In-Vehicle Camera Recording Disclosure Statement

IN-VEHICLE CAMERA RECORDING INFORMATION NOTICE

This “Information Notice” is prepared by AKKURTLAR TURİZM NAKLİYE VE GIDA SAN. TİC. LTD. ŞTİ. in accordance with Article 10 of the Personal Data Protection Law No. 6698 (“PDPL”), to inform and enlighten you regarding the processing, transfer, collection methods, and legal basis of your personal data, including visual and audio records obtained via security cameras used in our vehicles to ensure safe travel, as well as your rights under Article 11 of the PDPL.

We would like to state that we show the utmost sensitivity regarding the confidentiality and security of all personal data you provide, especially those containing audio and video, and that we take all necessary technical and administrative security measures to protect this data.

Data Controller Identity

In accordance with the PDPL, as AKKURTLAR TURİZM NAKLİYE VE GIDA SAN. TİC. LTD. ŞTİ., we act as the Data Controller and inform you that we will collect, record, store, process, classify, and update your personal data as needed, and share it with third parties within the scope of the law and relevant legislation, for the purposes specified below, in a lawful and fair manner.

Processed Personal Data

A closed-circuit camera system (CCTV) is used in the personnel service vehicles owned by our company, and visual and audio recordings containing personal data are obtained.

Purposes of Processing Personal Data

Camera recordings are processed for the following purposes:

To ensure the safe provision of transportation services,
To ensure the safety of employees and passengers,
To maintain in-vehicle order and discipline,
To improve and audit service quality,
To provide evidential information in case of possible judicial/administrative incidents,
To manage internal audit and security processes,
To fulfill legal obligations.

Within this scope, your personal data is processed based on the legal grounds set out in Article 5 of the PDPL, particularly “the legitimate interest of the data controller” and “legal conditions for data processing.”

Camera footage is collected automatically via closed-circuit camera systems installed inside vehicles, and processed under Article 5/2-f of the PDPL based on the legitimate interest of the data controller.

In addition, pursuant to Articles 5/2-ç and 5/2-e of the PDPL, such recordings are made for legitimate purposes such as ensuring passenger and employee safety, monitoring service quality, and obtaining evidence in possible legal/administrative cases.

If the recordings are required by regulation for specific services (e.g., mandatory camera systems in commercial taxis/public transportation vehicles), the following sentence should be added:

In certain cases, camera recording may become a legal obligation due to regulations imposed by public authorities. In such cases, the recordings are processed in accordance with the relevant legal framework.

Transfer of Personal Data

The personal data collected may be transferred within the scope of Article 5 of the PDPL to the following individuals and organizations:

Authorized public institutions and organizations (such as courts, law enforcement agencies),
The company’s legal advisors and attorneys,
If necessary, contracted IT and digital security firms,
Third-party institutions and organizations receiving transport services, and subcontractors or service providers working with these parties.

Transfers are carried out strictly within the limits of Articles 8 and 9 of the PDPL.

Method and Legal Grounds of Data Collection

Your camera footage is collected automatically through closed-circuit recording systems installed in vehicles and is processed under:

Article 5/2-f: "Processing is necessary for the legitimate interests of the data controller,"
Article 5/2-a: (if applicable) based on explicit consent,
Article 5/2-ç: "Processing is necessary for the establishment, exercise, or protection of a right."

Retention Period

Camera recordings are retained for the period required by their purpose and the maximum duration specified in legislation. After the retention period, data is destroyed in accordance with Articles 7 and 17 of the PDPL and the Regulation on the Deletion, Destruction, or Anonymization of Personal Data.

Rights of the Data Subject

According to Article 11 of the PDPL, 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 the processing and whether it is used appropriately,
To know the third parties to whom your data has been transferred domestically or abroad,
To request correction of incomplete or inaccurate data,
To request deletion or destruction of data if the reasons for processing no longer exist,
To request notification of these corrections or deletions to third parties,
To object to results arising from automated data processing if it has adverse effects,
To claim compensation for damages caused by unlawful processing.

Notice and Announcement

This information notice is publicly displayed in visible areas inside our vehicles equipped with recording systems and is also provided to employees in written and/or digital form.

To exercise your rights in this scope, you must submit your requests in "writing" or via the methods specified by the PDPL to AKKURTLAR TURİZM NAKLİYE VE GIDA SAN. TİC. LTD. ŞTİ.. As the Personal Data Protection Authority has not yet specified any alternative methods, written submission is currently required. You may deliver your written request in person along with identity verification documents to:

AKKURTLAR TURİZM NAKLİYE VE GIDA SAN. TİC. LTD. ŞTİ., Abdurrahmangazi Mah. Hasanağa Cad. No:14/A, Plaza Sancaktepe / Istanbul

Alternatively, you can send your request via notary or with a secure electronic signature.

By boarding the service vehicles operated by AKKURTLAR TURİZM NAKLİYE VE GIDA SAN. TİC. LTD. ŞTİ., you are deemed to have been informed of this notice and to have irrevocably declared, accepted, and undertaken your consent for all audio and video recordings to be processed and shared in accordance with the PDPL No. 6698.