Privacy Policy

1. INTRODUCTION AND PURPOSE

This Privacy Policy sets forth the principles regarding the protection of information collected, processed, and stored within the scope of electric vehicle charging services provided under the TOGER brand by Mionti Enerji ve Teknoloji Anonim Şirketi, registered at Başak Mahallesi, 5. Etap, 2. Kısım, Abdülhamithan Caddesi No:5, 34306 Başakşehir/Istanbul, with tax identification number 6211099577 (hereinafter referred to as the "Company" or "TOGER").

Our Company respects the privacy of its users and attaches the utmost importance to the protection of personal data. For detailed information regarding the processing of your personal data, please review our Personal Data Protection Law Disclosure Notice (www.toger.co/kvkk-aydinlatma-metni).

2. SCOPE

This Privacy Policy applies to information collected through the TOGER website (www.toger.co), the TOGER mobile application, TOGER charging stations, and all digital and physical service channels provided by TOGER.

The Policy covers all users, members, visitors, and business partners benefiting from TOGER services.

3. INFORMATION COLLECTED

The following categories of information are collected within the scope of providing TOGER services:

3.1. Information You Provide Directly

Information you share with us through membership registration, payment transactions, support requests, and contact forms: identity information, contact information, vehicle information, and payment information.

3.2. Information Collected Automatically

Information automatically collected when you use TOGER services: charging transaction data (date, duration, amount of energy, station information), digital usage data (IP address, browser information, application usage statistics), and location data subject to your explicit consent.

3.3. Information Obtained from Third Parties

Transaction data obtained from payment institutions, operators with which roaming agreements have been concluded, and the Energy Market Regulatory Authority Open Access Platform.

4. CREDIT CARD AND PAYMENT SECURITY

Our Company maintains the highest level of user security in payment transactions carried out through the TOGER charging network.

• Your credit card information is not stored on the Company’s servers under any circumstances. Payment transactions are processed through licensed payment institutions holding PCI DSS certification.
• All payment transactions are conducted through secure communication channels protected by 256-bit SSL/TLS encryption protocols.
• The 3D Secure authentication system is applied as an additional layer of security.
• Never share your credit card number, CVV code, or password through customer service channels. Our Company’s employees will not request such information from you under any circumstances.

5. PROTECTION OF INFORMATION

Our Company takes the necessary technical and administrative measures to ensure and protect the confidentiality of the information it collects. It undertakes to keep confidential information private and confidential, to take all necessary measures to ensure and maintain confidentiality, and to exercise the utmost care to prevent the unauthorized use or disclosure of confidential information to third parties.

The primary security measures applied include encrypted data communication, firewall protection, access control mechanisms, regular security testing, and employee training programs. For detailed information, please review our Personal Data Protection Law Disclosure Notice.

Encryption protocols (TLS 1.2/1.3) are used when transferring your data to third-party service providers, and separate data processing agreements are concluded with each provider. Security vulnerabilities occurring within the third-party providers’ own systems are beyond TOGER’s direct control, and in such circumstances our responsibility is limited to the duty of care exercised in selecting the relevant provider.

6. USE OF COOKIES

Our Company uses cookies and similar tracking technologies on the www.toger.co website and the TOGER mobile application. For detailed information regarding the types of cookies used, their purposes, and their management, please review our Cookie Policy (www.toger.co/cerez-politikasi).

7. THIRD-PARTY WEBSITES AND APPLICATIONS

The TOGER website and mobile application may contain links to websites and applications belonging to third parties. Our Company assumes no responsibility for the privacy practices or content of third-party platforms accessed through such links.

Map services, payment infrastructures, and social media links integrated with TOGER process data in accordance with their own privacy policies.

TOGER works with third-party service providers, including SMS delivery platforms, email services, push notification infrastructures, payment systems, map services, cloud infrastructure providers, and analytics tools, within the scope of providing its services. In the event of security breaches, unauthorized access, or data leaks occurring within the systems of these service providers, TOGER shall inform Users within a maximum period of 72 hours after becoming aware of the breach. TOGER does not have direct control over the internal security processes of third-party service providers; however, it observes industry-standard security requirements when selecting providers.

8. EXCEPTIONAL CIRCUMSTANCES

In the limited circumstances listed below, our Company may disclose information to third parties outside the provisions of this Privacy Policy:

• Fulfilment of obligations imposed by laws, regulations, and other applicable legislation
• Duly submitted requests from the Energy Market Regulatory Authority, the Turkish Personal Data Protection Authority, and other regulatory bodies
• Investigations or inspections conducted by authorized judicial or administrative authorities
• Fulfilment and enforcement of contractual obligations
• Circumstances where disclosure is necessary to protect the life or property of users or third parties

9. EMAIL AND ELECTRONIC COMMUNICATION SECURITY

Do not include your credit card number, CVV code, password, or similar sensitive information in emails sent to TOGER customer services. Our Company cannot guarantee the security of information transmitted by email.

Commercial electronic communications are sent only to users who have provided prior consent, in accordance with Law No. 6563 on the Regulation of Electronic Commerce. You may change your communication preferences through the TOGER mobile application or by using the "unsubscribe" link included in the relevant communication.

10. AMENDMENTS TO THE POLICY

Our Company reserves the right to update this Privacy Policy when necessary. Amendments shall be announced by publication on the TOGER website and/or through notifications sent via the mobile application and shall enter into force on the date of publication.

11. CONTACT

For any questions or suggestions regarding our Privacy Policy, you may contact us through the following channels:

Company Name: Mionti Enerji ve Teknoloji Anonim Şirketi
Trade Name: TOGER
Address: Başak Mahallesi, 5. Etap, 2. Kısım, Abdülhamithan Caddesi No:5, 34306 Başakşehir/Istanbul
Tax Identification Number: 6211099577
Email: info@mionti.com
Telephone: (+90) 212 980 01 44
Website: www.toger.co

INFORMATION SECURITY POLICY

As a Company, it is of great importance that we meet the legal requirements applicable to our fields of activity, provide services in a manner that responds to the needs and expectations of our customers, suppliers, and third-party stakeholders, ensure access to services delivered with high quality, speed, and security, and enable our employees to access information assets in a timely, complete, accurate, and uninterrupted manner. In order to protect information belonging to the Company, its customers, and third-party stakeholders, the Company has decided to establish an Information Security Management System (ISMS) in accordance with the ISO/IEC 27001:2022 standard. The purpose of establishing the Information Security Management System is to assess information within the framework of confidentiality, integrity, and availability; protect it against all intentional or accidental threats that may arise internally and/or externally; and ensure that activities are carried out effectively, accurately, rapidly, and securely. Information security is a corporate responsibility and is aligned with our corporate objectives. The necessary roles have been defined, responsibilities have been determined, and responsible persons have been appointed to ensure the effective operation of information security processes. These responsibilities cover, in particular, all departments using the information technology infrastructure, third-party users accessing information systems, and suppliers providing technical support to information systems. Together with the establishment of the ISMS within our Company, the objective is to identify and assess potential risks in all areas included within the scope and reduce such risks to an acceptable level by matching them with controls compliant with the relevant standard. The continuous and effective operation of the ISMS within the organization is monitored through the implementation of the risk assessment procedure.

QUALITY POLICY

As a Company, it is of great importance that we meet the legal requirements applicable to our fields of activity, provide services in a manner that responds to the needs and expectations of our customers, suppliers, and third-party stakeholders, ensure access to services delivered with high quality, speed, and security, and maintain customer satisfaction.    The Quality Management System is a corporate responsibility and is aligned with our corporate objectives; our primary objectives in relation to the products and services we provide are to maintain customer satisfaction at the highest level, improve effectiveness and efficiency, manage resources efficiently, effectively manage customer feedback, and ensure continuous improvement. The necessary roles have been defined, responsibilities have been determined, and responsible persons have been appointed to ensure the effective operation of the Quality Management System processes. 

INFORMATION TECHNOLOGY SERVICE MANAGEMENT POLICY

As a Company, we undertake to ensure that the services provided within our fields of activity are managed in accordance with the ISO 20000-1 Information Technology Service Management standard, to continuously improve the effectiveness of the Service Management System and the services provided, to ensure the continuity of the IT service infrastructure relating to all transactions carried out through the electronic applications offered by the organization, to ensure the satisfaction of users and stakeholders receiving IT services, to establish coordination between the departments providing services in order to understand and prioritize customer needs and ensure that such needs are addressed appropriately, to establish, develop, and maintain the effectiveness of a structure compliant with information technology service management requirements, to implement the necessary measures, to comply with applicable legal requirements, to fulfil the requirements of the ISO 20000 standard by effectively managing risks and opportunities, and to ensure the continuous improvement of all IT processes.

BUSINESS CONTINUITY MANAGEMENT POLICY

As a Company, we undertake to ensure that the services provided within our fields of activity are managed in accordance with the ISO 22301 Business Continuity Management System standard, in the event of a disaster, emergency, or any other incident beyond our control, to continuously maintain and improve our business continuity plans, primarily to ensure the safety of life and subsequently to ensure that our services and activities are not affected or are affected only to the minimum extent anticipated through previously conducted studies, to conduct exercises, taking into account our legal obligations, policies, and customer expectations, in order to ensure that our plans function effectively in emergency situations, to conduct analyses for the purpose of identifying potential risks that may cause service interruptions and taking measures against such risks, to manage internal and external communications concerning business continuity, to fulfil the requirements of suppliers, customers, shareholders, employees, and legal authorities, and to prepare our business continuity plans by taking into account customer expectations, corporate policies, and legal obligations.

PERSONAL DATA PROTECTION POLICY

The primary purpose of this Policy is to provide explanations regarding the personal data processing activities lawfully carried out by the Company and the systems adopted for the protection of personal data and, within this scope, to ensure transparency by informing persons whose personal data is processed by our Company, including, in particular, our customers, potential customers, employees, job applicants, company officials, visitors, employees and officials of organizations with which we cooperate, and third parties. With respect to personal data processed by the Company, we undertake to ensure that such processing is conducted in accordance with the ISO 27701 Personal Information Management System standard, to comply with applicable legal requirements, and to continuously improve our processes by managing risks relating to personal data.

CUSTOMER SATISFACTION POLICY

The Company adopts a customer-oriented approach under which customers may easily communicate their requests and dissatisfaction, such matters are handled objectively, fairly, carefully, and confidentially, and are assessed in a manner that does not conflict with legal requirements or Company policies. The Company continuously carries out the necessary improvements and controls to prevent the recurrence of the same dissatisfaction, adopts transparency as a fundamental principle in customer relations, and considers the resolution of all customer dissatisfaction as one of its primary principles. Our customer satisfaction principles are as follows: We initially regard our customers as being “right” and examine the reason for the complaint from this perspective, we investigate every matter communicated to us and consider it an opportunity for self-improvement, we maintain an approach consistent with our customers’ expectation of high-quality service, and we aim to establish strong, accurate, clear, and sustainable customer relationships following the provision of products and services by our organization.

COMPLAINT POLICY

No fee is requested from customers for the evaluation of complaints, and no financial benefit is obtained through the complaint-handling process. Company employees observe the principles of objectivity throughout the resolution process:  The complaint procedure is transparent and accessible to customers. Complaints are handled impartially and fairly.  Due care is exercised to establish all facts relating to the subject matter of the complaint, and all involved parties are taken into consideration. Information relating to customers submitting complaints is confidential. Such information is not shared outside the Company with third-party organizations or persons unless this is necessary for the resolution of the complaint. 

In this context, our Company undertakes to fulfil the requirements of the Integrated Management System standards, comply with applicable legal requirements, implement all applicable controls effectively, and continuously improve the established Integrated Management System at regular intervals every year in line with new areas of application and developing technologies.