Lixhium Information Services Inc.

Clarification Text on Protection and Processing of Personal Data

Information on the Protection of Personal Data

As Lixhium Information Services Inc. (referred to as the “Company”), we attach great importance to the privacy of private life and the protection of personal rights in the processing of personal data. Accordingly, this information text has been prepared within the scope of the Personal Data Protection Law No. 6698 (“KVKK”), which entered into force on April 7, 2016 and published in the Official Gazette No. 29677, and the Communiqué on the Fulfillment of the Obligation to Inform published in the Official Gazette dated March 10, 2018 and numbered 30356.

This text is presented in order to explain to you, our users, the purposes for which personal data are processed, how they are collected, with whom they can be shared, for what legal reasons they are transferred and the legal rights you have in accordance with the KVKK.

What Does Personal Data Mean?

Personal data refers to any information belonging to an identified or identifiable natural person. For example; all kinds of data that can identify you such as your name, surname, mobile phone, e-mail address and location information are considered within this scope.

Personal Data Collected by Lixhium

As Lixhium Information Services Inc., we may need to process some of your personal data due to the nature of the services we provide. The data categories specified below may vary depending on the relationship established with our users and the transactions carried out through our application:

  • Identity Information: Information such as your name, surname, Republic of Turkey ID number (or passport or foreign ID number for foreign users), tax number if you are an individual user.
  • Contact Information: Data that enables us to contact you, such as your mobile phone number, e-mail address, residential address.
  • Location Information: Location information collected based on your explicit consent during mobile application use.
  • Customer Transaction Information: Data on your service usage such as date and time of charging station usage, amount of electricity consumed, vehicle information (brand/model/plate number), call center call records, request/complaint history, membership and transaction numbers.
  • Financial Information: Financial transaction data such as encrypted information about your credit card, payment history, billing information, transaction receipt information.
  • Transaction Security Data: Digital security data such as IP address, login credentials, username, mobile device model, firmware information.
  • Marketing Data: Usage behaviors on the application and website, cookie data, campaign participation information, survey responses and analysis information on user habits
  • Audio and Visual Data: Audio and/or video recordings received in support services (such as call center, video calls).
  • Legal Process Data: Legal process data such as petitions submitted to judicial and administrative authorities, application records, contents of lawsuits and enforcement files.

This data may be obtained directly from you or indirectly (for example, through your device) during the use of the application, through the website, call center, support channels, social media platforms and our business partners.

Purposes and Legal Grounds for Processing Your Personal Data

Membership and Account Creation Processes

If you create a user account through the Lixhium mobile application, you are deemed to have accepted the Lixhium membership agreement. In this process, the following data groups are collected and processed:

  • Identity information: Name-surname, Turkish ID number (or ID number for foreign users), tax number for sole proprietorships
  • Contact information: Cell phone, e-mail address, residence information
  • Customer transactions: User number, vehicle brand/model/plate number, invoice details
  • Transaction security: Username and password, IP address
  • Financial data: Encrypted card details, bank details, card expiration date

This personal data; In accordance with paragraph 2 of Article 5 of the KVKK,

  • This personal data; In accordance with paragraph 2 of Article 5 of the KVKK,
  • It is processed for the following purposes based on the conditions that data processing is mandatory for the legitimate interests of the data controller:
  • Smooth operation of the Lixhium platform
  • Execution of membership procedures and management of your digital user account
  • Provision of recharging services and creation of customized content
  • Ensuring service provision in accordance with the legislation
  • Carrying out system development activities to improve service quality
  • Fulfillment of financial and legal obligations

Lix Card and Balance Top-up Transactions

As Lixhium users, some of your personal data are processed in the processes of requesting Lix Card and loading balance to your account within the scope of our business partnerships. In this context;

  • Identity information: Name-surname, Turkish ID number (or tax number for sole proprietorships)
  • Contact information: Cell phone number, address, e-mail address
  • Customer transaction information: Vehicle license plate number, user name, Lix Card number
  • Transaction security data: User name
  • Your vehicle information: Vehicle brand, model and license plate information

In accordance with paragraph 2 of Article 5 of Law No. 6698;

  • This personal data; In accordance with paragraph 2 of Article 5 of the KVKK,
  • Data processing is mandatory within the scope of legitimate interest

It is processed for the following purposes on legal grounds:

  • Receiving your Lix Card request and delivering the card to you
  • Performing balance top-up operations to your card
  • Integration of membership and payment systems
  • Conducting in-house service operations
  • Recording and auditing service utilization processes
  • Smooth progress of sales and invoicing processes
  • Execution of data processing processes in accordance with the legislation
  • Request Tracking

Provision of Charging Service

As Lixhium, while providing charging services to our users, some of your personal data are processed within the scope of the transactions you perform both through membership and as a guest user.

Categories of data processed for member users:

  • Customer transactions: User number, transaction number, vehicle information (brand, model, license plate), charging station location, date and time of use, amount of electricity consumed, service fee, billing information, Lix Card information
  • Process security: IP address, username, device information

Categories of data processed for guest users:

  • Identity information: Name-surname, Turkish ID number (or foreign ID number), VKN
  • Contact information: Telephone number, e-mail address, residential address
  • Customer transactions: Support request, call center records, vehicle information, vehicle license plate information, charging station information, usage times, amount of energy consumed, service package, fee and billing information, usage details
  • Transaction security: IP address, mobile device model, device operating system version

In accordance with paragraph 2 of Article 5 of the Law No. 6698 on the Protection of Personal Data;

  • Necessity of conclusion and performance of a contract
  • Fulfillment of the legal obligations of the data controller
  • Mandatory data processing activities within the scope of legitimate interest

It is processed for the following purposes on legal grounds:

  • Providing complete and safe charging services
  • Invoicing of charging transactions and tracking of service details
  • Recording users' transactions and providing support when necessary
  • Auditing and reporting of operational processes
  • Fulfillment of contractual obligations
  • Providing information to relevant official institutions within the scope of legal obligation

Payment Processes

Regarding the charging services offered through Lixhium, some personal data are processed within the scope of carrying out payment transactions and billing processes of users.

Data processed for member users:

  • Identity information: Name-surname, Turkish ID number (tax number for sole proprietorships)
  • Customer transactions: User number, transaction number, service type, vehicle license plate information, charging station location, date and time of use, amount of energy consumed, service fee, invoice details
  • Transaction security: Username

Data processed for guest users:

  • Identity information: Name-surname, Turkish ID number, VKN
  • Customer transactions: Vehicle information, request/support record, transaction number, charging location, time of use, energy consumed, invoice and usage information
  • Financial data: Information on the card
  • Transaction security: IP address, mobile device model, operating system information

Pursuant to paragraph 2 of Article 5 of the LPPD;

  • Necessity of conclusion and performance of a contract
  • Fulfillment of the legal obligations of the data controller
  • Necessity of data processing within the scope of legitimate interest

It is processed for the following purposes for legal reasons:

  • Realization of payment and collection transactions
  • Invoice issuance and submission
  • Execution of return and reconciliation processes
  • Creation of financial records and follow-up of accounting processes in accordance with the legislation
  • Supporting service continuity and internal audit activities
  • Sharing necessary information with legal authorities

Card Storage and Security Applications

In case you prefer to register your credit card through Lixhium;

  • Identity Name-surname
  • Financial information: Card bank, payment system provider, encrypted card number, expiration date

your data is processed and stored only through authorized service providers with PCI DSS Level 1 security standard.

Our company does not have access to your entire card number, CVV/CVC security codes. Card storage operations are carried out only with your explicit consent.

Our processing objectives in this context:

  • Fast and secure realization of payments
  • Smooth processing of returns
  • Ensuring customer satisfaction
  • Fulfillment of legal and financial obligations
  • Execution of storage and archive processes

User Support Processes

As Lixhium, within the scope of the support services we provide to our users, your data transmitted to us through the call center, WhatsApp communication, video calls, social media messages and complaint platforms can be processed.

The following categories of personal data are processed in these processes:

  • Identity information: Name-surname, Turkish ID number, tax number for sole proprietorships
  • Contact information: Cell phone, e-mail address, address
  • Location data Location data (optional)
  • Customer transactions: Call center records, user/member number, transaction number, complaint and request information, vehicle information (brand, model, license plate), charging station location and time of use, service fee, invoice details, Lix Card information
  • Audio and visual recordings: Audio/video recordings taken during video support service
  • Legal data: Information and documents related to judicial or administrative processes
  • Transaction security data: IP address, access information, username, password, mobile device information

This data; Within the scope of paragraph 2 of Article 5 of KVKK No. 6698;

  • Performance of a contract
  • Fulfillment of legal obligations
  • Legitimate interests
  • Establishment or protection of a right
  • The personal data has been made public by the data subject

It is processed on legal grounds and serves the following purposes:

  • Establishing contact with the customer and evaluating requests
  • Recording complaints and suggestions
  • Execution of after-service support processes
  • Measuring and improving customer satisfaction
  • Evaluating feedback to improve products and services
  • Ensuring information security
  • Providing information to authorized persons, institutions and organizations in accordance with legal obligations
  • Consumer disputes, follow-up of litigation/appeal processes
  • Conducting internal audit, archiving and reporting activities

Note: Audio/video call recordings made for our users who prefer video support are deleted from our systems within 1 month at the latest after the completion of the service.

Customer Satisfaction Processes

As Lixhium, we care about continuously improving the user experience, we periodically conduct satisfaction surveys and evaluation forms in order to measure the quality of service we provide and to make improvements with your feedback.

Within the scope of these activities, the following personal data may be processed for both member users and guest users:

  • Identity information Name-surname
  • Contact information: Cell phone, e-mail address, residential address
  • Location data: Location data (when using a mobile application or service)
  • Customer transactions: Call center records, user number, membership date, transaction number, vehicle information (brand, model, license plate), charging location and date/time information, amount of energy consumed, invoice and service details
  • Transaction security data: Username, mobile device model and operating system

Processing Objectives:

Your personal data collected is processed in line with the following legal reasons in paragraph 2 of Article 5 of the KVKK:

  • Directly related to the performance of a contract
  • Fulfillment of the Company's legal obligations
  • Necessary for the exercise or defense of a right
  • Data processing is mandatory within the scope of legitimate interest

Within this framework, your data is used for the following purposes:

  • Measuring and analyzing user experience
  • Evaluate feedback to improve service processes
  • To follow up on requests, suggestions and complaints
  • Carrying out communication activities for customer satisfaction
  • Making data-driven decisions to improve products and services
  • Supporting internal audit and evaluation processes

Debt Follow-up, Legal Processes and Official Institution Requests

In the event that payments for the services provided by Lixhium are not made on time, some of your personal data may be processed within the scope of the follow-up of receivables and the execution of legal processes. Likewise, your data may be used in the processes of responding to the requests of official authorities.

Data processed within this scope:

  • Identity information (name-surname, Turkish ID number, etc.)
  • Contact information (phone number, e-mail, address)
  • Customer transactions (user number, service details, transaction history)
  • Legal transaction information (data on lawsuits, executions and official correspondence)
  • Process security (IP address, access logs)

Pursuant to paragraph 2 of Article 5 of the LPPD:

  • Fulfillment of the Company's legal obligations
  • Exercise or defense of a right
  • Obligation to process data within the scope of legitimate interest

It is processed for the following purposes based on its legal grounds:

  • Collection of receivables and initiation of necessary legal proceedings
  • Conducting judicial/administrative processes
  • Providing information to official institutions and organizations
  • Evaluation of requests, complaints and objections

Commercial Communication Authorization and Management

If you have given us permission for commercial communications, so that we can send you information such as campaigns, benefits, new services and special occasion celebrations;

  • Identity information Name-surname
  • Contact information: Cell phone, e-mail address

Your data is processed with your explicit consent in accordance with paragraph 1 of Article 5 of the KVKK

Also to manage your commercial communication preferences (details such as consent, rejection, date and channel information):

  • Customer transactions

Your data is processed due to legal obligation within the scope of paragraph 2 of Article 5 of the KVKK.

General Purpose Data Processing Activities

The above-mentioned personal data may also be processed for the following additional purposes, where necessary, based on paragraph 2 of Article 5 of the KVKK:

  • Carrying out internal audit, internal control and reporting processes
  • Follow-up of occupational health and safety procedures
  • Carrying out information security, sustainability and strategic planning activities
  • Development and sustainability of Lixhium mobile application
  • Managing financial transactions and accounting records
  • Organizing consultancy, business partnership, procurement and supply processes

Personal Data Processed Based on Explicit Consent

At Lixhium, we process some of your personal data only with your explicit consent. This data is used solely for the purpose of providing you with tailored services and campaigns, personalizing your experience and improving brand communication.

Categories of data processed based on explicit consent for member users:

  • Identity Name-surname, Turkish ID number
  • Contact: Cell phone, e-mail address, address
  • Location Location data
  • Customer Transactions: Member number, usage details, charging station location and date, energy consumed, invoice information
  • Marketing: Web/mobile application usage behaviors, cookie data, survey responses, segmentation information

Purposes of processing within the scope of explicit consent:

  • Offering personalized campaigns, discounts, gifts and promotions
  • Analyzing brand perception, user satisfaction and experience
  • Segmentation, profiling and development of marketing strategies
  • Execution of contests, sweepstakes and events you participate in
  • Tailored content recommendations and reminders
  • Sending personalized commercial electronic messages
  • Providing opportunities to participate in events and trainings
  • Promotion of services offered in partnership with our business partners and suppliers

Data processed with explicit consent for guest users:

  • Identity Name-surname
  • Contact Cell phone, e-mail address

This data is processed limited to the following purposes:

  • Informing about campaigns, announcements and service promotions
  • Offering special opportunities for membership and events
  • Promotion of products and services offered by Lixhium or our business partners

Use of Your Location Data

When using the Lixhium mobile app, if you allow location sharing, the location information received from your device is processed for the sole purpose of showing you the nearest charging stations.

  • Used to show charging points on a map by detecting the current location of your device
  • It is in no way recorded or stored in our systems

If you do not want to share your location information, you can disable the Lixhium app's location access at any time in your device's settings.

Our Commitment to Data Security and Privacy

At Lixhium, we only process your personal data within the legal framework and for specific purposes. In this process

  • The accuracy and timeliness of your data is observed
  • No unnecessary and improper data processing
  • Stored for as long as necessary, then disposed of securely
  • Your privacy is meticulously protected in all processes

In line with the obligations stipulated by KVKK, all your personal data, including your location data, are protected with high security standards.

With whom and for what purposes is your personal data shared?

As Lixhium, we only share your personal data with certain persons and organizations in accordance with the legislation, with your explicit consent or within the framework of legal obligations. These disclosures are limited to the realization of the following purposes only:

Parties that can be shared:
  • Authorized public institutions and organizations: Under the Electricity Market legislation and other relevant legal regulations (e.g. EMRA)
  • Our business partners, suppliers and group companies
  • Banks, payment service providers and financial institutions (in payment processes)
  • Legal authorities, judicial bodies, mediation authorities (in debt follow-up and legal disputes)
  • Information technology providers and cloud service companies (e.g. Amazon Web Services, Google Cloud)
  • Service provider platforms and Message Management System for sending commercial electronic messages
Legal Basis for Data Transfer:
  • Fulfillment of legal obligations
  • Establishment or performance of the contract
  • Legitimate interest of the company
  • Explicit consent has been given
  • The establishment, exercise or defense of a right
Data Transfer Abroad:

If you communicate with Lixhium via WhatsApp or video support, some of your personal data may be temporarily hosted on servers abroad. This transfer takes place only in accordance with Article 9 of the KVKK, within the framework of legitimate interest and explicit consent.

How Long Is Your Personal Data Stored?

Your data will only be retained for the aforementioned purposes and for the statutory retention periods. Once the required period has expired, your data will be deleted, destroyed or anonymized in accordance with the relevant regulations.

Your Rights under Article 11 of the KVKK

Pursuant to Law No. 6698 on the Protection of Personal Data, you have the following rights in relation to your personal data:

  • Learn whether your personal data is being processed
  • Requesting information if processed
  • Learn the purpose of processing and whether they are used in accordance with the purpose
  • Learning the third parties to whom it is transferred domestically or abroad
  • Request correction of incomplete or incorrectly processed data
  • To request the deletion or destruction of the data in case the reasons requiring its processing disappear
  • Request notification to third parties to whom these transactions are transferred
  • Challenging automated systems that produce a result that is unfavorable to you
  • If you have suffered damage due to unlawful processing of data, to request compensation for the damage

How Can You Exercise Your Rights Regarding Your Personal Data?

Pursuant to Article 11 of the Law No. 6698 on the Protection of Personal Data, you can submit your requests regarding your personal data that you have notified to Lixhium to Lixhium Bilişim Hizmetleri A.Ş. within the scope of the “Communiqué on the Procedures and Principles of Application to the Data Controller” in the following ways:

  • In writing with a wet signed petition,
  • Via registered electronic mail (REM) address,
  • Through secure electronic signature or mobile signature,
  • Or by sending an e-mail to [email protected] via the e-mail address you have previously notified to Lixhium and registered in our system.

The following information must be included in your application:

  • Your name, surname and signature (if written)
  • Turkish ID number for citizens of the Republic of Turkey, nationality, passport or ID number, if any, for foreign nationals
  • Residential or workplace address for notification
  • Electronic mail address, telephone and fax number, if any
  • Subject of request

If you wish, you can fill out the “Contact Person Application Form” and send it to us to make your application faster and easier.

Applications will be finalized within 30 days at the latest after authentication by Lixhium.

Data Controller Information

Lixhium Information Services Inc.

Address: Muallimköy Mh, Informatics Valley, Deniz Cd., 41400 Gebze/Kocaeli

E-mail: [email protected]

Policy Updates

Lixhium reserves the right to update its policy on the protection of personal data in order to comply with changes in legislation, updates in internal processes and legal requirements.