DISCLOSURE TEXT ON THE PROCESSING OF PERSONAL DATA     

Commercial ElectronicMessage Guest

This Clarification Text on the Processing of Personal Data applies to the data of the relevant group of persons specified in the upper right box held by the Company, which has the title of data controller.

1. WHY ARE WE SENDING THIS TEXT?

YOLCU 360 BİLİŞİM ANONİM ŞİRKETİ (“Company” or “Data Controller”), in accordance with the Personal Data Protection Law No. 6698 (“KVKK”) and the Communiqué on the Procedures and Principles to be Followed in the Fulfillment of the Obligation of Disclosure published in the Official Gazette dated 10.03.2018 and numbered 30356, with this ‘Information’ letter prepared in the capacity of Data Controller, we hereby inform you about the 10th article titled “Data Controller's Obligation to Disclose” in the KVKK. Within the framework of Article 10 titled “Disclosure Obligation of the Data Controller”, Article 11 titled “Rights of the Data Subject” and Articles 4 and 5 of the Communiqué on the Procedures and Principles to be followed in the Fulfillment of the Disclosure Obligation; It has been arranged in order to provide information about the purpose for which your personal data will be processed, to whom and for what purpose your processed personal data can be transferred, the method and legal reason for collecting your personal data and your other rights listed in Article 11 of the KVKK.

2. ON WHICH SUBJECTS DO WE PROVIDE INFORMATION?

  • Which of your personal data is collected 

  • For what purposes your Personal Data is processed

  • With whom and for what purposes your Personal Data is shared

  • The method and legal reason for collecting your Personal Data

  • Destruction of your data

  • Your rights under KVKK

3. WHICH PERSONAL DATA DO WE PROCESS?

If you select the “I would like to receive commercial electronic communications to stay informed about important campaigns” option on https://yolcu360.com/en/checkout  and consent to receive commercial electronic communications via email and/or SMS based on your preferences, the following personal data will be processed based on your explicit consent:

Personal Data Category

Personal Data Processed

Identity Information

First name, last name

Contact Information

Email address, phone number

Transaction Security Data

IP address, website login and logout logs, system logs

Legal Transaction Data

Records of your consent and refusal regarding the receipt of commercial electronic communications

Marketing Data

Content of commercial electronic communications sent to you, dates and records of such communications

4. WITH WHOM AND FOR WHAT PURPOSE DO WE SHARE YOUR PERSONAL DATA?

In case of legal obligations or the existence of the conditions of Articles 8/2 and 9 of the KVKK, your personal data; In accordance with the law and the rule of honesty, provided that it is limited and measured within the specific, clear and legitimate purposes in an accurate and up-to-date manner in accordance with the law and the rule of honesty, the use of our right to legal defense in a possible legal dispute, investigation, judicial or administrative audit and other cases, responding to official or legal other information and document requests, for purposes such as responding to our lawyer, judicial and administrative authorities requesting information, and third party persons or persons from whom our Company will receive services in order to achieve the described purposes, or public institutions or organizations authorized to request this data as required by a legal obligation.

Our Company uses Google Cloud Platform, Google Workspace, Cloud ID, Looker (original), SecOps Service, Application Services and/or other Google Cloud services (“Google Solutions”) while conducting its commercial and administrative activities. In this context, personal data processed through the use of Google solutions (such as commercial electronic message permission records stored on the Google Cloud Platform, recipient information contained in marketing emails sent via the Google Workspace Gmail service, or customer interaction data analyzed through Looker (original)) will be transferred to Google Cloud EMEA Limited, whose servers are located in the European Union due to the nature of the technical process. Our Company has signed a standard contract with Google Cloud EMEA Ltd. pursuant to Article 9/4(c) of the KVKK and personal data transfers to be made abroad through the use of Google Solutions are carried out in accordance with the provisions of the KVKK and in a secure manner.

5. WHAT IS THE METHOD AND LEGAL REASON FOR COLLECTING YOUR PERSONAL DATA?

In the event that the option of sending commercial electronic messages specified in section 3 is selected, we automatically COLLECT your personal data through cookies on your site visits; we process your personal data by digitally saving it in the information system, storing it on the physical server and cloud server, and creating a database, making a list, filling out documents, writing petitions, filling out forms, etc. by automatic or non-automatic means depending on the nature of the work and the nature of the personal data requested / to be processed.

6. WHAT ARE THE PURPOSES AND LEGAL REASONS FOR PROCESSING YOUR PERSONAL DATA

Personal Data Category

Purposes of Processing

Legal Grounds

Identity Information

Your personal data are processed for the following purposes: ensuring that activities are carried out in compliance with the legislation, the follow-up and execution of legal affairs, conducting communication activities, conducting/monitoring business activities, managing customer relationship processes, carrying out activities aimed at customer satisfaction, carrying out marketing analysis, conducting advertisement/campaign/promotion processes, carrying out strategic planning activities, conducting marketing processes for products/services, and providing information to authorized persons, institutions, and organizations.

Article 5/1 of Law No. 6698, which regulates “Explicit Consent.”

Contact Information

Your personal data are processed for the following purposes: ensuring that activities are carried out in compliance with the legislation, the follow-up and execution of legal affairs, conducting communication activities, conducting/monitoring business activities, managing customer relationship processes, carrying out activities aimed at customer satisfaction, carrying out marketing analysis, conducting advertisement/campaign/promotion processes, carrying out strategic planning activities, conducting marketing processes for products/services, and providing information to authorized persons, institutions, and organizations.

Article 5/1 of Law No. 6698, which regulates “Explicit Consent.”

Transaction Security

Your personal data are processed for the following purposes: carrying out marketing analysis activities, the follow-up and execution of legal affairs, ensuring that activities are carried out in compliance with the legislation, providing information to authorized persons, institutions, and organizations, conducting information security processes, ensuring the security of data controller operations, and managing access authorizations.

Article 5/2(a) of Law No. 6698, which states “Explicitly prescribed by law.”

Legal Transaction Data

Your personal data are processed for the following purposes: ensuring that activities are carried out in compliance with the legislation, the follow-up and execution of legal affairs, conducting/monitoring business activities, and providing information to authorized persons, institutions, and organizations.

Article 5/2(a) of Law No. 6698, which states “Explicitly prescribed by law.”

Marketing Data

Your personal data are processed for the following purposes: ensuring that activities are carried out in compliance with the legislation, the follow-up and execution of legal affairs, conducting communication activities, conducting/monitoring business activities, managing customer relationship processes, carrying out activities aimed at customer satisfaction, carrying out marketing analysis, conducting advertisement/campaign/promotion processes, carrying out strategic planning activities, conducting marketing processes for products/services, and providing information to authorized persons, institutions, and organizations.

Article 5/2(a) of Law No. 6698, which states “Explicitly prescribed by law.”

7. YOUR RIGHTS UNDER THE KVKK

By applying to the data controller, your personal data;

a) to learn whether your personal data is processed, 

b) to request information if processed, 

c) to learn the purpose of processing and whether it is used in accordance with its purpose, 

d) to know the third parties to whom it is transferred domestically / abroad, 

e) to request correction if incomplete / incorrectly processed, 

f) You have the right to request deletion/destruction within the framework of the conditions stipulated in Article 7 of the KVKK, 

g) to request notification of the transactions made in accordance with subparagraphs (ç) and (d) above to third parties to whom it is transferred, 

h) to object to the occurrence of a result against you due to the analysis exclusively by automated systems, 

j) to demand the compensation of the damage in case you suffer damage due to unlawful processing.

In your application;

  • Your name, surname and signature if the application is in writing,

  • Your T.R. identification number for citizens of the Republic of Turkey, your nationality if you are a foreigner, your passport number or your identification number, if any,

  • Your residential or workplace address for notification,

  • Your e-mail address, telephone and fax number, if any,

  • It is mandatory to include the subject of your request, and information and documents related to the subject, if any, must be attached to the application.

You can submit your applications that you want to make in writing by attaching the necessary documents to the address of our Company as the data controller, Atatürk Mahallesi Ertuğrul Gazi Sokak D2 Blok No:2 R Interior Door No:13 Ataşehir / Istanbul. 

You can make your applications through your e-mail address previously notified to our Company and registered in our system through the communication channels on the website www.yolcu360.com.

Within the scope of the Electronic Signature Law No. 5070, you can make your applications that you want to make via your Registered Electronic Mail (KEP) address by signing with a secure electronic signature to our KEP address. KEP addresses can only be sent from addresses with KEP extension.

According to the nature of your request, the information and documents that will enable identification must be provided to us completely and accurately. In the event that the requested information and documents are not provided as required, there may be problems in the full and qualified execution of the investigations to be carried out by our Company based on your request. In this case, our Company declares that it reserves its legal rights. For this reason, your application must be complete according to the nature of your request and must include the information and documents requested for identification purposes.

8. PRECAUTIONS FOR THE PROTECTION OF YOUR PERSONAL DATA

Protection of personal data is an important issue for the data controller. Our Company takes the necessary technical and administrative measures to protect against unauthorized access to personal data or loss, misuse, disclosure, alteration or destruction of this information. Our Company undertakes to keep your personal data confidential, to take all necessary technical and administrative measures to ensure confidentiality and security and to exercise due diligence.

Despite the fact that the data controller has taken the necessary information security measures, in the event that personal data is damaged as a result of attacks on the website and the system or if it is obtained by third parties, the data controller immediately notifies you and the Personal Data Protection Board.

9. ACCURATE AND CURRENT STORAGE OF YOUR PERSONAL DATA

Those who share their personal data with the data controller accept and declare that they are aware that the accuracy and up-to-date storage of this information is important both in terms of the rights they have on their personal data in terms of the Law No. 6698 on the Protection of Personal Data and other relevant legislation, and that the responsibilities arising from providing incorrect information will be entirely their own.  

You can make the necessary notifications regarding the changes and/or updates regarding your personal data you have shared via physical mail to the notification address specified below or through the communication channels on the website www.yolcu360.com.

10. DELETION, DESTRUCTION OR ANONYMIZATION OF YOUR PERSONAL DATA

Your personal data processed for the purposes specified in this Information text; KVKK Art. 7/1 of the LPPD and, if any, after the periods determined by the Laws have expired; will be deleted, destroyed or anonymized by us ex officio or upon your request in accordance with the Personal Data Storage and Destruction Policy prepared in accordance with the provisions of the Regulation on Deletion, Destruction or Anonymization of Personal Data of the data controller.

11. IDENTIFICATION OF THE DATA CUSTODIAN

YOLCU 360 BİLİŞİM ANONİM ŞİRKETİ

Mersis No: 0981139899000001

Address: Atatürk Mahallesi Ertuğrul Gazi Sokak D2 Blok No:2 R Interior Door No:13 Ataşehir / İstanbul

KEP Address: yolcu360bilisim@hs01.kep.tr