35 MOYA VIP TRANSFER
Privacy Policy
This Privacy Policy explains the fundamental principles
regarding the privacy of information relating to visitors,
customers and passengers who use 35 MOYA VIP Transfer
services, our website, reservation channels and
communication channels.
TRAVEL AGENCY & SERVICE BRAND
Journey Friends Travel Agency
Group A Travel Agency Operating Certificate · Certificate No: 12513
Journey Friends Travel Agency operates under a Group A
Travel Agency Operating Certificate (Certificate No: 12513)
issued in the name of
35MOYA Turizm İnşaat Gıda Nakliye San. ve Tic. Ltd. Şti.
35 MOYA VIP Transfer is the service brand used by the
company for its transfer and transportation services.
DATA CONTROLLER / SERVICE PROVIDER
35MOYA TURİZM İNŞAAT GIDA NAKLİYE SANAYİ VE TİCARET
LİMİTED ŞİRKETİ
Service Brand: 35 MOYA VIP Transfer
Travel Agency: Journey Friends Travel Agency
Group A Travel Agency Operating Certificate ·
Certificate No: 12513
Address: Çınarlı Mah. 1570 Sk. Kuyumcu No: 19,
İç Kapı No: 53, Konak / İzmir, Türkiye
Phone / WhatsApp: +90 546 976 59 36
Email: moyaviptransfer@gmail.com
DATA CONTROLLER
35MOYA Ltd. Şti.
TRAVEL AGENCY
Journey Friends Travel Agency
SERVICE BRAND
35 MOYA VIP Transfer
1
Purpose and Scope of This Policy
This Policy has been prepared to explain the fundamental
principles applied to information relating to persons who
visit our website, request information or quotations for
transfer services, make reservations, use our services or
otherwise contact us.
This Policy may cover the website, telephone, WhatsApp,
email, reservation forms and other communication and
operational channels used in connection with the
provision of our services.
2
Information That May Be Collected
Depending on the nature of the service and the interaction
with the individual, the following categories of
information may be processed:
- Name, surname and passenger information,
- Telephone number and email address,
- Reservation and transfer information,
- Pick-up and drop-off locations,
- Flight number, flight date and related flight information,
- Number of passengers and luggage-related information,
-
Requests for an infant seat, child seat or booster seat,
- Billing and payment transaction information,
-
Information relating to communications made by
telephone, WhatsApp, email or other channels,
-
Technical information and cookie data that may arise
during use of the website.
As a general principle, personal information that is
not necessary for the service should not be requested,
and the data processed should be limited to what is
necessary for the relevant purpose.
3
Purposes for Which Information Is Used
Where the relevant legal conditions are met, information
obtained may primarily be used for the following purposes:
- Receiving and evaluating transfer requests,
- Creating and managing reservations,
- Planning transfer operations,
- Communicating with customers and passengers,
- Planning vehicles and drivers,
- Managing airport meet-and-greet operations,
- Processing payments, accounting and invoicing,
- Handling customer requests and complaints,
- Maintaining service security and operational continuity,
- Complying with legal obligations,
-
Improving the security, performance and usability
of the website.
4
Methods of Collecting Information
Information may be obtained directly from the data subject
or from persons who are authorised to provide information
in connection with the provision of the service.
Data may be collected in particular through:
- Website reservation and contact forms,
- Telephone calls,
- WhatsApp correspondence,
- Email communications,
- Reservation or confirmation forms,
- Corporate customers or business partners,
-
Operational records generated during the provision
of the service,
- Cookies and similar internet technologies.
5
Sharing of Information
Personal information may be shared only to the extent
necessary for the provision of the service, compliance
with legal obligations or other lawful grounds provided
for under applicable legislation.
In this context, information may be shared, where
necessary and proportionate, with:
- Assigned drivers,
-
Authorised suppliers providing vehicle and
transportation services,
- Relevant travel and operational business partners,
- Accounting and financial advisory service providers,
-
Banks or payment service providers depending on the
method of payment,
-
Public authorities and institutions legally authorised
to request such information.
Passenger or customer information is not shared with
unrelated third parties unless such sharing is
necessary for the provision of the service or is
otherwise permitted or required by law.
6
Information Shared with Drivers and the Operations Team
In order to perform the transfer, information such as the
passenger's name, pick-up and drop-off locations, transfer
time, flight information, number of passengers and other
information necessary for the operation may be shared with
the assigned driver or operations personnel.
The customer's telephone number may be shared with the
driver or relevant operations personnel where direct
communication is operationally necessary.
Such sharing should be limited to the information
necessary for the performance of the service.
7
Payment Information
Payments may be made in the vehicle, by bank transfer/EFT,
POS terminal, mobile POS/Cep POS, payment link or another
payment method accepted by the company.
For transactions made by credit or debit card, card
information may be processed through the secure
infrastructure of the relevant bank or payment service
provider.
The company may retain payment and transaction information
required for the provision of the service and maintenance
of financial records in accordance with applicable
legislation.
If direct online payment is made available through the
website in the future, payment security and data
processing procedures will also be applied according
to the payment infrastructure used.
8
Information Relating to Child Passengers
Where an infant seat, child seat or booster seat is
requested for a child passenger, limited information such
as the child's age or the type of seat required may be
requested in order to arrange an appropriate seat.
Such information should be used only for the purpose of
planning the transfer service safely and correctly.
9
Cookies and Website Data
The website may use cookies and similar technologies to
enable the website to function technically, maintain
security, remember user preferences, measure performance
or analyse website usage.
The use of non-essential cookies may, to the extent
required by applicable legislation, be subject to the
user's preferences or consent.
Further information regarding the types of cookies,
their purposes and how they may be managed is provided
in the separately published
Cookie Policy.
10
Third-Party Services and Links
The website may contain links or integrations directing
users to map services, messaging applications, social
media platforms, analytics services or other third-party
services.
When a user accesses a third-party platform, that
platform's own privacy and data processing terms may
apply.
Data processing activities carried out by third parties
within their own systems may be subject to the
responsibility of the relevant third party.
11
Retention of Information
Personal information may be retained for the period
necessary for the relevant processing purpose, taking
into account applicable statutory retention periods,
financial and commercial obligations, the establishment
or defence of legal claims and legitimate operational
requirements.
Once the applicable retention period has expired and
there is no other legal basis requiring continued
processing, information may be deleted, destroyed or
anonymised using methods compliant with applicable
legislation.
12
Information Security
Reasonable technical and administrative measures
appropriate to the nature of the service and systems
used are implemented to protect personal information
against unauthorised access, loss, misuse, unlawful
disclosure or alteration.
However, no method of data transmission over the internet
or electronic communication system can be guaranteed to
provide absolute security.
13
Rights Under the KVKK
Data subjects whose personal data is processed may apply
to the data controller and exercise the rights provided
under Article 11 of Turkish Law No. 6698 on the Protection
of Personal Data (KVKK), subject to the conditions set
out in the law.
Where the relevant conditions are met, these rights may
include the right to learn whether personal data is being
processed, request information if it has been processed,
learn the purpose of processing and whether the data is
being used in accordance with that purpose, learn the
third parties to whom the data has been transferred and
exercise the other rights provided by law.
For more detailed information regarding application
procedures under the KVKK and the processing of
personal data, please refer to the
KVKK Privacy Notice
published on the website.
14
Commercial Electronic Communications
Informational messages necessary for managing a
reservation or transfer operation serve a different
purpose from commercial electronic communications sent
for advertising, promotional or marketing purposes.
For marketing-related commercial electronic
communications, the consent, authorisation and opt-out
mechanisms required by applicable legislation are
applied.
Providing contact information for the purpose of receiving
a transfer service does not, by itself, constitute general
consent to receive marketing communications.
15
Relationship Between This Privacy Policy and the KVKK Privacy Notice
This Privacy Policy explains the general privacy approach
applied in connection with our website and services.
Detailed legal information concerning the legal grounds
for processing personal data, the purposes for which data
is used, the parties to whom data may be transferred and
the rights of data subjects under the KVKK is provided
in the KVKK Privacy Notice.
Reading the KVKK Privacy Notice or confirming that the
required information has been provided does not, by
itself, constitute explicit consent for processing
activities that legally require explicit consent.
16
Updates to This Policy
This Privacy Policy may be updated where necessary due to
changes in legislation, technologies used, website
features, payment systems or service processes.
The current version becomes effective from the date it is
published on the website. Where significant changes are
made, additional notice may be provided where considered
necessary or legally required.
This Privacy Policy explains the general privacy
principles applied in connection with the 35 MOYA VIP
Transfer services and website. It should be read together
with the KVKK Privacy Notice for detailed legal
information regarding the processing of personal data
and with the Cookie Policy for detailed information
regarding the use of cookies on the website.