Protection of Personal Data

Personal Data Protection Notice 

As TCI SEYAHAT VE TAŞIMACILIK SEYAHAT TİC.LTD.ŞTİ (“itctur.com”, the “Company” or “We”), we exercise the utmost care to ensure the confidentiality of your personal data and to process your data in accordance with the legislation while providing the services we offer to you, our guests. Through this notice, prepared in accordance with Article 10 of the Personal Data Protection Law No. 6698 (the “Law”), we would like to inform you about the following matters:

1. How may we obtain your personal data?

2. Which of your personal data do we process?

3. For what purposes and on what legal grounds do we process your personal data?

4. For what purposes and with whom may we share your personal data?

5. What are your rights regarding your personal data and how can you exercise these rights?

How may we obtain your personal data?

As itctur.com, we may contact you, our guests, through many channels. For example

• During your visits to our agencies or branches,

• When you call our call center and provide your information,

• When you visit our website or become a member and make a reservation;

• You may share your personal data with us during your communications by e-mail with our customer services or other itctur.com employees.

In addition, if your relationship with our Company takes place through an intermediary institution, we may also obtain your personal data through such intermediary institutions.

Which of your personal data do we process?

As itctur.com, we may process your personal data in different categories within the scope of the services we offer to you, our valued guests.

• Your identity and contact information; Your name, surname, Turkish ID number, passport and similar information, as well as your e-mail address, telephone number, mobile telephone number, information contained in your identity document, and address information

• Your visual and audio records; Your photograph and call center records

• Your financial information; Financial records or payment information relating to the services you have received from our Company

• Your current and past transaction information; Your hotel or package tour preferences or travel information relating to your current or past reservation.

• Your request and complaint information; Written or verbal records regarding requests and complaints you have submitted to us concerning the services offered by itctur.com, or your special requests concerning an existing reservation

• Your insurance information; Details regarding your travel insurance policy

• Your special categories of personal data; If you have a health condition that may cause you to have special needs during your travel or if you request a reservation change or cancellation due to your illness, we may process your health information, which constitutes special categories of personal data.

For what purposes do we process your personal data?

As itctur.com, we may process your personal data for the following purposes and based on the following legal grounds:

• We process your personal data based on the legal ground of ‘being directly necessary for or directly related to the establishment and performance of the contract’ set forth in subparagraph (c) of paragraph 2 of Article 5 of the Law, in order to provide you with the products and services you have requested in the best possible manner. As itctur.com, we bring many products and services, particularly tour reservations, together with you. In order to provide you with the products and services you request or to complete your membership through our website, we process personal data such as your identity, contact, request or financial information, and thereby monitor the making of your reservations, the operational process and your membership process. For example, in order to arrange a package tour you have selected, we make hotel reservations, purchase airline tickets on your behalf, notify the people who will welcome you, and send you informative communications about your travel. If it is necessary to process your special categories of personal data during the reservation processes, we will process this data by requesting your explicit consent.

• We process your personal data based on the legal ground of ‘the legitimate interest of the data controller’ set forth in subparagraph (f) of paragraph 2 of Article 5 of the Law and, from time to time, on the legal ground of ‘having been made public by the data subject’ set forth in subparagraph (d) of paragraph 2 of Article 5 of the Law, in order to improve the quality of our products and services. As itctur.com, we are always looking for ways to provide better service to you, our guests. We carry out business development activities and analyses for purposes such as increasing the quality of our products and services, measuring guest satisfaction, getting to know our customers and their preferences more closely, and creating more efficient business strategies. We process your personal data in order to carry out these business processes. Alternatively, we may process the personal information contained in feedback you have publicly provided through social media for the purpose of improving our products and services and measuring customer satisfaction.

• We process your personal data by obtaining your ‘explicit consent’ pursuant to paragraph 1 of Article 5 of the Law for the purpose of conducting commercial communication activities. As itctur.com, we offer many products and services. We may send you notification content to introduce these products and services and inform you about innovations and opportunities that will excite you. Receiving these notifications is entirely your choice; whenever you wish, you may allow us to send you these messages or withdraw the consent you have given.

• We process your personal data based on the legal grounds of ‘the legitimate interest of the data controller’ set forth in subparagraph (f) of paragraph 2 of Article 5 of the Law and ‘fulfillment of the legal obligation of the data controller’ set forth in subparagraph (ç) of paragraph 2 of Article 5 of the Law, in order to conclude your requests and complaints. Your requests and feedback are very important to us. We may process your personal data in order to evaluate your requests regarding how we can provide the services we offer to you better, resolve the negative experiences you have encountered, or take the necessary measures to prevent them from happening again.

• We process your personal data based on the legal ground of ‘being directly necessary for or directly related to the establishment and performance of the contract’ set forth in subparagraph (c) of paragraph 2 of Article 5 of the Law, in order to create financial records. We may process your personal data while carrying out the financial processes of our Company. For example;

your personal data may be processed when issuing invoices for the services we provide, creating financial records, or conducting financial audits.

• We process your personal data based on the legal ground of ‘the legitimate interest of the data controller’ set forth in subparagraph (f) of paragraph 2 of Article 5 of the Law, for the purpose of carrying out internal company activities. As in almost every company, we may process your personal data while carrying out certain processes within the Company and creating records in the course of conducting our business activities. For example, we manage our information technology infrastructure, reward the performance of our employees, or carry out internal audit operations.

• We process your personal data based on the legal grounds of ‘fulfillment of the legal obligation of the data controller’ set forth in subparagraph (ç) of paragraph 2 of Article 5 of the Law and ‘being expressly stipulated in laws’ set forth in subparagraph (a) of paragraph 2, in order to fulfill our legal obligations. As a Company, we are subject to many legal obligations. For example, we may process your personal data and share your information with authorized public institutions or private organizations in order to fulfill certain obligations arising from regulations such as tourism, tax and insurance legislation. In particular, we may process your personal data in order to respond to lawful information requests made by authorities such as judicial bodies, police forces, and regulatory and supervisory institutions.

For what purposes and with whom may we share your personal data?

In certain circumstances, we may share your personal data with third parties. Below, we summarize the parties with whom we may share your personal data and the reasons for sharing. We would like to emphasize that, as itctur.com, we never share or make your personal data accessible to unauthorized third parties in a manner that serves our own interests.

The third parties with whom we may share your personal data and our reasons for sharing are as follows:

• We may share your personal data with our business partners. We may share your personal information with our suppliers, such as hotels and similar accommodation service providers that enable us to provide you with the products you purchase within the scope of our package tour services, companies providing transportation services such as airlines or bus companies, insurance companies providing travel insurance services, or companies providing organization services. Particularly when you purchase tour packages involving travel abroad, our business partners to whom we transfer your information may be located abroad. In many cases, the third parties to whom we transfer your personal data may also process your personal data in their capacity as data controllers.

• We may share your information with our suppliers. At certain points where we communicate with you, we use the services of third parties other than itctur.com. In this context, we receive services from suppliers in matters directly related to our services, such as sending commercial communications, managing our website, and providing our information technology infrastructure. In addition, we may share your personal data with lawyers in order to protect the legal and economic security of our Company. In these cases, we may transfer your personal data to suppliers.

• We may transfer your information to financial institutions. We may share your personal data with banks or payment institutions in order to process payments for our services.

• We may share your personal information with authorized public institutions or private persons if legally requested. In accordance with our legal obligations, we may need to routinely or upon request share your information with authorized public institutions or with relevant organizations due to the insurance and tax legislation to which we are subject. For example, we may share your information with public institutions in order to respond to information requests submitted to us by courts in the context of criminal investigations or during tax audits.

What are your rights regarding your personal data and how can you exercise these rights?

Under Article 11 of the Law, as the owner of personal data, you have many rights regarding your personal data. In this section, we would like to inform you about the rights you have and how you can exercise these rights.

Your rights under Article 11 of the Law are as follows:

You can learn whether your personal data is processed by us,

If your personal data has been processed by us, you can request information from us about this, 2/3 You can learn the purposes for which we process your personal data and whether your personal data is used in accordance with these purposes, and you can learn the third parties to whom we transfer your personal data domestically or abroad,

If we have processed your personal data incompletely or incorrectly, you may request that it be corrected and that these corrections be communicated to the third parties to whom we have transferred your personal data.

Although we have processed your personal data in accordance with the Law and other relevant legal provisions, if the reasons requiring the processing of your personal data cease to exist, you may request that your personal data be deleted or destroyed and may request that the corrections made in this context be communicated to the third parties to whom we have transferred your personal data. If a result arises against you as a consequence of the analysis of the data we process exclusively through automated systems, you may object to this result,

If you suffer any damage due to the unlawful processing of your personal data, you may request compensation for the damage arising from the unlawful processing of data.

You may exercise these rights by submitting your requests regarding the rights listed above to us. We have prepared the itctur.com Data Subject Application Form, which you can access at www.itctur.com.com, so that you can submit your requests regarding your rights in accordance with the requirements of the legislation and easily maintain control over your personal data. After completing the application form, you may submit the document to us by one of the methods specified in the form. We will respond to your applications as soon as possible and no later than thirty days, depending on the nature of your application. Data subject applications are generally answered free of charge; however, we reserve the right to charge you a fee according to the tariff determined by the Personal Data Protection Board if an additional cost arises.