Contact Form Disclosure Text

DEFINITIONS

In this disclosure text:

Personal Data: Any information relating to an identified or identifiable natural person.

Personal Data Protection Law (“KVKK”): The Law No. 6698 on the Protection of Personal Data, which entered into force upon its publication in the Official Gazette on April 7, 2016.

Güven Air Aviation Industry and Trade Joint Stock Company (“Güven Air”): The legal entity located at Esenboğa Center, Özal Boulevard No: 325 D:79, 06146 Çubuk/Ankara.

Data Processor: A natural or legal person who processes personal data on behalf of the data controller based on the authority granted by the controller.

Data Controller: The natural or legal person who determines the purposes and means of processing personal data, and is responsible for the establishment and management of the data recording system.

DATA CONTROLLER

Güven Air Aviation Industry and Trade Joint Stock Company (hereinafter referred to as “Güven Air”) is the Data Controller in accordance with Article 3(1)(ı) of the Law No. 6698 on the Protection of Personal Data (“KVK Law”) with respect to the personal data specified in this disclosure text.

Your personal data are processed in accordance with the Law No. 6698 and secondary regulations for the purposes and legal reasons stated below. When you fill out the “Contact Form” available at [https://guvenair.com/rezervasyon/], your Name–Surname, E-mail Address, Phone Number, and Message are processed by Güven Air for the purposes of contacting you, evaluating and resolving your requests, complaints, and suggestions. Your personal data are processed in accordance with Articles 4, 5, and 6 of the Law No. 6698 under the following principles:

• Lawfulness and fairness

• Accuracy and being up to date when necessary

• Processing for specific, explicit, and legitimate purposes

• Being relevant, limited, and proportionate to the purpose of processing

• Being retained for the period stipulated in the relevant legislation or as required for the purpose of processing

WHICH PERSONAL DATA WE PROCESS

The categories and examples of personal data that may be processed are as follows:

PURPOSE OF PROCESSING PERSONAL DATA

Your personal data specified above are processed in accordance with the KVK Law and secondary regulations for the following purposes and legal reasons:

• Conducting Company Activities: Your personal data may be processed pursuant to Article 5/2(c) (establishment or performance of a contract) and Article 5/2(f) (legitimate interest) of the KVK Law for the purposes of ensuring corporate cooperation, evaluating project proposals within the scope of social responsibility activities, improving company operations, responding to your requests, and managing data backup and storage processes.

• Legal Obligations: Your personal data may be processed in accordance with Article 5/2(a) (explicitly provided by law) and Article 5/2(ç) (necessary for compliance with a legal obligation) of the KVK Law for fulfilling the legal obligations of the company, ensuring information security, and maintaining the safety of relationships between parties.

• Dispute Resolution: Your personal data may be processed based on Article 5/2(e) (establishment, exercise, or protection of a right) of the KVK Law to prove legal compliance, fulfill legal obligations, and resolve disputes, and may be shared with relevant legal authorities.

METHODS OF COLLECTING PERSONAL DATA

Güven Air collects and processes your personal data primarily through the contact forms available on our website, in compliance with the KVK Law and relevant legislation, within the scope of the purposes and legal bases stated in this disclosure text.

In addition, your personal data may be collected through the following channels for the purpose of fulfilling your requests:

• E-mail, verbal communication, call center, or in written/electronic form, through automated or non-automated means,

• Electronic storage areas, software, programs, and accounting systems in which your personal data are recorded and stored,

• Online communication channels, websites, social media, SMS channels, and other oral, written, or electronic means.

This disclosure text has been prepared for the personal data collected online and processed within the related processes.

STORAGE OF PERSONAL DATA

Your personal data are stored in accordance with one of the legal bases specified in Article 5 of the KVK Law and the general principles stated in Article 4, particularly for the period stipulated in the relevant legislation or required for the purpose of processing, and are destroyed at the end of the retention period.

TRANSFER OF PERSONAL DATA

Your collected personal data may be transferred within the scope of Articles 8 and 9 of the KVK Law, which regulate the conditions for processing and transferring personal data.

• Based on Article 5/2(ç) of the KVK Law (“necessary for compliance with a legal obligation”), your personal data may be transferred to courts and public institutions authorized to request information.

• Based on Article 5/2(e) (“establishment, exercise, or protection of a right”), your personal data may be shared with legal offices and consultants for the purposes of providing legal or technical support and verifying compliance with obligations.

• Based on Article 5/2(f) (“legitimate interest”), your personal data may be transferred to domestic/foreign suppliers and/or archive companies providing secure data storage, server infrastructure, backup, or cloud services.

• Based on Article 9/4, your data may also be transferred to suppliers abroad under standard contractual clauses approved by the Personal Data Protection Authority, ensuring adequate safeguards.

RIGHTS OF THE DATA SUBJECT

Pursuant to Article 11 of the KVK Law, every individual has the right to apply to the data controller and:

• Learn whether their personal data are being processed,

• Request information regarding their processed personal data,

• Learn the purpose of processing and whether data are used in accordance with that purpose,

• Know the third parties to whom personal data are transferred domestically or abroad,

• Request the correction of incomplete or inaccurate personal data,

• Request the deletion or destruction of personal data within the framework of Article 7 of the KVK Law,

• Request notification of correction, deletion, or destruction to third parties to whom data have been transferred,

• Object to the emergence of a result against themselves by means of exclusively automated data processing,

• Request compensation for damages in case of unlawful processing of personal data.

APPLICATION TO THE DATA CONTROLLER

You may submit your requests regarding your rights as a data subject, in accordance with Article 13(1) of the KVK Law and the Communiqué on the Procedures and Principles of Application to the Data Controller (https://www.resmigazete.gov.tr/eskiler/2018/03/20180310-6.htm), by delivering a written and signed application clearly stating your request, along with documents verifying your identity and address information, to the company address below by hand, mail, or notary.

Güven Air will evaluate and conclude your request free of charge as soon as possible and within 30 days at the latest, depending on the nature of the request. However, if the process requires an additional cost, a fee may be charged according to the tariff determined by the Personal Data Protection Authority.

GÜVEN AIR AVIATION INDUSTRY AND TRADE JOINT STOCK COMPANY

Address: Esenboğa Center, Özal Boulevard No: 325 D:79, 06146 Çubuk/Ankara
Phone: +90 533 135 78 11
E-mail: [email protected]
KEP Address: [email protected]