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Personal Data Protection

ENERJISA PRIVACY NOTICE ON THE PROTECTION AND PROCESSING OF PERSONAL DATA

As Enerjisa Customer Solutions Inc., a company holding an electricity supply license and acting in the capacity of data controller (hereinafter collectively referred to as “ENERJISA”), we would like to inform you, in accordance with the Personal Data Protection Law No. 6698 (“KVKK”), about the processing of your personal data by ENERJISA through this Privacy Notice.

1) Which Personal Data Do We Collect?

PERSONAL DATA CATEGORY DESCRIPTION
Identity Name-surname, date and place of birth, Turkish ID number, ID card and driver’s license information, DASK (Compulsory Earthquake Insurance) policy details
Subscription Information Electricity meter number, subscriber group, contract number, customer number, meter index and electricity consumption information, meter serial number, ETSO code, UEVÇB code, estimated consumption data
Contact Information Telephone number (landline/mobile), home address, email address, internal company contact details, national electronic notification address
Location Address, location information
Legal Transactions Information contained in correspondence with judicial authorities, information in legal case files
Customer Transactions Call center records, invoices, promissory notes, check information, counter receipt details, order information, request information
Physical Security* Visitor entry-exit records, CCTV footage
Transaction Security** IP address details, website access information
Risk Management Information processed for the management of commercial, technical, and administrative risks
Finance Balance sheet data, financial performance information, credit and risk details, promissory notes, check information, bank account numbers, invoice information, DASK policy details, debt and receivable data, letter of guarantee details, cash collateral information, Direct Debit System registration, NACE code
Marketing Surveys, cookie records
Professional Experience Diploma details, attended courses, in-service training information, certificates, transcript information
Audio Records*** Voice recordings
Other Industrial Registration Certificate details, water usage permit issued by the State Hydraulic Works (DSİ), documents showing martyr or veteran relative status or receipt of martyr family pension, demographic segment information

2) How and On What Legal Basis Do We Collect Your Personal Data?

Your personal data are collected through various verbal, written, or electronic channels, either partially or fully automated, or manually as part of a data recording system. These channels include our headquarters, customer service centers, customer transaction centers, call centers, website, as well as through physical contracts and forms you fill out, and through electronic means such as telephone, mobile applications, call centers, IVR calls, complaint management systems, and website cookie applications.

ENERJISA may process the data it collects within its own structure or transfer and process them within its subsidiaries, affiliates, or related entities for the purposes defined below.

Your data are collected and processed based on the following legal grounds specified in Article 5 of the Personal Data Protection Law (KVKK):

  • When processing is necessary for the establishment or performance of a contract to which you are a party,
  • When processing is necessary for the legitimate interests of the data controller, provided that it does not violate the fundamental rights and freedoms of the data subject,
  • When processing is required for the data controller to fulfill its legal obligations.

3) For What Purposes Do We Process Your Personal Data?

Collecting, using, and processing certain personal data is highly important for ENERJISA to fulfill its legal obligations and carry out its activities effectively. Your personal data may be processed for the following purposes:

  • Where explicitly required by law: Ensuring the provision of electricity supply services under the Electricity Market Law and conducting electricity supply activities in accordance with relevant legislation, performing balancing and settlement market transactions, supervising electricity market activities by the relevant authorities, maintaining relations with public institutions and other organizations, executing occupational health and safety processes, customer relations, and call center processes, and planning and implementing information security procedures.
  • Where directly related to the establishment or performance of a contract: Providing services under electricity supply agreements, performing support services and obligations, ensuring customer satisfaction, and executing corporate communication activities within the scope of our electricity supply activities.
  • Where necessary for the data controller to fulfill its legal obligations: Complying with obligations arising from legislation applicable to our company, such as the Electricity Market Law and its secondary regulations, providing information and reporting to private, official, or administrative authorities such as the Energy Market Regulatory Authority, the Ministry of Energy and Natural Resources, and Energy Market Operation Co. Inc. (EPİAŞ) upon request, managing regulatory compliance and legal processes, conducting lawsuits and enforcement proceedings involving our company, and responding to consumer applications and complaints.
  • Where necessary for legitimate interests of the data controller, provided that it does not harm your fundamental rights and freedoms: Enhancing the quality of electricity supply services, performing sales, after-sales support, and marketing activities, preparing demand forecasts, personalizing and recommending ENERJISA products and services according to data subjects’ preferences, usage habits, and needs, conducting profiling/segmentation studies, data enrichment, and market research activities, ensuring corporate sustainability, corporate governance, strategic planning, application development, legal and commercial security, conducting financial operations, monitoring and securing company locations with cameras, and executing consultancy, partnership, procurement, tender, and sales processes.
  • Where you have given explicit consent:
    • Processing, storing, and using your data for sales, marketing, and customer service purposes within ENERJISA Group Companies**** and Hacı Ömer Sabancı Holding Companies*****.
    • Sharing your data with third parties in business relations with ENERJISA only for the purposes of improving service quality, resolving complaints, and developing joint products and services.

Your personal data are processed and used by ENERJISA strictly for the purpose of providing services to you, under confidentiality and supervision in accordance with KVKK. ENERJISA ensures that your data are accurate, not used outside the scope of processing, processed for legitimate purposes, kept up to date, and retained for a reasonable period required for the intended purpose.

4) To Whom and For What Purpose Do We Transfer Your Personal Data?

Your personal data may be shared with relevant parties to the extent permitted by law and required by our business processes for the purpose of enhancing the quality of the services provided, including:

  • • Where explicitly required by law: With legally authorized public authorities, and institutions and organizations permitted under the Electricity Market Law and other relevant legislation, including the Energy Market Regulatory Authority, Ministry of Energy and Natural Resources, Energy Market Operation Co. Inc., Turkish Electricity Distribution Co. (TEDAŞ), Turkish Electricity Transmission Co. (TEİAŞ), and other relevant public legal entities.
  • • Where necessary for the legitimate interests of the data controller without harming your rights and freedoms: With domestic partners, subsidiaries, and companies under controlling-subsidiary relationships.
  • • Where directly related to the establishment or performance of a contract: With banks and financial institutions, organizations providing services or collaborating with us for electricity supply activities, program partners, and, in cases where your contract is transferred to another licensed ENERJISA Group company, with the relevant supply company.

Data may be shared in accordance with Article 8 of KVKK regarding the conditions and purposes of personal data processing. These data are processed for the period required by electricity supply activities in accordance with our policies and procedures under the Regulation on the Deletion, Destruction, or Anonymization of Personal Data and are deleted when your relationship with ENERJISA ends, or when there is no reasonable or legal necessity.

5) Cookie Policy on Our Website

ENERJISA may use cookies to collect data for the purposes mentioned above during visits to its website. Cookies are small text files sent by a website to the user’s computer or mobile browser.

The purpose of cookies is to facilitate the experience of users visiting our website. Cookies may also be used to speed up future activities and experiences on the website. Cookies help us understand how visitors use our website, allowing us to improve its structure and content. These data do not enable identification of individual users.

The lifespan of cookies depends on the browser settings of the user. Many browsers are set by default to accept cookies automatically. You can change your browser settings to block cookies or notify you when cookies are sent to your device. For detailed instructions on adjusting your browser settings, refer to your browser’s guide or help screen.

6) What Are Your Rights as a Data Subject Under Article 11 of KVKK?

Under Article 11 of KVKK, you have the right to:
a) Learn whether your personal data are processed,
b) Request information if your personal data have been processed,
c) Learn the purpose of processing and whether data are used in accordance with that purpose,
d) Know the third parties to whom personal data have been transferred domestically or abroad,
e) Request correction of incomplete or inaccurately processed data,
f) Request deletion or destruction of personal data when the reasons for processing no longer exist, even if processed in compliance with KVKK and other relevant laws,
g) Request notification of the actions taken under (e) and (f) to third parties to whom the data have been transferred,
h) Object to outcomes arising solely from automatic processing,
i) Request compensation in case of damages caused by unlawful processing of personal data.

7) How Can You Exercise Your Rights Regarding Your Personal Data?

You can submit your requests regarding your personal data under Article 11 of KVKK in writing to:

Address: Barbaros Neighborhood, Begonya Street, Nidakule Ataşehir West Site No: 1/1, Ataşehir, Istanbul, Turkey

Email: enerjisamustericozumleri@hs01.kep.tr (with secure electronic or mobile signature) or musteriiliskileri@enerjisa.com (from the email address previously registered with ENERJISA).

Your application must include:

a) Name, surname, and signature (if the request is in writing),
b) T.C. ID number for Turkish citizens, or nationality, passport number, or ID number for foreigners,
c) Residential or workplace address for notification,
d) Email address, phone, and fax number for contact, if available,
e) The subject of your request.

You can use the Data Subject Application Form to submit your request. Applications are processed after identity verification, and responses are provided in writing or electronically within the legally prescribed periods. Under Article 7 of the Communiqué, there is no fee for responses up to ten pages; beyond that, a fee of 1 TRY per page applies.

8) Amendments

ENERJISA reserves the right to make changes to its personal data policies and procedures to ensure compliance with legislation.

* Processed when visiting company buildings.
** Processed when visiting https://www.enerjisamustericozumleri.com.
*** Processed when calling our call center.
**** ENERJISA Group Companies include: Başkent Elektrik Dağıtım A.Ş., İstanbul Anadolu Yakası Elektrik Dağıtım A.Ş., Toroslar Elektrik Dağıtım A.Ş., Enerjisa Başkent Elektrik Perakende Satış A.Ş., Enerjisa Toroslar Elektrik Perakende Satış A.Ş., Enerjisa İstanbul Anadolu Yakası Elektrik Perakende Satış A.Ş., Enerjisa Elektrik Enerjisi Toptan Satış A.Ş., Enerjisa Müşteri Çözümleri A.Ş., Eşarj Elektrikli Araçlar Şarj Sistemleri A.Ş., Enerjisa Araç Filo Hizmetleri A.Ş., Enerjisa Üretim A.Ş., Enerjisa Enerji A.Ş.
***** Hacı Ömer Sabancı Holding Companies include all companies under AgeSA, Aksigorta, TeknoSA, CarrefourSA, Akbank, SabancıDx, Akportföy, Ak Yatırım, and any company in which Hacı Ömer Sabancı Holding owns 20% or more shares, operating in insurance, banking, and retail sectors.

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