Mavi Gök Havacılık Anonim Şirketi
Clarification Text On The Processing of Personal Data

Dear customers,
This Clarification Notice provides information regarding which of your personal data is processed, the purposes for which this data is processed, the third parties with whom your personal data may be shared, your rights, and how you can contact MAVİ GÖK AVIATION JOINT STOCK COMPANY (hereinafter referred to as “MGA”) for any inquiries. This Notice has been prepared in accordance with Article 10 of the Law on the Protection of Personal Data No. 6698 (“KVK Law”) to ensure the transparent processing of personal data belonging to customers who submit complaints or requests through MGA’s website, or who make flight reservations and purchase tickets for travel.

Identity of The Data Controller

MAVİ GÖK AVIATION JOINT STOCK COMPANY is the “Data Controller” within the meaning of Article 3, paragraph 1 (ı) of the KVK Law for the personal data mentioned in this Clarification Notice.

As the Data Controller, MGA takes all necessary measures to prevent unlawful use of personal data, to ensure its protection, and to maintain an appropriate level of security in accordance with applicable legal requirements during the processing and transfer of personal data. Your personal data is processed by taking into account primarily the provisions of the KVK Law, the Turkish Civil Aviation Law, the Law on the Protection of Consumers, the Turkish Code of Obligations, the Turkish Commercial Code, and other applicable legislation.

Depending on the services, products, or commercial activities offered by MGA, your personal data may vary, but it will always be processed in accordance with Article 4 of the KVK Law and the following principles:

Lawfulness and fairness
Accuracy and, where necessary, keeping the data up to date,
Being processed for specific, explicit, and legitimate purposes,
Being relevant, limited, and proportionate to the purposes for which they are processed,
Being retained for the period stipulated in the relevant legislation or required for the purposes for which they are processed.

Purpose and Legal Reason for The Processing of Your Personel Data

Personal data		Purpose of the data processing	Legal ground for data processing
Data category	Data type
Identity data	First name, surname, gender, date of birth, Turkish identity card number, passport number, nationality of the person.	Carrying out the contract establishment and fulfilment processes and, in this context, carrying out the enquiry, offer, booking, ticket production, sale, payment, invoicing and accounting processes. Carrying out the activities in accordance with the legislation Allocating MGA's products and services to you Conducting goods/services contact, customer satisfaction, demand, complaints procedures Fulfilment of contractual obligations in case of possible damage during the use of MGA's services, elimination of victimisation of our clients, realisation of compensation payments Implementation of procedures for cancellation and delay of flights and provision of the necessary assistance Providing the necessary assistance and coordination in case of problems with lost items and baggage Carrying out communication activities Carrying out storage and archiving operations Ensuring the security of operations Ensuring flight security and taking the necessary measures by identifying passengers who breach flight security Conducting and supervising commercial operations and carrying out activities in accordance with legislation Informing the authorised persons, institutions and organisations	If expressly provided for by law If they are directly related to the conclusion or performance of a contract and the processing of personal data of the contracting parties is necessary If it is absolutely necessary for the data controller to comply with its legal obligations If the data processing is absolutely necessary for the establishment, exercise or protection of a right If the data processing is strictly necessary for the legitimate interests of the controller, provided that it does not adversely affect the fundamental rights and freedoms of the data subject
Contact details	Address, phone number, e-mail
Customer procedure	Tax identification number, tax office information, business title, billing information, enquiry/complaint information, reservation information, travel information, flight information, ticket information, PNR/ticket number.
Finance	Bank account information, credit card information, payment information, compensation information, current records, financial data	Collecting payments, incoming payments Executing contractual processes and realising financial, accounting and invoicing transactions within this framework Making compensation payments and refunds in the event of losses incurred by our clients Carrying out the necessary controls and checks in the context of your enquiries and complaints Carrying out storage and archiving activities Carrying out activities in accordance with the law Informing the authorised persons, institutions and organisations
Private Personal Data	Health data necessary for the provision of services to you at your request, Subject of the request, Private Personal Data	Allocating MGA's services to you according to your wishes and fulfilling contractual obligations, providing services to passengers with health disabilities and taking necessary precautions. Ensuring customer satisfaction Providing after-sales service for goods/services Fulfilling requests made by you to the MGA, investigating complaints and providing the necessary support	(Your personal data will be retained for as long as your express consent and permission for commercial communication is valid for the purposes listed and for the periods set out in the legislation or for reasonable periods after consent is withdrawn).
Audiovisual recording	Photo, video recording	Photographing and videotaping our customers in organisations and at events that take place in the course of carrying out advertising, promotional, campaigning, promotional and sales processes for our company's products and services, as well as carrying out advertising and promotional activities during the performance of flights
Marketing	Personal habits, preferences, targeting information, information obtained as part of marketing analysis activities, Commercial electronic message authorisation information	Carrying out analyses, profiling and targeting activities for marketing purposes Carrying out advertising, marketing, campaign and promotion processes and informing our customers in this context Providing the most suitable offers for our customers' previous preferences and tastes Creating a register of potential customers Increasing engagement with MGA products and services Conducting customer satisfaction activities Conducting celebration and welcome activities on special days Sending commercial electronic messages (SMS, email, phone calls, etc.) with the content of promotion, communication, advertisements, marketing, sales, surveys, campaigns related to the products and services within MGA's commercial activities; content of birthdays, national and religious holidays, New Year celebrations, etc.
ID card	Name, surname, date of birth

Method of Collecting Personal Data

MGA collects and processes your personal data in a limited manner and in accordance with the purposes and legal grounds specified under the section titled “Purpose and Legal Basis of Processing Your Personal Data,” in compliance with the Law on the Protection of Personal Data (KVK Law) and other relevant legislation. The primary methods include collection through our website, via request, complaint, and feedback forms, reservation procedures, ticket sales, travel information pages, and online payment channels, following the provision of relevant information to you.

In addition, your personal data may also be collected and processed via the following channels for the purposes of managing reservation and ticket sales processes, providing travel organization, carrying out accounting activities, meeting your requests, delivering our services to you, and conducting advertising and promotional activities:

Call centers, ticket sales offices, email, verbal communication, written or electronic media, collected through automatic or non-automatic methods.
Electronic storage areas, software and programs, accounting programs where your personal data is recorded and stored.
Printed documents, identification and passport documents required for the provision of the service.
Photographs and video recordings.
Travel agencies authorized to sell MGA’s products and services, online sales channels, social media, passenger and customer interviews, SMS channels, business partner companies, group/affiliate companies, through verbal, written, and electronic means.
Please note that we kindly request you to share your personal data with MGA limited to the scope of your request. If the nature of your request requires the processing of special categories of personal data, by submitting such data to MGA, you will be deemed to have given your explicit consent for their processing. Furthermore, special categories of personal data may only be processed under the circumstances stipulated in Article 6 of the KVK Law. Without the application of exceptional provisions, processing such data is only possible with your explicit consent.

Transfer of Your Personal Data

Your collected personal data may be transferred within the framework of the data processing conditions outlined in Articles 8 and 9 of the KVK Law.

On the basis of the legal basis of "expressly provided for by laws" regulated in Article 5/2 (a) of the KVK Act; Your personal data may be disclosed to law enforcement authorities, the tax administration, the General Directorate of the State Airport Authority, as well as to authorised persons, public institutions and organisations requesting information, in order to provide the necessary notifications within the framework of the fulfilment of obligations arising from legislation, in particular the provisions of the Turkish Civil Aviation Law, the Tax Procedure Law and the Turkish Commercial Code. In addition, in the course of fulfilling legal obligations and sending commercial electronic messages to you, as well as carrying out our advertising and marketing activities, the permits, telephone numbers or e-mail addresses and commercial electronic message information received from you must be stored in the message management system. For this reason, we may share your personal data with our service providers and business partners for the purpose of carrying out registration procedures. Detailed information about the message management system can be found at https://iys.org.tr.
On the legal basis of "establishment and performance of the contract" regulated in Article 5/2 (c) of the KVK Act; Your personal data may be transferred to relevant banks, payment and credit institutions for necessary payment and collection transactions; handling companies, catering companies, marketing, information technology suppliers, business partners and authorised public institutions and organisations, group and community companies, which are the service providers of MGA for the purposes of establishing the contract you are a party to and allocating our services to you in accordance with the contract.
On the basis of the legal basis of "the processing of data is strictly necessary for the data controller (MGA) to comply with its legal obligations" regulated in Article 5/2 (ç) of the KVK Act that; Your personal data may be disclosed to courts and public bodies and organisations requesting information to make legal notifications, financial advisory/accountancy firms and independent auditors to comply with obligations arising from legislation.
On the basis of the legal basis of "the data processing is necessary for the establishment, exercise or protection of a right" regulated in Article 5/2 (e) of the KVK Act; Your personal data may be disclosed to law firms and other advisers to serve as evidence in the event of any disputes, to obtain legal advice and technical assistance, to implement the contract and to check that the parties are complying with their obligations.
On the basis of the legal basis of "legitimate interest of the data controller" regulated in Article 5/2 (f) of the KVK Act; Your personal data may be transferred to accounting programs to ensure commercial security, store your personal data securely, use accounting programs and archiving services; transferred to domestic providers and/or archiving companies to perform electronic storage, infrastructure server services, backup services or systems; transferred to group/group companies to perform accounting operations, perform necessary checks, receive support services and provide information in this context.
On the basis of the legal basis of "express consent" regulated in Article 8/1 of the KVK Act;
- Your visual recordings may be shared with third parties in public media such as our Company's corporate website, social media accounts and transferred to social media platforms for the purposes of informing the public, carrying out advertising activities, announcing events and organisations, increasing the visibility of our Company in online media.
- Your sensitive personal data may be transferred to MGA's domestic suppliers, handling companies, catering companies, marketing, information technology suppliers, business partners and authorised public institutions and organisations, group and community companies in order to execute contract processes, meet and follow up requests and complaints and ensure customer satisfaction.
On the basis of the legal basis of "explicit consent" regulated in Article 9/1 of the KVK Law; Your personal data and private personal data may be transferred to our service providers located abroad for the purpose of using corporate e-mail services and carrying out communication activities, and to business partners located abroad, suppliers, airlines, law enforcement agencies, public institutions and organisations with which information should be exchanged, for the purpose of carrying out international flight organisations, carrying out clearance procedures, providing travel services and fulfilling contracts.

Retention of Your Personal Data

Your personal data is retained in accordance with one of the data processing conditions specified in Article 5 of the KVK Law and in line with the general principles outlined in Article 4 of the KVK Law, especially for the duration stipulated in relevant legislation or as long as necessary for the purpose. It is destroyed within the deletion and destruction period specified in the Retention and Destruction Policy established under Article 7 of the KVK Law.

As a data subject, you have the following rights;

To learn whether your personal data is being processed,
To request information if your personal data has been processed,
To learn the purpose of processing your personal data and whether they are used in accordance with this purpose,
To know the third parties to whom your personal data is transferred domestically or abroad,
To request the correction of your personal data if it is incomplete or incorrectly processed and to request that this correction be notified to third parties to whom your data has been transferred,
To request the deletion or destruction of your personal data in the event that the reasons requiring its processing cease to exist, even though it was processed in compliance with the KVK Law and other relevant laws, and to request that such action be notified to third parties to whom your data has been transferred,
To object to any outcome to your detriment arising from the analysis of your processed data exclusively through automated systems,
To request compensation for any damage suffered due to unlawful processing of your personal data.

Application to The Data Controller

As personal data subjects, if you submit your requests regarding your rights to MGA in writing or via methods set forth in the “Communiqué on the Principles and Procedures for the Request to the Data Controller” (https://www.resmigazete.gov.tr/eskiler/2018/03/20180310-6.htm) pursuant to Article 13, Paragraph 1 of the KVK Law, MGA will finalize the request free of charge as soon as possible and within no later than thirty days, depending on the nature of the request. However, if the process requires an additional cost, MGA may charge the fee determined by the Personal Data Protection Authority.

Our contact details

MAVİ GÖK HAVACILIK ANONİM ŞİRKETİ

BARBAROS MAH. SERİK (E) CAD. E BLOK NO: 419E İÇ KAPI NO: 2 AKSU / ANTALYA

KEP address: [email protected]

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