Reservation Form Clarification Text

DEFINITIONS

In this clarification text:

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

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

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

Data Processor: The natural or legal person who processes Personal Data on behalf of the data controller based on the authorization given by the data 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”) has the title of “Data Controller” for the personal data included in this clarification text in accordance with subparagraph (ı) of paragraph 1 of Article 3 of the Law on the Protection of Personal Data No. 6698 (KVK Law).

Your personal data are processed in accordance with the Law on the Protection of Personal Data No. 6698 and secondary regulations, within the purposes and legal reasons specified below. If you fill out the “Contact Form” at [https://guvenair.com/rezervasyon/], your Name–Surname, E-mail, Phone Number, and the note you wish to convey will be processed by Güven Air within the scope of the communication request created by you, for the purposes of contacting you, evaluating your requests, complaints and suggestions and concluding them, in line with the principles written below pursuant to Articles 4, 5 and 6 of Law No. 6698:

Lawful and in accordance with the rules of good faith
Accurate and, where necessary, up to date
For specific, explicit and legitimate purposes
Relevant, limited and proportionate to the purposes for which they are processed
Stored for the period stipulated in the relevant legislation or required for the purpose for which they are processed

WHICH PERSONAL DATA DO WE PROCESS?

The personal data of yours that may be subject to processing by us are as follows:

Personal Data

Categories

Examples of Personal Data We Collect

Identity Information

Name, surname.

Contact Information

Personal e-mail address, phone number

Flight Information

Other information regarding your flight reservation

Purpose of Processing Personal Data

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

▪ Conduct of Company Activities: Your personal data may be processed based on the legal reason of the establishment or performance of a contract specified in Article 5/2(c) of the KVK Law and the legitimate interest specified in Article 5/2(f) of the KVK Law, for the purposes of ensuring corporate cooperation, taking actions to improve company activities by evaluating your project proposals in the conduct of social responsibility and civil society activities, responding to your requests submitted to us, and carrying out data backup and storage processes.

▪ Legal Obligations: Your personal data may be processed, based on the legal reason of “explicitly stipulated by laws” specified in Article 5/2(a) of the KVK Law and “being necessary for the data controller to fulfill its legal obligations” specified in Article 5/2(ç) of the KVK Law, for the purposes of fulfilling the legal obligations to which the Company is subject, ensuring information security, and ensuring the security of the relationship between the parties, taking into account the provisions of the Law on the Protection of Personal Data and other relevant legislation.

▪ Resolution of Disputes: Your personal data are processed, based on the legal reason of the establishment, exercise or protection of a right specified in Article 5/2(e) of the KVK Law, for the purpose of proving that the transactions have been carried out in accordance with the law and that legal obligations have been fulfilled and ensuring the resolution of disputes, and may be shared with the relevant legal authorities.

METHODS OF COLLECTING PERSONAL DATA

Güven Air primarily collects and processes your personal data through the contact forms on our website within the scope of the data processing purposes and legal reasons stated in this clarification text, in accordance with the provisions of the KVK Law and relevant legislation.

In addition, for the purpose of fulfilling your requests, your personal data collected through the channels written below may also be processed:

▪ Your personal data collected by e-mail, verbal communication, call center, in written or electronic environment, by automated or non-automated methods,

▪ Your personal data recorded and stored in electronic storage areas, software and programs, your personal data stored through accounting programs,

▪ Your personal data collected through communication channels operating over the internet, website, social media, verbal interviews, SMS channels, verbal, written and electronic media.

This clarification text presented to you has been prepared for your personal data collected online and processed in the processes related to this.

STORAGE OF YOUR PERSONAL DATA

Your personal data are stored based on one of the data processing conditions specified in Article 5 of the KVK Law and in accordance with the general principles specified in Article 4 of the KVK Law, particularly for the period stipulated in the relevant legislation or required for the purpose, and are destroyed within the destruction period.

TRANSFER OF PERSONAL DATA

Your personal data collected may be transferred within the framework of the personal data processing conditions regulated in Articles 8 and 9 of the KVK Law.
Based on the data processing condition of “being mandatory for the fulfillment of the data controller’s legal obligation” regulated in Article 5/2(ç) of the KVK Law, your personal data may be transferred to courts and public institutions and organizations requesting information for the purpose of making legal notifications.
Based on the data processing condition regulated in Article 5/2(e) of the KVK Law “for the establishment, exercise or protection of a right,” your personal data may be transferred to law firms and other consultants for the purposes of serving as evidence in possible disputes, obtaining legal consultancy and technical support, and auditing compliance with the obligations of the parties.
Based on the legal reason of “legitimate interest of the data controller” regulated in Article 5/2(f) of the KVK Law, your personal data may be transferred to domestic/overseas suppliers and/or archiving companies from which services are received for the secure storage of your information, obtaining electronic storage, website infrastructure server services, provision of backup services or systems.
Based on the data processing condition of the existence of the standard contract “announced by the Personal Data Protection Board, which includes issues such as data categories, purposes of data transfer, recipients and recipient groups, technical and administrative measures to be taken by the data recipient, additional measures taken for special categories of personal data,” regulated in Article 9/4 of the KVK Law among the appropriate safeguards, your personal data may be transferred to domestic/overseas-based suppliers from which the Company receives services, through electronic or physical data storage, use of cloud services, backup services or systems, for the purpose of ensuring the security of your personal data.

RIGHTS OF THE PERSONAL DATA SUBJECT

Pursuant to Article 11 of the KVKK, everyone, by applying to the data controller, has the right to:

Learn whether personal data are processed or not,
Request information if personal data have been processed,
Learn the purpose of processing personal data and whether they are used in accordance with that purpose,

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

Request correction of personal data if they are incomplete or incorrectly processed,
Request the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the KVKK,
Request notification to third parties to whom personal data have been transferred of the actions taken pursuant to subparagraphs (d) and (e),
Object to the occurrence of a result against the person by analyzing the processed data exclusively through automated systems,

ğ) Request compensation for damages in the event of damage due to unlawful processing of personal data.

APPLICATION TO THE DATA CONTROLLER

As the relevant person, you must submit your requests regarding your rights in accordance with paragraph 1 of Article 13 of the KVK Law in writing or by the methods regulated in the Communiqué on the Principles and Procedures for the Application to the Data Controller (https://www.resmigazete.gov.tr/eskiler/2018/03/20180310-6.htm), clearly and understandably, and by attaching documents identifying your identity and address, in writing and with a wet signature, by hand, by mail or through a notary public, to the full address of the company below. Your request will be concluded free of charge by Güven Air as soon as possible and at the latest within thirty days from the date your request reaches Güven Air, depending on the nature of the request. However, if the transaction requires an additional cost, a fee in the tariff determined by the Personal Data Protection Authority will be charged by Güven Air.

GÜVEN AIR AVIATION INDUSTRY AND TRADE JOINT STOCK COMPANY

Address: Esenboğa Merkez, Özal Bulvarı No: 325 D: 79, 06146 Çubuk/Ankara

Phone: +90 533 135 78 11

E-Mail: [email protected]

KEP Address: [email protected]