Disclosure Text Pursuant to the Law on the Protection of Personal Data

In accordance with the Law No. 6698 on the Protection of Personal Data (hereinafter referred to as the “KVKK” or the “Law”), the processing and preservation of personal data are of significant importance. Therefore, as Birtek Turizm Ltd. Şti., we act in compliance with the KVKK regarding the protection, storage, and processing of your personal data.

We frequently obtain data from you via online channels. Personal data collected during your visit to our website is processed in accordance with the KVKK. We would also like to state that all personal data processed during your visit to our website is protected within the scope of our Privacy Policy. You may review our Privacy Policy available on our website.

This disclosure text has been prepared by Birtek Turizm Ltd. Şti. (hereinafter referred to as “Birtek Turizm” or the “Company”) as a data controller, within the scope of Article 10 of the Law No. 6698 on the Protection of Personal Data and the Communiqué on the Procedures and Principles to Be Followed in Fulfilling the Obligation to Inform. Birtek Turizm hereby informs and enlightens you within this framework.

1. WHAT IS PERSONAL DATA?

Personal data is defined in the Law No. 6698 as “any information relating to an identified or identifiable natural person.” As understood from this definition, any information that enables you to be identified constitutes personal data. In addition to this, political opinion, sect, race, religion, association–foundation membership, health information, philosophical belief, faith, sexual preference, criminal record, conviction information, and biometric data constitute special categories of personal data.

2. LEGAL BASIS OF THIS DISCLOSURE TEXT

The Law No. 6698 requires that individuals whose data is processed must be informed before data processing activities are carried out. This requirement, referred to as the Obligation to Inform, is set forth in Article 10 of the Law on the Protection of Personal Data as follows: “During the acquisition of personal data, the data controller or the person authorized by the data controller shall inform the data subject about; the identity of the data controller and its representative, if any; the purpose of processing personal data; to whom and for what purpose the processed personal data may be transferred; the method and legal reason for collecting personal data; and other rights listed in Article 11.”

In Article 3 of the Law, a data controller is defined as “a natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system.” A data processor is defined as “a natural or legal person who processes personal data on behalf of the data controller based on the authorization given by the data controller.” In this context, the data controller is Birtek Turizm, the operator of the website you are visiting. The information of the data controller is provided below:

3. PURPOSES OF PROCESSING YOUR PERSONAL DATA

Your personal data is processed within the limits stipulated by the Law No. 6698 on the Protection of Personal Data and in accordance with the principles of the Law. The categories of personal data processed through our website by Birtek Turizm include “identity, contact, customer transaction, transaction security, marketing, and photographs.” Within the framework of the Law, our purposes for processing your personal data as Birtek Turizm are as follows:

• – Increasing the quality of goods and services offered to you,
• – Ensuring that you are promptly informed about innovations and services offered within Birtek Turizm,
• – Identifying personalized needs and usage purposes and offering personalized goods and services accordingly,
• – Ensuring the execution of Birtek Turizm’s commercial activities and providing accurate performance to you,
• – Informing you about our developing and changing goods and services and providing necessary notifications,
• – Enabling you to benefit from our products and services in the best possible way,
• – Developing and determining our commercial partnerships and strategies, establishing a secure basis, and enabling accurate managerial decisions,
• – Establishing a strong corporate identity and ensuring corporate functionality,
• – Achieving the goals of our internal company policies and thereby increasing customer satisfaction,
• – Ensuring information security,
• – Improving goods and services delivered online by Birtek Turizm,
• – Enabling rapid resolution of negative situations,
• – Communicating with individuals who submit requests or complaints to Birtek Turizm,
• – Ensuring the delivery of goods and services,
• – Fulfilling contractual obligations,
• – Carrying out necessary work by relevant units to enable you to benefit from our goods and services,
• – Fulfilling obligations required or mandated by legal regulations,
• – Fulfilling proof obligations in legal disputes,
• – Carrying out public relations, press, and media processes,

4. PRINCIPLES FOR PROCESSING YOUR PERSONAL DATA

1. To store data for the period stipulated in the relevant legislation or required for the purpose for which it is processed;
2. To process data lawfully;
3. To ensure the accuracy and up-to-dateness of data;
4. To act in accordance with the principles of good faith;
5. To avoid using data for purposes other than those for which it is processed;
6. To ensure that processing is relevant, limited, and proportionate to its purpose;
7. To process data in compliance with general ethical norms and customs;
8. To process data in compliance with the provisions of the Law No. 6698 on the Protection of Personal Data and all related legislation;

5. METHOD AND LEGAL GROUNDS FOR COLLECTING YOUR PERSONAL DATA

Your personal data is collected in written, printed, electronic, or verbal form through the corporate email accounts on our website, communication channels specified on the website, physical documents sent to our address, calls made to the phone numbers listed on the website, cookies on our website, forms related to the performance of services on our website, passports, identity documents, and photographs, and is processed through automatic and non-automatic means.
The personal data we collect is processed based on the legal grounds set forth in Article 5/2 of the Law No. 6698, including: being explicitly provided for in the laws; being necessary for the establishment or performance of a contract, provided that it is directly related to the parties to the contract; being necessary for the data controller to fulfill its legal obligations; being necessary for the establishment, exercise, or protection of a right; and being necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

6. PARTIES TO WHOM PERSONAL DATA MAY BE TRANSFERRED AND PURPOSE OF TRANSFER

Your data may be transferred to third parties when necessary, in accordance with the Law No. 6698 on the Protection of Personal Data and under the terms set forth in our confidentiality agreements. Birtek Turizm carries out data transfer activities in compliance with Articles 8 and 9 of the Law No. 6698 and takes the necessary technical and administrative measures.
Your personal data may be transferred—based on the legal grounds specified in this disclosure text pursuant to Article 8/2(a) of the Law—for the fulfillment of contractual requirements, the delivery of goods and services, communication activities, business continuity, business process management, public relations, press and media processes, and the execution of commercial activities carried out by the company, to suppliers, natural persons, private legal entities, shareholders, business partners, authorized public institutions, consulates, intermediary institutions, and insurance companies; and for the purpose of fulfilling legal obligations and providing evidence in legal disputes, to authorized public institutions, judicial authorities, and judicial bodies.
Additionally, with your explicit consent pursuant to Article 9/1 of the Law No. 6698, your personal data may be transferred to our cloud service providers located abroad and/or whose servers are located abroad for the purpose of improving service quality and business continuity; and for the fulfillment of contractual requirements, delivery of goods and services, communication activities, business continuity, business processes, and the execution of commercial activities carried out by the company, to foreign suppliers, natural persons, private legal entities, business partners, authorized institutions and organizations, consulates, intermediary institutions, and insurance companies.

7. RIGHTS OF THE DATA SUBJECT

A – GENERAL INFORMATION ABOUT APPLICATION AND YOUR RIGHTS

Article 11 of the Law No. 6698 on the Protection of Personal Data sets forth the rights of data subjects. In the Law, the data subject is referred to as the “related person,” and is granted certain rights to make requests regarding the processing of their personal data. Pursuant to this article, the rights of the data subject are as follows:
a) To learn whether personal data is processed,
b) If personal data is processed, to request information regarding such processing,
c) To learn the purpose of processing personal data and whether such data is used in accordance with its purpose,
ç) To know the third parties to whom personal data is transferred within or outside the country,
d) To request the correction of personal data if it is incomplete or inaccurate,
e) To request the deletion or destruction of personal data within the framework of the conditions set forth in Article 7 of the Law titled “Deletion, destruction, or anonymization of personal data,”
f) To request that the transactions carried out pursuant to subparagraphs (d) and (e) be notified to third parties to whom personal data is transferred,
g) To object to a result arising to the detriment of the data subject through the exclusive analysis of processed data by automated systems,
h) To request compensation in case the data subject suffers damage due to unlawful processing of personal data.
Your requests based on your rights arising from the Law No. 6698 on the Protection of Personal Data described above will be answered by Birtek Turizm as soon as possible or within thirty days at the latest, depending on the nature of the request. Applications must be made exclusively by the data subject. Birtek Turizm will only consider applications submitted by the data subject.

B – APPLICATION PROCEDURE

As a data controller, you may submit your requests regarding your rights listed above to Birtek Turizm in writing or via registered electronic mail (KEP), secure electronic signature, mobile signature, or by using the electronic mail address you have previously provided to the data controller and which is registered in the data controller’s system. To exercise your rights regarding personal data, you may review the information provided on our website and use the “Information Request Form Pursuant to the Law No. 6698 on the Protection of Personal Data” available on our website.
C – INFORMATION REQUIRED IN THE APPLICATION
The information that must be included in your application is as follows:
Your Name and Surname
Your Turkish ID Number
If You Are a Foreign National: Your Nationality, Passport Number, or Identification Number (if any)
Your Wet Signature (for written applications)
The Content and Subject of Your Request Pursuant to Article 11 of the KVKK
Your Phone and Fax Number(s) for Contact
Your Email Address for Correspondence
Your Residential or Workplace Address for Notification Purposes