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Togg CES 2023 EXPERIENCE PRIVACY POLICY

Türkiye’nin Otomobili Girişim Grubu Sanayi ve Ticaret Anonim Şirketi (“we”, “us”, or  “our”) incorporated and registered in Bilişim Vadisi, Muallimköy Mah. Deniz Cad. No: 143/1, 41400 Gebze/Kocaeli, Turkiye recognizes the importance of your privacy and carry out our activities in line with the applicable data protection regulation. 

This Privacy Policy aims to specify how we collect, use, and disclose your personal information in accordance with the Nevada Revised Statutes Chapter 603A (“NRS 603A”) Nevada Revised Statutes Chapter 603A (“NRS 603A”), the California Consumer Privacy Act (“CCPA”) and and other relevant laws and regulations.

  • Interpretation and Definitions

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

For the purposes of this Privacy Policy:

  • Experience means the Togg CES 2023 Experience provided by Togg.
  • Personal Information means any information relating to an identified or identifiable natural person.
  • Covered Information means any one or more of the following items of personally identifiable information about a consumer collected by an operator through an Internet website or online service and maintained by the operator or a data broker in an accessible form:
    • A first and last name.
    • A home or other physical address which includes the name of a street and the name of a city or town.
    • An electronic mail address.
    • A telephone number.
    • A social security number.
    • An identifier that allows a specific person to be contacted either physically or online.
    • Any other information concerning a person collected from the person through the Internet website or online service of the operator and maintained by the operator or data broker in combination with an identifier in a form that makes the information personally identifiable.
  • Data Subjects means the identified or identifiable person to whom personal information relates. We process the personal information of individuals who participated to the Experience (“you”, “participant”).
  • Data Controller means the natural or legal person (either alone or jointly or in common with other persons) who determines the purposes and means of the processing of personal information. We act as a Data Controller when we process your personal information.
  • Data Processor means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Data Processors to provide better service for you.
  • Personal Information We Collect

Personal Information: We can collect the following personal information:

  • Your first name, last name, CES ID as embedded in your CES badge;
  • Your e-mail address;
  • Your restaurant selection, gift selection, type of trade, energy sharing, coffee selection and donate selection;
  • Your mood for the day and your selection of experience (Forest, City, Space, Future Turkey); Your audio or visual information including your photo, video and voice;
  • Your digital souvenir including an image or video of an abstract avatar from your time in the Experience.

Choices During the Experience:

During the Experience, we may ask you several questions including but not limited to your restaurant selection, gift selection, type of trade, energy sharing, coffee selection and donate selection. These are designed to satisfy you with a full and personalized Togg CES 2023 Experience (Beyond-X, Trumore Experience, Clean Energy Solutions) and do not intend to associate any of your choices with your identity. We do not keep any of your choices. These questions and your choices are fictional and will not have any real-life consequences except your coffee selection. We are pleased to serve you a complimentary coffee fitting your gusto during your Experience.

Webcam/Voice Input and Sensor Camera

To provide you with a better experience, we use a webcam and voice input and a sensor camera during the Experience. However, none of them record, store, transfer, or process by any means any videos, photos, voices or any kind of data from the session. All of these functions are instantaneous.

  • Use of Your Personal information

We may use your personal information for the following purposes:

  • to manage your registration as a participant of the Experience.
  • to provide you and maintain our services;
  • to identify and resolve errors, problems or bugs in the Experience;
  • to review your requests, suggestions and complaints regarding the Experience and provide you the necessary support;
  • to retain and evaluate information on your recent visits to our website and how you   move   around   different   sections   of   our website for   analytics   purposes   to understand how people use our website so that we can make it more intuitive;
  • to send you the certificate of your seed you planted in Togg’s Digital Garden;
  • to improve and personalize the Experience based on your needs, requests and suggestions;
  • to contact you for marketing purposes, and promote our services;
  • to comply with applicable laws, government requests, and legal processes.
  • Legal Basis for Processing

We rely on the following legal bases for processing your personal information:

  • You have given consent to the processing of your personal information for one or more specific purposes. (For example, we need your consent to send you electronic mail marketing.)
  • Processing is necessary for the performance of a contract to which you are a party. (For example, we process your personal information to provide you with the Experience.)
  • Processing is necessary for compliance with a legal obligation to which we are subject. (For example, we may process your personal information to comply with requests from government authorities.)
  • Processing is necessary for our legitimate interests, provided that such interests are not overridden by your interests or fundamental rights and freedoms that require personal information protection. (For example, we have a legitimate interest in improving and personalizing the Experience based on your needs, requests and suggestions.)
  • Disclosure of Your Personal information

We share your personal information with:

  • the service providers, business partners and solution partners for the purposes specified in the Section 3 (e.g., to perform our contractual obligations, to provide you with more efficient and personalized services, to identify and resolve errors, problems or bugs in the Experience, to review your requests, suggestions and complaints and provide you the necessary support etc.);
  • government and regulatory authorities and other organizations to meet legal and regulatory requirements, or to protect or defend our rights or property in accordance with applicable laws.
  • Marketing

We may occasionally communicate news, updates, promotions, and information about our products and services. We shall only do this where you have given us your consent or otherwise where we are permitted to do so under the data protection laws in pursuit of our legitimate interests.

We may share personal information with third parties to help us with our marketing and promotional projects or send marketing communications.

If you want to opt-out of receiving promotional and marketing emails, text messages, posts and other forms of communication from us (or our promotional partners), which you might receive in accordance with this section, you can choose one of the following ways:

  • Click “unsubscribe” at the bottom of an email we sent you; or
  • Contact us at togg.kvkk@togg.com.tr and request to opt-out.

If you do opt-out of receiving promotional and marketing messages, we will no longer use or transfer your personal information to third parties for direct marketing purposes. We want to remind you that we may continue to send transactional or administrative e-mails (e.g., respond to your inquiries or complaints etc.)  related to our services or your requests for information or materials, even if you opt-out.

  • Retention of Your Personal information

We securely store your personal information. We take all the necessary measures to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your personal information will take place to an organization or a country unless stated in this Privacy Policy and there are adequate controls in place including the security of your data and other personal information.

We will retain your personal information only for as long as they are necessary for the purposes set out in this Privacy Policy. If we no longer have a legal basis or a purpose for processing your personal information, we will delete, destroy or anonymize such personal information.

  • Notification and Communication of Personal Information Breaches

In case of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal information transmitted, stored or otherwise processed (“data breach”), we shall notify you and relevant data protection authorities within 72 hours at the latest after we become aware of it when we are legally required to do so. 

  • Your Rights

If you are from the European Economic Area or in certain countries, you are also entitled (with some exceptions and restrictions) to:

  • Access: You have the right to request information about how we process your personal information and to obtain a copy of that personal information.
  • Rectification: You have the right to request the rectification of inaccurate personal information about you and for any incomplete personal information about you to be completed.
  • Objection: You have the right to object to the processing of your personal information, which is based on our legitimate interests.
  • Deletion: You can delete your account by using the corresponding functionality directly on the service.
  • Automated decision-making: You have the right to object to a decision made about you that is based solely on automated processing if that decision produces legal or similarly significant effects concerning you.
  • Restriction: You have the right to ask us to restrict our processing of your personal information so that we no longer process that personal information until the restriction is lifted.
  • Portability: You have the right to receive your personal information, which you have provided to us, in a structured, commonly used and machine-readable format and to have that personal information transmitted to another organization in certain circumstances.
  • Complaint: You have a right to lodge a complaint with the authorized data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.

You may, at any time, exercise any of the above rights by contacting us via togg.kvkk@togg.com.tr together with a proof of your identity, i.e., a copy of your ID card, passport, or any other valid identifying document.

In some cases, we may not be able to give you access to your personal information that we hold if making such a disclosure would breach our legal obligations to other data subjects or if prevented by any applicable law or regulation.

  • Additional Information for Residents of the State of California (USA)

Under the California Consumer Privacy Act of 2018 (“CCPA”), specific disclosures are required, and California residents have additional rights regarding their personal information. Please review this section to learn more. 

  • Categories of Personal Information We Collect
Category of Personal Information Categories of Sources from Which Personal Information Was Collected Business or Commercial Purpose for Processing
Identifiers (e.g., first name, last name, email address and CES ID) – Directly from you

 

– From your CES badge

– From third-party data suppliers and business partners

– To provide and improve our services

 

– To communicate with you

– For advertising and marketing purposes 

– To identify you as a participant of the Experience

– To protect our or others’ rights

Audio or visual information (e.g., images, videos or voices) From webcam/voice input or sensor camera – To satisfy you with a full Togg CES 2023 Experience

 

– To personalize our services

Inferences drawn from any of these personal information categories (e.g., preferences in services, such as based on feedback and customer support) – Directly from you

 

– From third-party data suppliers and business partners

– To provide you with and to improve the services

 

– To satisfy you with a full Togg CES 2023 Experience

– To provide you the necessary support and feedback 

– For advertising and marketing purposes 

  • Your Rights

Access

Upon appropriate verification, you may request access to the personal information we have collected and maintained about you (along with information regarding its use and disclosure) over the past twelve (12) months. You may only make such requests twice (2) per every twelve (12) months.

Deletion 

You have the right to request that we delete personal information collected and maintained about you, subject to certain exceptions. Once your request is verified, and we have determined that we are required to delete that information in accordance with applicable law, we will delete your personal information accordingly. 

Your request to delete your personal information may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the CCPA. Please note that a record of your deletion request may be kept pursuant to our legal obligations.

Your California Privacy Rights under the “Shine the Light” Law

If you are a California resident, you have the right to request certain information from us regarding our information-sharing practices with third parties for direct marketing purposes. To the extent that we share your personal information for direct marketing purposes, you may receive the following information: (1) the categories of information and sources of information that we disclosed to third parties for direct marketing purposes during the preceding year; and (2) the names and address information of third parties that received such information, or if the nature of their business cannot be determined from the name, the examples of the products or services marketed.

To the extent that we sell your personal information to third parties, you also have the right to request that we disclose to you: (i) the categories of your personal information that we sold, and (ii) the categories of third parties to whom your personal information was sold. You also have the right to direct us not to sell your personal information.

Verifying Your Request

Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. In the case of access and deletion, your request must be verifiable before we can fulfill such request.

Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or a person authorized to act on your behalf.

We will only use the personal information you provided in a verifiable request to verify your request. As stated above, we cannot respond to your request or provide you with personal information if we cannot verify your identity or authority.

Please note that we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive, or manifestly unfounded

You may also designate an authorized agent to make a request to access or delete on your behalf. Your authorized agent must submit proof that you have provided them with power of attorney pursuant to Probate Code sections 4000 through 4465. We may deny a request from a purported authorized agent who does not provide proof of authorization to act on your behalf.

Non-Discrimination

We will not discriminate against any consumer that asserts their rights under the CCPA. 

We will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (iii) provide you a different level of qualify of goods or services; or (iv) suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services.

  • Additional Information for Residents of the State of Nevada (USA)

This section of this Privacy Notice applies to “Consumers” as defined by Nevada Revised Statutes Chapter 603A (“NRS 603A”). 

We may collect covered information including your name, surname, CES ID, e-mail address. If any of your covered information changes at any point, you may send your new information to us at togg.kvkk@togg.com.tr

We may share your covered information as explained in Section 5 for several purposes stated in this Privacy Policy.  

If you are a Nevada resident you have the right to opt-out to the sale of your covered information as defined by NRS 603A. We do not sell covered information as defined in the NRS 603A. As a Nevada residents you may contact us via togg.kvkk@togg.com.tr to be verified and learn more about your opt-out rights under NRS 603A.

  • Right to withdraw consent

If you have provided your consent to the collection, processing, and transfer of your personal information, you have the right to withdraw your consent wholly or partly. To withdraw your consent, please get in touch with us via togg.kvkk@togg.com.tr.  

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

  • Collection of Children’s Personal Information

We do not knowingly collect personal information from children under the age of 13.  We encourage parents and legal guardians to monitor their children’s usage and to help enforce our Privacy Policy by instructing their children never to provide us with personal information without their permission. If you have any concerns about your child’s privacy with respect to our services, or if you believe that your child may have provided his/her personal information to us, please contact us via togg.kvkk@togg.com.tr. We ensure to delete such personal information from our records immediately.

In case we knowingly collect personal information from children under 13, we must comply with the Children’s Online Privacy Protection Act of 2001. However, please be cautioned that we have no way of determining the age of a person volunteering personally identifiable information online or by email.

  1. Links to Other Sites

Our platform may contain links to other sites that we do not operate. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

  • Changes to This Privacy Policy

We reserve the right to update and change this Privacy Policy from time to time to reflect any changes to how we process your personal information. Any changes we may make to our Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or push notification. We also recommend that you check back frequently to see any updates or changes to our Privacy Policy.

  • Contact Us

If you have any questions about this Privacy Policy, please contact us by email: togg.kvkk@togg.com.tr