PRIVACY NOTICE UNDER TURKISH DATA PROTECTION LAW

1 About the Data Controller

For the purposes of Turkish Personal Data Protection Law No. 6698, the data controller is 35MOYA TURİZM İNŞAAT GIDA NAKLİYE SANAYİ VE TİCARET LİMİTED ŞİRKETİ .

Our company provides transfer, private transportation and related travel services under the travel agency name Journey Friends Travel Agency and the service brand 35 MOYA VIP Transfer.

2 Personal Data That May Be Processed

Depending on the nature of the service and your relationship with us, the following categories of personal data may be processed:

• Identity information: First name, surname and, depending on the nature of the reservation, other identity information that may be necessary for the provision of the service.
• Contact information: Telephone number, email address and other contact details provided to us.
• Reservation and travel information: Transfer date and time, pick-up and drop-off locations, hotel/accommodation information, flight number, flight date, route and reservation details.
• Passenger information: Passenger names, number of passengers and other passenger information required for the transfer operation.
• Service request information: Vehicle category, luggage information, infant seat, child seat, booster seat and other special service requests.
• Financial and transaction information: Reservation amount, payment status, payment method and information required for refund, accounting and invoicing processes.
• Communication and transaction records: Requests and correspondence sent to us by telephone, WhatsApp, email or other channels in connection with a reservation or service.

3 Purposes of Processing Personal Data

Your personal data may, where relevant, be processed for the following purposes:

• Creating and managing transfer requests and reservations,
• Planning and providing airport, hotel, local and intercity transfer services,
• Planning and assigning the appropriate vehicle and driver,
• Communicating with customers and passengers before, during and, where necessary, after the transfer,
• Using flight information for the purpose of managing the transfer operation,
• Planning infant/child seats, luggage requirements and other special service requests,
• Carrying out payment, refund, accounting and invoicing processes,
• Responding to customer requests, questions and complaints,
• Ensuring operational security and service quality,
• Fulfilling legal obligations,
• Establishing, exercising or protecting legal rights.

4 Methods of Collecting Personal Data

Your personal data may be collected by fully or partly automated means, or by non-automated means provided that the data forms part of a data recording system.

Personal data may in particular be obtained through:

• Website reservation and contact forms,
• Telephone calls,
• WhatsApp and similar communication channels,
• Email communications,
• Direct customer requests,
• Travel agencies and business partners,
• Corporate customers and event coordinators,
• Other channels used during the reservation or service process.

5 Legal Grounds for Processing Personal Data

Your personal data may be processed on the basis of the applicable personal data processing conditions set out in Article 5 of KVKK.

Depending on the circumstances, these legal grounds may include:

• Processing being directly related to the establishment or performance of a contract,
• Processing being necessary for the data controller to fulfil its legal obligations,
• Processing being necessary for the establishment, exercise or protection of a legal right,
• Processing being necessary for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed.

6 Payment Transactions

Depending on the reservation, payment for transfer services may be made in the vehicle, by EFT/bank transfer, credit or debit card via POS, mobile POS, payment link or another payment method accepted by our company.

If direct online payment functionality is made available on the website, payment transactions may be processed through the relevant bank, payment institution or secure payment service provider.

Financial information required for processing, monitoring and recording payments and, where necessary, carrying out refunds may be processed for these purposes.

7 Transfer of Personal Data

Where necessary for the provision of services or fulfilment of legal obligations, your personal data may be transferred, to the extent required and in accordance with applicable legislation, to the following recipient groups:

• Drivers assigned to the transfer operation,
• Contracted transportation and operational service providers used where necessary to provide the service,
• The relevant business partner where a reservation is made through a travel agency, company, institution or organisation,
• Banks and payment service providers, depending on the payment method,
• Accounting, financial, legal and similar professional service providers,
• Legally authorised public authorities, judicial authorities and administrative bodies.

Personal data transfers are limited, as a principle, to the information required for the relevant purpose, and unnecessary personal data is not intended to be shared.

8 Information Shared with Drivers and Operations Personnel

In order to provide the transfer service, the assigned driver or operations personnel may receive the passenger's name, pick-up location, destination, transfer date and time, flight information and other reservation information necessary for the operation.

Where direct communication with the customer or passenger is necessary during the transfer operation, the telephone number may also be shared with the assigned driver or relevant operations personnel.

9 Information Concerning Child Passengers

Where a transfer reservation includes a child passenger, the adult making the reservation may provide information concerning the child's age or other information required to determine the appropriate type of child restraint so that the transfer can be planned safely and appropriately.

We aim not to request information that is unnecessary for arranging an infant seat, child seat or booster seat.

10 Retention of Personal Data

Your personal data is retained for the period necessary for the purpose for which it is processed and for any retention periods required by applicable legislation.

Different retention periods may apply to different categories of data due to reservation, payment, accounting, invoicing, customer relations, legal disputes and statutory obligations.

Where the reasons requiring the processing of personal data cease to exist and there is no other legal obligation requiring its retention, the data will be deleted, destroyed or anonymised in accordance with applicable legislation.

11 Data Security

Our company takes appropriate administrative and technical measures, according to the nature of the processing, to help prevent unlawful processing of and access to personal data and to ensure the secure storage of personal data.

When data is shared with employees, operations personnel or service providers, personal data should be used only to the extent required for the relevant service.

12 Your Rights Under Article 11 of KVKK

As a personal data subject, you may apply to the data controller under Article 11 of KVKK to:

• Learn whether your personal data is being processed,
• Request information if your personal data has been processed,
• Learn the purpose of processing your personal data and whether it is being used in accordance with that purpose,
• Know the third parties to whom your personal data has been transferred in Türkiye or abroad,
• Request correction if your personal data has been processed incompletely or inaccurately,
• Request deletion or destruction of your personal data under the conditions provided by law,
• Request notification of correction, deletion or destruction operations to third parties to whom your personal data has been transferred,
• Object to a result arising against you through analysis of processed data exclusively by automated systems,
• Claim compensation if you suffer damage due to the unlawful processing of your personal data.

13 Applications to the Data Controller

You may submit requests concerning your rights under KVKK to the data controller together with information sufficient to identify you and to determine the nature of your request.

Applications will be evaluated in accordance with the procedures and methods prescribed by applicable legislation and will be answered within the statutory time limits.

14 KVKK Information During Reservation

When a reservation or transfer request is submitted through the website, this Privacy Notice may be presented to the user and a record may be obtained confirming that the user has read the notice and has been informed about the processing of personal data.

15 Updates to This Notice

This Privacy Notice may be revised in the event of changes in applicable legislation, company or travel agency information, systems used on the website, or our service and operational processes.

The updated version will apply from the date on which it is published on the website.