FORD OTOMOTİV SANAYİ ANONİM ŞİRKETİ
(SHORTLY “DEALERS”) FOR SATISFACTION SURVEYS
(“Privacy Policy”)
Ford Otomotiv Sanayi Anonim Şirketi (“Ford Otosan” or “Company”) attributes great importance to the secure and transparent processing of your personal data in conformity with the law and good faith. This Privacy Policy (“Policy”) is prepared for the objective of explaining how and for which purposes data relating to you will be processed and how you can manage your rights.
Below, you will find an explanation of general principles for the processing of personal data by Ford Otosan, the purposes for which your personal data is processed and the rights that you have concerning your personal data since you are an employee of Ford Trucks’ Dealers.
Ford Otosan exports Ford branded Heavy Commercial Vehicles (“Ford Trucks”) to countries in the European Economic Area (EEA) to its Importers, which are authorized by Ford Otosan to sell Ford Trucks and provide repair and maintenance services through its Authorized Dealers and Repairers Network (“Ford Trucks Export Operations”). Hence it is important for us to understand your satisfactionand take necessary actions to improve this under Ford Truck Export Operations.
This Privacy Policy has been executed in English.
General Information
While, being an entity located in the Republic of Turkey, Ford Otosan shall comply with the provisions of the Law No. 6698 on the Protection of Personal Data (“Law No. 6698”), the European General Data Protection Regulation (“GDPR”) and National Data Protection Law applicable in your region (“Applicable National Data Protection Law”) as far as these laws apply for the processing of personal data by Ford Otosan.
Data Controller:
Ford Otomotiv Sanayi Anonim Şirketi
Akpınar Mahallesi, Hasan Basri Cad. No:2, 34885 Sancaktepe, İstanbul, Turkey
Company Registry No: 73232
Representative (Art. 27 para. 1 GDPR):
JURCOM GRC SERVICES B.V.
Willemsweg 94 6531 DN Nijmegen, Netherlands
Data Protection Officer of Ford Otosan:
You may approach the Data Protection Officer at dpo@ford.com.tr or by addressing a letter to the “Data Protection Officer” at the address of the Data Controller.
What is Personal Data?
“Personal Data” means any information relating to an identified or identifiable individual (a data subject) in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
How do we collect Personal Data?
We collect your personal data through our systems related to Ford Truck Operations.These data may be entered into system directly by you or Dealer whom employs you.
Furthermore, Ford Otosan may collect and process Personal Data like your email address or phone number when:
• you contact Ford Otosan, or request that Ford Otosan contacts you, for any reason, or
• you submit your Personal Data to Ford Otosan for any reason.
Which Personal Data do we collect?
Ford Otosan collects and transfers your name, surname and e-mail address in order to conduct satisfaction survey and take necessary action to improve this under your employment relationship with our Dealers.
We do not process sensitive Personal Data of special categories, as well as any biometric personal data.
For Which Purposes Is Your Personal Data Processed?
The purpose of processing your Personal Data is to plan and execute Satisfaction Surveys and take necessary actions in order to improve your satisfaction.
The following types of processing Personal Data are applied: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission or transfer, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
You may find additional detailed information about the purposes of processing Personal Data by Ford Otosan on its Policy on the Processing and Protection of Personal Data, which has been made available to the public through the https://www.fordtrucks.com.tr/en/privacy-notice-and-consent-letter-for-ford-trucks-importers .The aforementioned Policy on the Processing and Protection of Personal Data shall be applied in conjunction with this Policy. However, to ensure observance of the GDPR in case of its applicability, provisions of this Policy have always priority.
Legal Basis for Processing Personal Data
Depending on the purposes of processing and the circumstances, in processing your Personal Data we may rely on the following legal bases in the priority of their order below:
• The processing is necessary in connection with any contractual relationship that you may enter into with our Dealers under Ford Truck Operations
• We have a legitimate interest in carrying out the processing for the purpose of assessing your satisfaction andmanaging, improving our operations accordingly. (If you like to receive detailed information on the legitimate interests on which we base our processing, please send us an e-mail to gdprrep@ford.com.tr.); or
• We have obtained your explicit prior consent to the processing.
We refer to Art. 6 para. 1 (a), (b) and (f) GDPR.
Where May We Receive Your Personal Data From?
Ford Otosan collects Personal Data directly from you and/or Dealer whom employs you.
Who May Access Your Personal Data?
Ford Otosan processes the Personal Data alone or together with its shareholders or may give assignment to third parties to process your data. If we are involving data processors into the performance of our services and contractual obligations, we have entered into data processing agreements with them. Ford Otosan may also transfer your Personal Data within the scope of this Policy to business partners, subcontractors, affiliates, shareholders in particular to Ford Motor Company and its vendors and business partners in the US, legally authorized public institutions and individuals in order to realize the above-mentioned data processing purposes within the framework of this Policy.
Ford Otosan and some of its third parties are located outside the EU, which have not been subject of an adequacy decision of the EU commission pursuant to Article 45 GDPR. Ford Otosan will ensure that the level of data protection guaranteed by the GDPR will be upheld by
• Concluding EU Standard Contractual Clauses in accordance with Art. 46 para. 2 (c) GDPR or
• Regarding the U.S., applying the EU U.S. Privacy Shield according to Art. 46 para. 2 (f) GDPR in connection with Decision (EU) 2016/1250 of the European Commission dated July 12, 2016.
Further information may be obtained by e-mail to gdprrep@ford.com.tr .
International transfer of your Personal Data is required in order to ensure that satisfaction survey could conduct by our business partners residing outside EU and Ford Motor Company in the US.
How do we protect and store Personal Data
We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:
● pseudonymisation and encryption of Personal Data;
● the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
● the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident;
● a process for regular testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.
In assessing the appropriate level of security account shall be taken in particular of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Personal Data transmitted, stored or otherwise processed.
Consequences in case we may not collect your Personal Data
We need your Personal Data to enable conducting Satisfaction Surveys. Without providing such Personal Data, we may not be able to realize such survey and improve our operations and increase your satisfaction accordingly.
Consent and withdrawal
Any consent is provided freely. If you give your consent, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. After your withdrawal we will stop processing your Personal Data, including storage, unless further data processing is legally permitted.
To withdraw your consent, please send us an e-mail to gdprrep@ford.com.tra letter to Akpınar Mahallesi, Hasan Basri Caddesi, No:2, 34885 Sancaktepe, İstanbul, Turkey.
Legitimate Interest and Right to Object
You may object to the processing of your Personal Data based on legitimate interests of Ford Otosan or third parties. In such a case you have to explain your special situation, which makes the processing of your Personal Data based on legitimate interests unacceptable for you.
To object, please send us an e-mail to gdprrep@ford.com.tr or a letter to Akpınar Mahallesi, Hasan Basri Caddesi, No:2, 34885 Sancaktepe, İstanbul, Turkey.
Retention
We only keep your personal information in identifiable form for as long as one of the following applies:
· Your information is reasonably required in order to satisfy the purpose for which you submitted or we collected the information;
· Your information is reasonably required in order to protect and defend our rights or property (this will generally be the length of the relevant limitation period in your jurisdiction); or
· We are otherwise required to keep your information by applicable laws or regulations.
Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please send us an e-mail to gdprrep@ford.com.tr
Your rights related to data privacy
You have the right to request access to and rectification or erasure of your Personal Data, or restriction of their processing. Furthermore, you have the right to request data portability. If you are situated in the EU, you have the right to file a complaint to the relevant data protection authority.
If you have questions or concerns regarding our use of your information, or would like to exercise any of your rights, please send us an e-mail to gdprrep@ford.com.tr or a letter to Akpınar Mahallesi, Hasan Basri Caddesi, No:2, 34885 Sancaktepe, İstanbul, Turkey.
Updates to this Privacy Policy
We may modify or update this information from time to time. Please check https://www.fordtrucks.com.tr/en/privacy-notice-and-consent-letter-for-ford-trucks-importers for the actual version of the data protection notice.
FORD OTOMOTİV SANAYİ ANONİM ŞİRKETİ
CONSENT INTO PROCESSING OF PERSONAL DATA FOR SATISFACTION SURVEYS
:
· I have the read the Privacy Policy on the Processing of Personal Data of the Employees of Ford Trucks’ Dealers for Satisfaction Surveys;
· I consent Ford Otosan to process my Personal Data according to the abovementioned Privacy Policy for the purposes of planning and execution of Satisfaction Surveys andtake necessary actions in order to improve its operations and my satisfaction.
· To this extent, I also consent Ford Otosan to share my Personal Data collected in accordance with the above mentioned purposes and Privacy Policy with its business partners, subcontractors, affiliates, shareholders in particular to Ford Motor Company and its vendors and business partners in the US, legally authorized public institutions and individuals which have not been subject of an adequacy decision of the EU commission pursuant to Article 45 GDPR;
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