal obligations as required by laws and regulations, based on the legal ground that “processing is necessary for the data controller to fulfill its legal obligations,” and in accordance with laws and regulations to which we are subject, upon a court order or a request from authorized administrative authorities, to authorized public institutions and organizations;
• Based on the legal ground that “the processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the conclusion or performance of the contract,” to our domestic suppliers;
• “Signing a standard contract,” to our suppliers located abroad.

Retention and Destruction of Your Personal Data

Unless a longer retention period is required by law, we retain your personal data in accordance with the Law for as long as necessary to achieve the purposes specified in this Privacy Notice.

When the legal basis for processing your personal data ceases to exist, your personal data is destroyed during the first destruction period in accordance with our Retention and Destruction Policy, by taking the necessary technical and administrative measures.

Your Rights Regarding Your Personal Data and How to Exercise Them

With regard to your personal data, as listed in Article 11 of the Personal Data Protection Law (KVKK):

• The right to learn whether your personal data is being processed,
• To request information regarding the processing of your personal data, if it has been processed,
• To learn the purpose of the processing of your personal data and whether it is being used in accordance with that purpose,
• To know the third parties to whom your personal data has been transferred, whether within or outside the country,
• To request the correction of your personal data if it has been processed incompletely or incorrectly,
• To request the erasure or destruction of personal data in accordance with the conditions set forth in the KVKK legislation,
• If you request the correction of incomplete or incorrect data or the erasure or destruction of your personal data, to request that this be notified to the third parties to whom your personal data has been transferred,
• To object to a decision made solely through the automated processing of personal data that adversely affects you, and
• to request compensation for any damage suffered as a result of the unlawful processing of your personal data.

You may submit your rights and requests regarding your processed personal data by using the email address registered in our systems to togg.kvkk@togg.com.tr , or by using your registered electronic mail (KEP) address along with a secure electronic signature or mobile signature to the registered electronic mail (KEP) address turkiyeninotomobili@hs01.kep.tr , or in writing to the following address: Muallimköy Mah. Deniz Cad. Bilişim Vadisi T.G.B. Site, Block 1.3.A, No. 143/9, Interior Door No. 105, Gebze/Kocaeli/Turkey. Additionally, you may choose to use the other methods specified in the Communiqué on the Procedures and Principles for Applications to the Data Controller.

Requests regarding your rights as set forth in Article 11 of the KVKK will be processed free of charge as soon as possible and no later than thirty days, depending on the nature of the request. However, if the process incurs additional costs, you may be charged a fee in accordance with the tariff determined by the Personal Data Protection Board.

Updates to the Privacy Notice

The Privacy Notice may be updated in line with changes to services and terms within the Trumore Mobile App, as well as regulatory developments. Notifications regarding updates to the Privacy Notice will be provided by Togg through the app.