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Entrance

KVKK policy According to Article 20 of the Constitution of the Republic of Turkey, everyone has the right to demand the protection of personal data concerning him/her. With this personal data protection policy created by Volta Motor San ve Tic. A.Ş. (“Volta”) as the Data Controller regarding the protection of personal data, which is a constitutional right; the process of securely protecting the processed personal data of real persons such as company employees, job applicants, interns, suppliers, supplier employees, subcontractors, subcontractor employees, customers, third parties and visitors will be managed. All necessary administrative and technical measures have been taken by Volta to protect the processed personal data in accordance with the Law on the Protection of Personal Data No. 6698 and secondary legislation.

Aim

Volta's main purpose in implementing this KVKK policy is to ensure the security of personal data processed automatically or non-automatically, provided that it is part of any data recording system, of the above-mentioned real persons, primarily company employees, with whom it has a legal and commercial relationship, through administrative and technical measures taken within the scope of personal data processing and data protection activities carried out in accordance with the law.

Scope

The KVKK policy is related to all personal data of Volta’s employees, customers, subcontractors, subcontractor employees, suppliers, supplier employees, job applicants, interns, third parties, customers and visitors, processed automatically or non-automatically as part of any data recording system.

Data Controller
Purpose of Processing Personal Data

In this context, Volta processes personal data for the following purposes:

– Carrying out corporate sustainability activities,
– Management of relations with suppliers and subcontractors,
– Carrying out personnel recruitment processes,
– Carrying out internal audit and legal procedures,
– Carrying out corporate management and communication activities,
– Request and complaint management,
– Providing information to authorized persons or organizations arising from the legislation,
– Creation and monitoring of visitor records,

If the processing activity carried out for the purposes mentioned above does not meet any of the conditions stipulated under Law No. 6698, Volta will obtain explicit consent from the data owners for the relevant processing process.

Personal Data
Principles of Processing

Volta Motor San. Ve Tic. carries out its work within the scope of the basic principles adopted in the processing of personal data within the scope of this Policy and listed below:

Processing personal data in accordance with the law and rules of integrity,
Keeping personal data accurate and up-to-date when necessary,
Processing personal data for specific, clear and legitimate purposes,
Processing personal data in a way that is relevant, limited and proportionate to the purpose for which they are processed,
To store personal data for the period stipulated in the relevant legislation or necessary for the purpose for which they are processed,
Enlightening and informing personal data owners,
Establishing the necessary system for personal data owners to exercise their rights,
Taking necessary measures to protect personal data,
Acting in accordance with the relevant legislation and the Personal Data Protection Board regulations when transferring personal data to third parties in line with the requirements of the processing purpose,
To show due sensitivity to the processing and protection of special personal data.

Personal Data
Conditions of Processing

Volta processes personal data under the conditions listed below within the scope of the KVKK policy:

If the processing of personal data is clearly prescribed by law,
If the processing of personal data is directly related to and necessary for the establishment or performance of a contract,
If it is necessary for Volta to fulfill its legal obligations, If personal data has been made public by the data owner,
If the processing of personal data is necessary to establish, exercise or protect the rights of the data owner or third parties,
If personal data processing is necessary for Volta's legitimate interests, provided that it does not harm the fundamental rights and freedoms of the data owner,
Personal data is processed if the personal data processing activity is necessary to protect the life or physical integrity of the personal data owner or another person, and if the personal data owner in this case is unable to give his consent due to actual or legal invalidity.

Personal Data
Ensuring Security

Volta takes all necessary technical and administrative measures in accordance with current technological possibilities and practices to ensure that personal data is processed in accordance with the law. In this context;

The system established within the scope of personal data processing activities carried out within the company by IT experts assigned by Volta to ensure that personal data is processed in accordance with the law is audited by the IT Department and the technical measures taken are periodically reported to the company's senior management in accordance with the internal audit mechanism.

Employees are trained and their knowledge and awareness levels are increased regarding personal data protection law and the lawful processing of personal data.

By analyzing the business processes carried out by all units operating within Volta, personal data were defined, data processors were identified, job descriptions were made, and a data processor contract was signed with each of them.

Personal data processing activities carried out by all units of Volta are determined in accordance with the personal data processing conditions sought by Law No. 6698.

Records are included in the documents that set out the legal relationship between Volta and its employees, interns, job candidates, subcontractors and suppliers, imposing obligations not to process, disclose, use or share personal data in violation of the law, and the awareness of employees and other people on this issue is increased and audits are carried out.

Volta takes technical measures in line with technological developments, and the measures taken are periodically updated and renewed.

Access authorizations to Personal Data are limited, authorization matrices are created, and authorizations are reviewed regularly.

Software and hardware including virus protection systems and firewalls are installed.

Applications that collect personal data are regularly scanned to detect security vulnerabilities.

Employees are informed that personal data acquired as a requirement of their job cannot be disclosed to anyone else contrary to the provisions of Law No. 6698 and cannot be used for purposes other than those for which they are processed, and that this obligation will continue after they leave office, and the necessary commitments are obtained from them in this regard.

Volta adds provisions to the contracts (confidentiality agreements) concluded with its subcontractors and suppliers with whom it has business relations, stating that the necessary security measures will be taken and that these measures will be complied with in its own organisations.

Backup programs are used in accordance with the law to ensure the safe storage of personal data.

Access to data storage areas where personal data is located is logged and any inappropriate access or access attempts are instantly communicated to the relevant parties.

Data Owner's Rights
and Application Process

The rights held by Volta in accordance with Article 11 of Law No. 6698 regarding personal data shared with the company within the scope of the purposes and processing methods of personal data specified in this Policy are listed below:

Learning whether personal data is being processed,
To request information regarding the processing of personal data,
To learn the purpose of processing personal data and whether the data is used in accordance with its purpose,
To inform third parties that personal data is transferred domestically or abroad,
To request correction of personal data if it is processed incompletely or incorrectly,
Request the deletion or destruction of personal data within the framework of the conditions stipulated in Law No. 6698,
To object to a result that is to the detriment of the person himself/herself, as a result of the analysis of the processed data exclusively through automatic systems,
In case of damage caused due to unlawful processing of personal data, the person has the right to demand compensation for the damage.

In order to exercise the rights listed above, you can contact our company using the “Application Form” on our website http:/www.volta.com.tr and the methods specified in this form. Requests submitted by the personal data owner in accordance with the application above will be finalized by Volta free of charge within thirty days at the latest, depending on the nature of the request.

Storage of Data
Durations and Disposal Method

KVKK policy Volta stores personal data for the periods stipulated in the relevant laws, legislation and the “Personal Data Storage and Destruction Policy”. If no period is stipulated in the legislation regarding how long personal data will be stored, the data is stored and subsequently deleted, destroyed or anonymized according to the activities and practices carried out by Volta and the customs required by the company's commercial life. However, although the purpose of processing personal data has ended; the data may be stored for the purpose of constituting evidence in possible legal disputes, asserting the relevant right related to personal data or establishing a defense. Even in such cases, stored personal data cannot be accessed for other purposes, and access is provided only for the purpose of being used in relevant legal disputes. In any case, at the end of the said period, personal data is processed using one or more of the technical methods specified in the “Personal Data Storage and Destruction Policy” that are most suitable for the company's business processes and activities. Records kept regarding camera monitoring are deleted every 30 days.

Group of Persons Whose Data is Processed
and Data Categories

Volta processes the data of the following persons within the scope of this Policy. These are natural persons such as company employees, job applicants, interns, suppliers, supplier employees, subcontractors, subcontractor employees, third parties and visitors. According to the Labor Law No. 4857, Volta processes the identity, contact, location, family and relationship, criminal record, visual, education, finance, personnel, health and biometric data of persons working under an employment contract and whose personal data is obtained through business relationships. Within the scope of Law No. 4857, the identity, contact, criminal record, visual, finance, personnel and health information of natural persons employed by subcontractors who receive work in a part of the main job or in auxiliary jobs and of employees employed by suppliers with whom supplier contracts have been signed for the purpose of procuring services; the identity, contact, visual, signature and financial information of subcontractors and suppliers; and the identity, contact, visual, signature and financial information of natural persons doing internships within the scope of Law No. 3308 on Vocational Education; It processes the identity, contact, criminal record, visual, financial, personnel and health information of the candidate employees who have applied for a job by any means or have made their CV and related information available for review by our company; the identity, contact, education and location information of third parties such as family members, relatives and former employees who are not covered by this Policy; and the identity and visual information of real persons who are visitors to the physical premises owned by the company for various purposes.

Personal Data
Transfer of

Volta may transfer the personal data of data owners governed by this Policy, in accordance with Articles 8 and 9 of Law No. 6698, to the following categories of persons:

– To Volta’s top officials,

– To the authorities of Volta,

– Legally authorized persons, institutions and organizations, Legally authorized private law persons,

Volta does not transfer the personal data it processes within the scope of this policy abroad. The relevant legal regulations in force regarding the processing and protection of personal data are primarily applied. In the event of any inconsistency between the current legislation and the Policy, Volta accepts that the current legislation will be applied. It may make changes or updates to this Policy in line with new legal regulations and company policy. The new policy text reflecting all these changes and updates is announced to the relevant persons via the website. Cookies are used on the www.volta.com.tr web page to track the site usage habits of online visitors.

Cameras in Buildings and Facilities
Monitoring Activities

Volta camera monitoring activities are carried out in accordance with the Law on Private Security Services and relevant legislation, Law No. 6698 and the personal data processing conditions listed in the “Volta Motor San ve Tic. A.Ş. Camera Monitoring Policy”. Camera monitoring activities are carried out to ensure the security of the company and the health and safety of other individuals. Data owners are informed about the camera monitoring activities carried out by Volta in accordance with Article 10 of Law No. 6698. Camera recordings are not shared with anyone other than authorized persons, institutions or organizations.

Force

This Policy, which will be implemented by Volta Motor San. ve Tic. A.Ş., will enter into force on August 9, 2019.