Togg CES 2023 EXPERIENCE PRIVACY NOTICE

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 carries out our activities in line with the applicable data protection regulation. 

This Privacy Notice 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”).

• 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 plural.

For the purposes of this Privacy Notice:

• 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 the personal information relates. We process the personal information of individuals who participated in the Experience (“you” or  “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, and 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 digital souvenir, including an image or video of an abstract avatar created by combining a 15-second snapshot of your movements in the Experience captured by the sensor camera and the answers to several questions 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 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, voice input and a sensor camera during the Experience. 

Upon your consent, the sensor camera captures a 15-second snapshot of your motions in the Experience. By combining this snapshot with your answers to the questions you are asked on the Experience screen, the Experience creates your digital avatar as an image or video. At your request, we will send you this digital avatar as a digital souvenir via the email address you provided.

Please note that neither the webcam nor voice input processes, records, stores or transfers any videos, photos, voices or any 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 in 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 with the necessary support;
• to send your digital avatar to you;
• 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 the 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 the 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 following:

• our service providers, business partners and solution partners for the purposes specified in 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. However, 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 Notice, and no transfer of your personal information will take place to an organization or a country unless stated in this Privacy Notice 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 Notice. 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.

• 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.
• 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 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 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, and 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 Notice.  

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 described in the NRS 603A. As a Nevada resident, 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 13.  We encourage parents and legal guardians to monitor their children’s usage and to help enforce our Privacy Notice 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 children may have provided their personal information to us, please contact us via Togg.kvkk@Togg.com.tr. We ensure to delete such personal information from our records immediately.

If 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. You will be directed to that third party’s site if you click a third-party link. We strongly advise you to review the Privacy Notice 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 Notice

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

• Contact Us

If you have any questions about this Privacy Notice, please get in touch with us by email: Togg.kvkk@Togg.com.tr