» KVKK Clarification Text

As ZAĞNOS TURİZM NAKLİYAT İNŞ. TİC. LTD. ŞTİ. (referred to as "Zağnos Tour", "Company" or "We"), we pay the utmost attention to ensure the confidentiality of your personal data and to process your data in accordance with the legislation while fulfilling the services we offer to our guests. Within this clarification text prepared in accordance with Article 10 of the Law No. 6698 on the Protection of Personal Data ("Law"), we would like to inform you about the following issues:

How can we obtain your personal data?

Which personal data do we process?

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

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

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

- How can we obtain your personal data?

As Zağnos Tour, we can contact you, our guests, through many channels.

For example

During your visits to our agencies or branches,

When you call our call center and leave your details,

During your visit to our website or when you become a member and make a reservation;

You can share your personal data with us during your communication with our customer service or other Zağnos Tur employees via e-mail. In addition, if your relationship with our company is realized through an intermediary institution, we may also obtain your personal data through these intermediary institutions.

Which personal data do we process?

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

Your identity and contact information; Your name, surname, TRKN, passport etc. information, e-mail address, telephone number, mobile phone number, information on your identity card, address information

Your visual and auditory records; your photo, your call center records

Your financial information; financial records or payment information for services you have received from our company

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

Your request and complaint information; written or verbal records of the requests and complaints you have submitted to us regarding the services provided by Zağnos Tour, or your special requests regarding an existing reservation

Your insurance information; details about your travel insurance policy

Your occupation information; details about your occupation

Other information; date of marriage and children

Your sensitive personal data; In case 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 is sensitive personal data.

For what purposes do we process your personal data?

As Zağnos Tour, we may process your personal data for the following purposes and legal reasons:

In order to provide you with the products and services you have requested in the best way, we process it based on the legal reason 'being directly necessary or relevant for the establishment and performance of the contract' in subparagraph c of paragraph 2 of Article 5 of the Law. As Zağnos Tour, we bring you many products and services, especially tour reservations. We process your personal data such as your identity, contact, request or financial information in order to provide you with the products and services you request or to realize your membership through our website, and thus we follow up your reservations, operation process and membership process. For example, in order to realize a package tour you prefer, we make hotel reservations, buy your flight tickets on your behalf, notify the people who will meet you and inform you about your trip. If it is necessary to process your sensitive data during the reservation processes, we will process this data by requesting your explicit consent.

In order to improve our product and service quality, we process based on the legal reason of 'legitimate interest of the data controller' in subparagraph f of paragraph 2 of Article 5 of the Law and from time to time based on the legal reason of 'being made public by the data subject himself/herself' in subparagraph d of paragraph 2 of Article 5 of the Law. As Zağnos Tur, we are always looking for ways to provide better service to our guests. We carry out business development activities and analyzes to improve the quality of our products and services and to measure the satisfaction of our guests. We process your personal data in order to realize these business processes. Or we may process your personal information contained in the feedback you have publicly provided on social media for the purpose of improving our products and services and measuring customer satisfaction.

In order to finalize your requests and complaints, we process your personal data based on the legal reason of 'legitimate interest of the data controller' in subparagraph f of paragraph 2 of Article 5 of the Law and 'fulfillment of the legal obligation of the data controller' in subparagraph ç of paragraph 2 of Article 5 of the Law. 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 you with better services and to solve the problems you have experienced or to take necessary measures to prevent them from happening again.

In order to create financial records, we process it based on the legal reason 'being directly necessary or relevant for the establishment and performance of the contract' in subparagraph c of paragraph 2 of Article 5 of the Law. We may process your personal data while carrying out the financial processes of our company. For example, your personal data may be processed during the issuance of invoices for the services we provide, the creation of financial records or the conduct of financial audits.

In order to carry out internal activities, we process your personal data based on the legal reason of 'legitimate interest of the data controller' in subparagraph f of paragraph 2 of Article 5 of the Law. As in almost every company, we may process your personal data while carrying out certain processes and creating records within the company while conducting our business activities. For example, we manage our information technology infrastructure, reward the performance of our employees or perform internal audit operations.

In order to fulfill the legal obligations to which we are subject, we process based on the legal reason of 'fulfillment of the legal obligation of the data controller' in subparagraph ç of paragraph 2 of Article 5 of the Law and 'expressly stipulated by law' in subparagraph a of paragraph 2. 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 authorities, police forces, regulatory and supervisory authorities.

For what purposes do we process your data in order to make marketing communications and offer you special opportunities?

If you have given your explicit consent, we process your name, surname, phone number and e-mail address based on the explicit consent legal reason in paragraph 1 of Article 5 of the Law in order to inform you about our promotions and promotions by sending you commercial electronic messages.

If you have given your explicit consent, we process your name, surname, gender, date of birth, marital status, telephone number, e-mail address, travel information (your preferred holiday destination, your expenditure amount, your expenditure frequency, how many times you go on vacation annually, your preferred hotel category and the person booked), marriage date, child information and occupational information for the planning of marketing activities, segmentation and profiling analysis in order to provide you with special marketing activities, based on the explicit consent legal reason in paragraph 1 of Article 5 of the Law. In this way, as Zağnos Tour, we are able to introduce the content that will be suitable for you from our products and services we offer specifically for you.

You can withdraw the consent you have given by contacting us at any time.

For what purposes and with whom can 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 underline that, as Zağnos Tur, we never share or make your personal data accessible to unauthorized third parties for our own benefit.

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

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

We may share your information with our suppliers. At some points where we communicate with you, we use the services of third parties other than Zağnos Tour. In this context, we receive services from suppliers in matters directly related to our services such as the management of our website and the provision of our information technology infrastructure. However, 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 for the realization of payments for our services.

We may share your personal data with authorized public authorities or private individuals if legally requested to do so. In accordance with our legal obligations to which we are subject, we may be required to share your information routinely or upon request with authorized public institutions or relevant organizations due to 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 the courts within the scope of criminal investigations or during tax audits.

For what purposes and to whom do we transfer your data in order to carry out our marketing activities?

In order to send you commercial messages, we share your name, surname, phone number and e-mail information with our suppliers from whom we receive message delivery services. On the other hand, in accordance with the Regulation on Commercial Communication and Commercial Electronic Messages, we upload your permission information, name, surname, phone number and e-mail information given for sending commercial messages to the Message Management System in accordance with our legal obligations.

We share your name, surname, gender, date of birth, marital status, telephone number, e-mail address, travel information (your preferred holiday destination, your expenditure amount, your expenditure frequency, the number of times you go on vacation annually, your preferred hotel category and the person with whom the reservation is made), marriage date, child information and occupation information with our domestic and foreign suppliers who provide these services in order to receive application hosting and server services.

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

Pursuant to Article 11 of the Law, as a personal data subject, 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.

The rights you have pursuant to Article 11 of the Law are as follows:

You can find out whether your personal data is processed by us,

If your personal data has been processed by us, you can request information from us,

You can find out for which purposes we process your personal data and whether your personal data is used in accordance with these purposes,

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 inaccurately, you may request correction of your personal data and you may request that these corrections be communicated to 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, you may request the deletion or destruction of your personal data in the event that the reasons requiring the processing of your personal data disappear, and you may request that the corrections made within this scope be communicated to third parties to whom we have transferred your personal data.

In the event that the data we process is analyzed exclusively by automated systems to your detriment, you may object to this result,

In case you suffer any damage due to unlawful processing of your personal data, you may request the compensation of the damage caused by unlawful data processing.

You can exercise these rights by submitting your requests regarding your rights listed above to us. We have prepared the Zağnos Tour Data Owner Application Form, which you can access at www.zagnostur.com, so that you can realize your requests regarding your rights in accordance with the conditions in the legislation and easily have control over your personal data. After filling out the application form, you can send the document to us by one of the methods specified in the form. Depending on the nature of your application, we will respond to your applications as soon as possible and within thirty days at the latest. As a rule, data subjects' applications are answered free of charge; however, we reserve the right to charge you a fee according to the tariff to be determined by the Personal Data Protection Board in case an additional cost arises.