Vehicle Camera System Personal Data Subject Information Notice

1. Information

This Information Notice has been prepared so that the data controller, Transay Taşımacılık ve Personel Hizmetleri Tic. A.Ş. (referred to in this text as “TRANSAY”), processes all personal data of natural persons obtained through vehicle cameras in accordance with Law No. 6698 on the Protection of Personal Data (referred to in this text as the “Law”) and other legislative provisions.

Through this Information Notice, it is intended that the activities carried out by TRANSAY continue and develop in compliance with the principles set forth in the Law.

2. Processed Personal Data and Collection Methods

Your personal data is collected automatically through camera systems in electronic form.

Vehicle Camera System Personal Data Subject Information Notice

Data Category	Processed Data
Physical Space Security Data	Image and Audio Recordings

3. Legal Grounds and Purposes of Personal Data Processing

Your personal data may be processed by TRANSAY for the purposes and legal grounds specified below. If there is any change in the purpose of processing your personal data, your separate consent will be obtained.

3.1. Legal Grounds

Your personal data processed within the scope of this activity carried out within TRANSAY;

1. It is necessary for the data controller to fulfill its legal obligation,
2. Provided that it does not harm the fundamental rights and freedoms of the data subject, processing is necessary for the legitimate interests of the data controller
and accordingly it is processed for the purposes set out below.

3.2. Purposes

1. To serve as evidence within the scope of security, inspection, and investigation activities,
2. To enable rapid action and intervention in emergencies,
3. To ensure driving safety and supervision in vehicles owned and/or serviced by TRANSAY.
4. To ensure that the transportation service provided by TRANSAY is delivered reliably, continuously, and under the best possible conditions.
5. To increase customer satisfaction to the highest level.
6. To carry out and improve operations and to fulfill the requirements of the contracts concluded.

4. Transfer of Personal Data and Purposes of Transfer

Subject to being limited to the personal data required by the processing, your personal data processed by TRANSAY is collected through various channels for the purpose of carrying out TRANSAY activities, on the legal grounds of ensuring compliance with legislation and Company policies. Your collected personal data may be transferred by TRANSAY, in accordance with the fundamental principles prescribed by the Law and within the conditions and purposes for personal data processing set out in Articles 8 and 9 of the Law, directly or indirectly, to our business partners, suppliers, service providers and/or subcontractors, both domestically and abroad, and to public institutions and organizations authorized by law as well as private law natural and legal persons authorized by law, for the purposes of conducting legal processes and fulfilling obligations arising from legislation and legal obligations.

5. Ensuring the Security and Confidentiality of Personal Data

In accordance with Article 12 of the Law, TRANSAY takes all necessary technical and administrative measures to ensure an appropriate level of security in order to prevent the unlawful processing and access of the personal data it processes and to ensure the protection of personal data. If the processed personal data are obtained by others through unlawful means, TRANSAY shall notify the Personal Data Protection Board and the relevant person as soon as possible.

6. Retention Period of Personal Data Obtained Through Camera Monitoring Activity

The recorded personal data will be retained in accordance with the law and legal requirements and will be stored for the maximum period stipulated in the relevant legislation or required for the purpose for which they were processed and, in any event, for the statutory limitation periods.
The retention period of personal data obtained through cameras by TRANSAY is 15 days.

7. Deletion, Destruction, and Anonymization of Personal Data

In accordance with Article 7 of the Law, although personal data have been processed in compliance with the relevant legislation, if the reasons requiring their processing cease to exist, the personal data shall be destroyed ex officio or upon the request of the relevant person by TRANSAY, using the method deemed appropriate in accordance with our retention and destruction policy prepared in consideration of the legislation on the protection of personal data.

8. Rights of the Data Subject

In accordance with Article 11 of the Law, by applying to TRANSAY, you may submit requests regarding your personal data on the following matters:

1. To learn whether your personal data are being processed,
2. If your personal data have been processed, to request information regarding such processing,
3. To learn the purpose of processing your personal data and whether they are used in accordance with that purpose,
4. To learn the third parties to whom your personal data are transferred domestically or abroad,
5. To request correction of your personal data if it is incomplete or incorrectly processed, and to request that the transaction carried out within this scope be notified to third parties to whom the personal data have been transferred,
6. To request the deletion, destruction, or anonymization of your personal data if the reasons requiring their processing cease to exist, and to request that the transaction carried out within this scope be notified to third parties to whom the personal data have been transferred,
7. To object to the emergence of a result against the data subject by analyzing the processed data exclusively through automated systems,
8. To claim compensation for damages in the event that you suffer damage due to the unlawful processing of your personal data.

Data subjects may complete the “TRANSAY Data Controller Application Form” found at www.transay.com.tr in Turkish and submit their applications and requests under the Law by;

1. Applying in person with their identity to the e-mail address [email protected] or to the head office address listed on our website, or sending it through a notary,
2. Or sending it via registered electronic mail (KEP) to [email protected], with a secure electronic signature and mobile signature.

TRANSAY shall conclude application requests free of charge in accordance with Article 13 of the Law, depending on the nature of the request and within 30 (thirty) days at the latest. If the request is rejected, the reason(s) for the rejection shall be communicated in writing or electronically, together with the justification.

This Information Notice was prepared on 10.04.2026. This Information Notice may be revised by TRANSAY when deemed necessary. In the event of any change in the statement text, the effective date and content of this Information Notice shall be updated.