CLARIFICATION TEXT UNDER THE PERSONAL DATA PROTECTION LAW
1. Data Controller
As ISP TRANSFER VE YAZILIM HIZMETLERI ANONIM SIRKETI ("Company"), we act as the data controller under the Personal Data Protection Law No. 6698 (“the Law”).
Address: Gokturk Merkez Mah. Cesmebasi Cad. No:51/A Eyupsultan / ISTANBUL
E-mail: [email protected]
2. Personal Data Processed
Your personal data in the following categories are processed through the ISP Driver application:
| Category | Scope |
|---|---|
| Identity | Name, surname; Turkish ID number for individual accounts |
| Contact | E-mail address, telephone number |
| Corporate Information | Company name, taxpayer identification number, tax office (corporate account holders) |
| Location | Real-time location during active work; location history during the shift |
| Image | Profile photo, vehicle photo |
| Professional | Transportation and vehicle information under the U-ETDS; pickup/drop-off addresses; passenger information; |
| Operational | Trip history |
| Security of Processing | Device ID, application logs, error reports |
| Analytics | Device information and application usage data (anonymous/pseudonymous) |
| Reward / Performance | Score history, level information |
3. Purposes of Processing Personal Data
Your personal data are processed for the following purposes:
- Authentication and account management
- Providing secure login (OTP) via SMS or e-mail
- Assignment, journey planning, and operational coordination
- Location tracking during active task and the shift
- Profile and vehicle registration
- Mandatory statutory reporting to Republic of Türkiye Ministry of Transportation and Infrastructure under U-ETDS
- Sending push notifications for job assignments and operational updates
- Detection and elimination of application errors
- Improving application quality and the user experience
- Reward and score system management
- Providing information and documents to authorized governmental agencies in accordance with legal obligations
4. Legal Grounds for the Processing of Personal Data
| Purpose of Processing | Suggested Legal Basis |
|---|---|
| Authentication, account and trip management | Being directly related to execution or performance of contract |
| OTP authentication (SMS / e-mail) | Being directly related to execution or performance of contract |
| Real-time location tracking during active work | Being directly related to execution or performance of contract |
| Location history during the shift | Performance of the contract; provision of service to customers |
| Processing Republic of Türkiye identification number | Performance of the contract; provision of service to customers |
| U-ETDS statutory reporting | In Accordance with the Legislation |
| Application error tracking (Sentry) | Legitimate interests of the data controller, Functionality of the Application |
| Application usage analysis (Firebase) | Legitimate interests of the data controller, Functionality of the Application |
| Sending push notifications | Being directly related to performance of contract |
| Providing information to the relevant authorities | In Accordance with the Legislation |
5. Parties to Whom Personal Data are Transferred
Domestic Transfers
| Recipient | Purpose of the Transfer |
|---|---|
| Republic of Türkiye Ministry of Transportation and Infrastructure | U-ETDS Statutory Reporting |
| ISP Operation Team | Daily Driver and Operations Tracking and Coordination |
| Ekomesaj (SMS Provider Türkiye) | Authentication with OTP |
International Transfers
The Company processes and stores Personal Data obtained through service providers such as Sentry, Expo, Apple, Google, and Firebase; servers such as Cloudflare, Brevo, and CM.com; and third-party software developers. In this context, such Personal Data are processed in accordance with Law No. 6698 and all applicable legislation. The user acknowledges and agrees that, within the scope of Law No. 6698, the data collected through the use of the application may be shared with service providers and third-party software companies. In this context, the user gives consent in advance to the sharing of Personal Data with service providers, third-party software developers, and servers, and to their storage by the relevant institutions and organizations.
| Recipient | Country | Transmitted Data | Purpose |
|---|---|---|---|
| Sentry Inc. | USA | Device information, error logs | Application error tracking |
| Expo Inc. / EAS | USA | Notification identifier | Push notification infrastructure |
| Apple (APNs) | USA | Identifier and content of notification | iOS notification delivery |
| Google (FCM) | USA | Identifier and content of notification | Android notification delivery |
| Firebase (Google) | USA | Device information, usage data | Usage analysis |
| Cloudflare R2 | Europe (EU) | Profile and vehicle photos | Photo storage |
| Brevo | Europe (EU) | E-mail address, OTP content | Authentication with e-mail |
| CM.com | Europe (EU) | Telephone number, message content | WhatsApp operational notifications |
6. Method of Collecting Personal Data
Your personal data are collected electronically via the ISP Driver mobile app in the following ways:
- Data entered by the user: Registration form, profile editing screens, photo upload
- Automatically collected data: Location services, push notification infrastructure, application error reporting system, usage analytics system
7. Your Rights
Pursuant to Article 11 of the Law, you have the following rights regarding your personal data:
- 1. Learning whether your personal data are processed or not
- 2. Requesting information if your personal data are processed
- 3. Learning the purpose of processing personal data and whether the data are used for intended purposes
- 4. Knowing the third parties to whom personal data are transferred at home or abroad
- 5. Requesting the rectification of personal data processed incompletely or inaccurately, if any
- 6. Requesting the erasure or destruction of personal data under the conditions laid down in Article 7 of the Law
- 7. Requesting notification of the operations carried out under the subparagraphs (5) and (6) to third parties to whom personal data are transferred
- 8. Objecting to the processing of data exclusively by automatic means, which leads to an unfavorable consequence for you
- 9. Requesting compensation for the damage you suffer, if any, arising from the unlawful processing of personal data
8. Application Process
Name and Surname :
E-Mail :
Phone :
Your applications submitted to the company's email address [email protected] after filling out the information above will be responded to within no later than 30 (thirty) days. You also have the right to file a complaint with the Personal Data Protection Board.
The company reserves the right to charge a fee in accordance with the tariff set by the Personal Data Protection Board if the requested action incurs additional costs.
