Personal Data Protection Policy

Passenger Personal Data Protection Policy (“Policy”) includes information about the processes which BiTaksi Mobil Teknoloji A.Ş. (“bitaksi”) processes personal data of passengers. The Policy also includes explanations regarding the security of your personal data, the principles we consider when processing your personal data and your rights regarding your personal data.

If you have any questions regarding the processing of your personal data, you may contact us at kisiselveriler@bitaksi.com

You may click on the headings below to access the relevant section of the Policy:

Your Processed Personal Data
Channels and Methods of Collecting Your Personal Data
Processes of Processing Your Personal Data
Legal Grounds of Processing Your Personal Data
Situations Where We Share Your Personal Data
Rights Regarding Your Personal Data
Methods of Exercising Your Rights
Personal Data Processing Principles of bitaksi
Security of Your Personal Data
Terms Used In the Policy

1. Your Processed Personal Data

Identity Information: Name-surname, gender, passenger ID.
Contact Information: Phone number, e-mail, address and favorite address.
Payment Information: Instruments of payments, payment amount, payment method, payment and invoice details, first six and last two digits of the credit card.
Travel Information: Route of the travel, start and finish points, date, time and duration of the travel, amount and number of the travel.
Information Regarding Passenger Transactions: Request and complaints, call center records.
Location Information: Location information collected through your mobile device.
Transaction Security Information: Device operating system, IP address, user transaction on the application, password
Information Regarding Legal Transactions: Correspondence with judicial authorities, information on case/enforcement files in case of a dispute.
Risk Management: Information on the prevention of suspicious or illegal transactions.
Other: Comments, information about the cancellation and cancellation fee of the travel, scores, comments and tips given to the drivers, scores and comments given to the passengers by the drivers, language and mobile application preferences, discount code/campaign information, preferences and usage habits.

If you edit your pet and disability information in the “Profile” section of the bitaksi mobile application, we also process this information.

In addition, we process your preferences and usage habits and your information obtained as a result of the analysis of your data mentioned above (for example, the most preferred destinations).

We process your personal data through cookies to improve your mobile application experience. Click here for detailed information about bitaksi's use of cookies.

2. Channels and Methods of Collecting Your Personal Data

We collect personal data of mobile application users through the bitaksi mobile application.

If you call bitaksi customer services or if you contact us via info@bitaksi.com or our social media accounts, we collect your data through these channels.

Processing via partially automatic methods means that data processing is conducted partially with human intervention and partially with automated items (information systems). Processing via automatic methods is data processing that takes place spontaneously through information systems without human intervention.

In certain cases, we also collect your data in a physical environment, using non-automated methods, provided that it is a part of the data recording system (for example, if you physically transmit information or documents to us).

3. Processes of Processing Your Personal Data

bitaksi processes your personal data within the scope of the following processes in accordance with your mobile application account, your use of the application and our relationship with you.

Below is a summary of the types of personal data we process and the purpose of processing:

Process	Processed Data	Processing Purposes
Sign Up	Name-surname, e-mail, phone number, password, gender.	Signing up process to bitaksi mobile application and transactions regarding account creation, To verify your identity and ensure account activation.
Trip	Name-surname, passenger ID, address and favorite address, phone number, location, travel information, payment information, language and mobile application preferences, pet and disabled passenger preferences.	Receiving trip requests; ensuring that passengers are matched with available drivers, Ensuring that drivers and passengers confirm their positions and meet at the designated location, Ensuring that passengers take a taxi travel in accordance with their preferences, Conducting communication between bitaksi drivers and passengers (your contact information is not shared with bitaksi drivers), Conducting financial and accounting processes regarding payments.
Passenger Relations and Satisfaction	Name-surname, passenger ID, phone number, e-mail, comments, requests and complaints, call center records, scores, comments and tips given to the drivers, scores and comments given to the passengers by the drivers.	Communicating with passengers and managing our relationships with passengers, Conducting activities for the satisfaction of the passengers, Performing analysis to improve our services, Following up and concluding requests/complaints, Receiving and evaluating feedbacks regarding improvement of our services.
Marketing Activities	Name-surname, passenger ID, phone number, e-mail, discount code/campaign information, preferences and usage habits, travel information, payment information, marketing analysis, scores, comments and tips given to the drivers, scores and comments given to the passengers by the drivers, comments, requests and complaints, pet and disabled passenger preferences.	Informing you about campaigns and special offers in accordance with your communication preferences, Conducting marketing analysis in order you to benefit from our services in the most appropriate way, Introducing services offered by bitaksi, conducting marketing operations, Cooperating with third parties regarding special offers.
Other Processes	Name-surname, passenger ID, travel information, information about the cancellation and cancellation fees, payment information, correspondence with judicial authorities, information on case/enforcement files in case of a dispute, information on the prevention of suspicious or illegal transactions.	Conductingfraud risk assessments for safety and continuity of bitaksi operations, Informing you about innovations, updates and errors regarding the mobile application, Transactions related to cancellations and cancellation fees, Conducting our activities in accordance with the legislation, Conducting legal processes, Review and audit of our business operations.

For all the processes mentioned above, your transaction security information (device operating system, IP address, user transaction on the application, password) is processed in transactions performed via the mobile application.

Just as passengers can rate and comment on drivers through the mobile application, drivers also have the opportunity to rate and comment passengers. Passenger ratings and comments can only be viewed by bitaksi and are processed for the purpose of matching the parties that have given low scores to each other for passenger satisfaction, prioritizing high-scored passengers in the operation, improving and developing our services and considering the scorings/comments in possible conflicts.

4. Legal grounds of processing your personal data

We process your personal data based on the legal grounds stated in the Article 5 of the Law on the Protection of Personal Data. Your personal data is processed based on the below legal grounds:

a. Personal data processing is necessary for the establishment or performance of a contract

Processing of your personal data is directly related to the establishment and performance of the contract between you and bitaksi. For example, verifying your identity during signing up process and processing your personal data to sign you up is based on this legal ground.

b. Processing personal data for the establishment, execution or protection of a right

In cases where we process your personal data for establishment, execution or protection of a right, we rely on this legal ground. For example, if your objection about payments is deemed appropriate, it is based on this legal ground that we process your personal data to return the relevant amount to your card.

c. Personal data processing is mandatory for our legitimate interests

We rely on this legal ground when personal data is mandatory for our legitimate interests, provided that it does not harm fundamental rights and freedoms. For example, we process your pet information to direct you to taxi drivers suitable for pet transportation (we only process this information if you choose to share it with us).

We also conduct an assessment when determining whether a data processing activity is mandatory for our legitimate interests. While making this assessment, the criterias specified in the Decision of the Board dated 25/03/2019 and numbered 2019/78 are taken into account. We conduct balance tests by comparing the fundamental rights and freedoms of the person with the legitimate interest that will arise.

d. The data subject has provided explicit consent for the processing of his/her personal data

In the absence of legal grounds specified in Article 5 of the Law on the Protection of Personal Data, we ask for your explicit consent in order to process your data. In this context, for example, if you edit disabled information in the “Profile” section of our mobile application we process your information based on this legal ground.

If there is at least one of the legal grounds specified in the Law allowing us to process personal data, we do not ask the data subject’s explicit consent. We only ask explicit consent in the absence of other legal grounds stated in the Law.

Your location information is processed depending on whether you allow the use of location information in accordance with the operating system features of your mobile device. You may always change this preference in the "Settings" section of your mobile device.

Below we stated the legal grounds we are based on for each process:

5. Situations Where We Share Your Personal Data

We share your personal data with the following parties within the country or outside the country, for the following purposes:

Process	Legal Ground
Sign Up	Establishment or performance of the contract Establishment, execution or protection of a right
Travel	Establishment or performance of the contract Establishment, execution or protection of a right Data processing is mandatory for our legitimate interests
Passenger Relations and Satisfaction	Establishment or performance of the contract Establishment, execution or protection of a right Data processing is mandatory for our legitimate interests
Marketing Activities	Establishment, execution or protection of a right Data processing is mandatory for our legitimate interests
Other Processes	Establishment, execution or protection of a right Data processing is mandatory for our legitimate interests
Processes for Disabled Passengers	Explicit consent of the Data Subject

Purposes of Sharing the Personal Data	Shared Parties
Conducting communication between bitaksi drivers and passengers, ensuring that the drivers and passengers confirm their positions and meet at the specified location, ensuring that the trip are conducted in the most efficient way.	bitaksi Drivers
Getting support from suppliers related to our services, conducting financial and accounting operations, cooperating with third parties regarding special offers for users, managing business partner and supplier relations.	Suppliers and Business Partners
Informing the authorized persons, institutions or organizations, conducting legal processes and conducting our activities in accordance with the legislation.	Authorized Persons, Institutions or Organizations

Yandex infrastructure is used for mapping. For information about how Yandex processes personal data you may visit yandex.com.tr/legal/confidential

In case you want to share your travel information with your relatives, we share your travel information with your relative in accordance with your choice.

We use technologies that analyze the performance of our activities to learn how mobile application users respond to marketing activities, their interaction with our application, and how they use the mobile application. We share your information with our business partners for the use of these technologies.

6. Rights regarding your personal data

Article 11 of the Law on the Protection of Personal Dataregulates the rights regarding the processing of your personal data. These rights are as follows:

In addition, when we process your personal data based on your explicit consent, you have the right to withdraw your consent at any time by contacting us.

7. Methods of exercising your rights

You may use the following methods to submit your requests to bitaksi regarding the aforementioned rights:

8. Personal Data Processing Principles of bitaksi

While processing your personal data, we ensure compliance with the data processing principles stated in the Article 4 of the Law. These principles are as follows:

9. Security of Your Personal Data

We take the necessary technical and organizational measures to ensure the security of your personal data. Some of the measures we have taken in this context are as follows:

Data Subject	Natural person whose personal data is processed.
The Law	The Law on the Protection of Personal data dated 24/3/2016 and numbered 6698.
Personal Data Processing	Any operation performed on personal data such as collection, recording, storage, retention, alteration, re-organization, disclosure, transferring, taking over, making retrievable, classification or preventing the use thereof, fully or partially through automatic means or provided that the process is a part of any data registry system, through non-automatic means.
Board	Personal Data Protection Board
Passenger	People that bitaksi provides services through mobile application.
Data Controller	Natural or legal persons who determines the purpose and means of processing personal data and is responsible for establishing and managing the data registry system.

Passenger Personal Data Protection Policy