1. *Introduction*
CIPTAXI Transfer (Villadom İnşaat Emlak Turizm LTD ŞTİ) places great importance on protecting the personal data and privacy of its users. This section details how the personal data collected, processed, and stored by CIPTAXI Transfer is handled and how the security of this data is ensured. In accordance with the Law No. 6698 on Personal Data Protection (“KVKK”), we declare that we respect the rights of our users and have taken all necessary measures to protect these rights.

2. *Collection of Personal Data and Collection Methods*
CIPTAXI Transfer collects personal data to the extent necessary for the services it provides to its users. Personal data consists of information provided directly by the user and data automatically collected through the digital platforms provided by CIPTAXI Transfer (mobile application, website, customer services, etc.).

2.1 *Data Provided by the User:*
– *Identity Information:* Information for identity verification and personal identification, such as name, surname, T.C. identity number, and date of birth.
– *Contact Information:* Information that allows communication with the user, such as phone number, email address, and residential address.
– *Payment Information:* Financial data used in payment transactions, such as credit card information and bank account numbers.
– *Service Preferences:* Information related to service customization, such as preferred vehicle type, travel route, and preferred driver when using CIPTAXI Transfer services.

2.2 *Automatically Collected Data:*
– *Device Information:* Technical data such as the IP address of the device, device type, operating system, and browser type when accessing CIPTAXI Transfer’s mobile app or website.
– *Usage Information:* Data related to the frequency of use, the way services are utilized, and the clicking and browsing behavior on CIPTAXI Transfer platforms.
– *Location Information:* Real-time location data collected through mobile devices, if the user grants permission. This data is used for trip planning and more efficient service delivery.

3. *Purposes of Processing Personal Data*
CIPTAXI Transfer processes the collected personal data for specific and legitimate purposes. These purposes include:

3.1 *Service Delivery and Management:*
– Provision of VIP transportation and transfer services requested by the user.
– Carrying out and managing reservation transactions.
– Providing customized services according to the user’s service preferences.

3.2 *Communication:*
– Providing users with information about services, confirmations, reminders, and updates.
– Evaluating user complaints and suggestions, and providing customer service support.
– Marketing activities and announcing special campaigns for users (subject to the user’s consent).

3.3 *Payment Transactions and Financial Management:*
– Carrying out and securing payment transactions made by the user.
– Conducting billing procedures.
– Safely storing financial information related to the user.

3.4 *Fulfilling Legal Obligations:*
– Storing records that are mandatory by law.
– Providing information requested by official authorities.
– Processing data that needs to be used in legal processes and sharing it with judicial authorities.

3.5 *Security and Quality Management:*
– Ensuring the security of CIPTAXI Transfer platforms and user accounts.
– Preventing fraud, scam, and unauthorized transactions.
– Conducting user satisfaction and usage analysis to improve service quality.

4. *Storage and Security of Personal Data*
CIPTAXI Transfer stores the personal data it collects in data centers located within the borders of the Republic of Turkey. Personal data is stored for the period determined in accordance with KVKK or for the periods required by legal obligations. At the end of the retention period, personal data is securely deleted, destroyed, or anonymized in accordance with CIPTAXI’s data destruction policies.

4.1 *Data Security Measures:*
– *Encryption:* Financial information of users (such as credit card information) is protected using high-level encryption methods during transmission and storage.
– *Access Controls:* CIPTAXI Transfer grants access to personal data only to authorized personnel, who are trained in data security.
– *Penetration Testing and Security Audits:* CIPTAXI Transfer regularly conducts penetration tests and security audits to detect security vulnerabilities, ensuring data is protected from unauthorized access.
– *Data Backup:* CIPTAXI Transfer regularly performs data backup operations to prevent data loss and stores the backed-up data in secure environments.

5. *Sharing Personal Data with Third Parties*
CIPTAXI Transfer does not share users’ personal data with third parties. However, the following situations may constitute exceptions:

5.1 *Legal Obligations:*
Personal data may be shared as required by legal requests from official authorities. CIPTAXI Transfer evaluates such requests in accordance with KVKK and only shares the necessary information.

5.2 *Sharing with Service Providers:*
CIPTAXI Transfer may cooperate with external service providers (such as payment processors, cloud service providers) to provide certain services. In such cases, service providers are required to ensure the confidentiality of personal data, and the data is shared only for the purpose of providing the relevant service.

5.3 *Anonymized Data:*
CIPTAXI Transfer may share anonymized user data with third parties for statistical analyses, market research, and service development purposes. Anonymized data does not contain any information that can identify individual users.

6. *User Rights*
Under KVKK, CIPTAXI Transfer users have the following rights:

6.1 *Right to Information:*
Users have the right to learn whether CIPTAXI Transfer processes their personal data. If it is being processed, they have the right to request information about the data.

6.2 *Right to Rectification and Update:*
Users have the right to request the correction and updating of their personal data if it is incorrect or incomplete.

6.3 *Right to Deletion and Destruction:*
Users have the right to request the deletion, destruction, or anonymization of their personal data in accordance with the conditions set forth in Article 7 of KVKK.

6.4 *Right to Object:*
Users have the right to object to the result of the analysis of their personal data solely through automated systems, which may lead to a decision that negatively affects them.

6.5 *Sharing Personal Information when Necessary:*
CIPTAXI Transfer does not share your personal information with third parties. However, as required by the functionality of the application, certain information may need to be shared between the driver and passenger. Details such as location information, contact numbers, name, and vehicle information are shared only between the user and the driver to enable the application to function properly.