Last Update: October 18, 2021
The purpose of this Disclosure Text on the Protection and Processing of Personal Data (Disclosure) is the fulfillment of the obligation of disclosure pursuant to Article 10 of the Law on Protection of Personal Data No. 6698 (LPPD) with regard to the use of personal data obtained and/or received from third parties during the use of the web site www.turna.com (TURNA) managed by the company Tripenia Bilişim Turizm Seyahat Acentası ve Ticaret Anonim Şirketi (TRIPENIA). It is also intended to transparently enlighten the Users about the purposes of processing, legal reasons, their rights and the manner in which the personal data collected by TRIPENIA on the use of TURNA by the Users or the personal data entered into TURNA by the User's positive actions.
TURNA, which offers flight ticket reservation and sale services, works as the agent of various airlines. In line with these activities, personal data may be processed as required by the use of TURNA's functions as specified in this Disclosure text.
TURNA, a platform that received the Altın Örümcek Award in the field of the "Best Tourism and Travel Site" in 2016 and 2017, takes the highest possible security precautions in order to ensure the collection, storage, and sharing of personal data and protection of its confidentiality pursuant to the law. In order to achieve this purpose, personal data of Users are processed in the scope and conditions detailed below.
TRIPENIA may update and amend the provisions of this Disclosure at any time by publishing them on TURNA. Updates and amendments made by TRIPENIA shall be effective as of the date of publication in TURNA.
Pursuant to LPPD, your personal data may be collected and processed by TRIPENIA in its capacity as the data controller to the extent described below.
TRIPENIA collects a variety of static (steady) and dynamic (variable) data from Users by using the following methods. The data that TRIPENIA collects depends on the services and features that the Users use.
Under this article, the data processed by TRIPENIA under the scope of the services provided and personal data pursuant to the LPPD are listed below in groups. Unless expressly stated otherwise, "personal data" and "sensitive personal data" expressions include the following information under the terms and conditions set forth in the Disclosure Text:
| Personal Data Collected | |
|---|---|
| Identity and Contact Information | Name, surname, mobile phone, home phone, business phone, address, email address, invoice information, TR identification number (national identification number), photocopy of identity card and other similar documents. |
| Identity Authentication Information | Membership information of users, passwords used to authenticate and provide access to the account, Membership type, social media accounts, contact information, password hints, User numbers. |
| Demographic Data | Date of birth, age, gender, marital status, interests, travels, preferred language data. |
| Usage Data and Favorites | Data collected from your devices through various software and technological tools, including but not limited to your reasons for calling TRIPENIA or Call Centers; booking codes, voice recordings, flight ticket destination search information; date and time data that TURNA is used; flight tickets, dates, times, landing and departure places examined through TURNA; the data specified in the relevant advertisement or banner and their filtering, sorting, prioritization options so that users can be directed to the related product through modules such as banner routing and the product supplier companies contact the user; last entry date to TURNA, membership type, points collected, websites visited, number of pages displayed, duration of visit, search terms entered, information of flights visited; errors and similar problems that occur during service usage. |
| Location Data | It includes data about the precise or approximate location of users. GPS data, location data extracted from IP and port addresses, and the location data on the user's mobile device may be used on the condition that the user approves when using mobile applications of TRIPENIA. |
| Cookie Data | Browser information, IP and port data, browser movements, browser selection information and any data that can be obtained through cookies. |
| Payment Data | Data such as credit card data, invoice, and payment information (name, surname, billing address, TR identification number, tax identification number), bank receipt samples of invoices sent to members and payments received from members, payment number, invoice number, invoice amount, invoice date. |
| Survey Responses | Responses to periodic surveys organized by TRIPENIA within TURNA and responses to surveys conducted by natural and legal persons with whom TRIPENIA cooperates. |
| Travel Data | Flight information searches, destination data of interest, reservation information, travel date, and time information, meal preferences, flight insurance data, delay, and ticket usage data, disability and disease data, baggage data, preferred airline data. |
Your personal data that we have obtained may be stored at home or abroad in another country where TRIPENIA or its affiliates, subsidiaries or their service providers have facilities and may be processed for the purposes of this Disclosure Text and in proportion to these purposes.
Your personal data collected under this Disclosure Text shall be processed pursuant to the provisions stated herein and within the scope of the legislation in force in the country where the data is stored and processed and within the limits of the prescribed security precautions.
Your personal data shall be processed in line with the purposes stated in Disclosure Text and the Terms of Use Agreement, in accordance with the Principles and Processing Conditions issued by LPPD No. 6698 and within the scope of the purposes set forth below:
| Identity and Contact Information | Mainly as required by the service contract; internal evaluation, communication, user registration, obtaining potential customer information, developing after-sales processes, business development, collection of revenues, customer portfolio management, promotion, analysis, complaint management, managing customer satisfaction processes, marketing, advertising, research, invoicing, event information, conducting operational activities, measuring and improving service quality, auditing, controlling, optimization, customer verification, marketing, sales, advertising, after-sales services, detection and prevention of fraud; |
| Identity Authentication Information | User registration, problem/error reporting, control, execution and development of operational activities, development of after-sales processes, business development, collection, in-house evaluation, customer portfolio management, service quality measurement, communication, optimization, audit, risk management, audit, customer verification, detection and prevention of fraud; |
| Demographic Data | Promotion, in-house evaluation, analysis, communication, development of after-sales processes, business development, collection, usage data and interests, favorites, marketing, sales, advertising, audit and control, risk management, development of after-sales processes, business development, collection, customer portfolio management, after-sales services, measuring, improving service quality, conducting communication, complaint management processes, conducting and developing operational activities, registration, problem/error reporting; |
| Usage Data and Favorites | User registration, problem / error reporting, control, execution and development of operational activities, development of after-sales services and after-sales processes, business development, collection of revenues, in-house evaluation, online behavioral advertising and marketing, customer portfolio management, measuring and improving service quality, communication, optimization, audit, risk management and control, promotion, analysis, determination of areas of interest, scoring, profiling, marketing, sales, advertising, communication, complaint management processes, registration, problem / error reporting; |
| Location Data | Use of location-based or location-related TURNA functions, audit and control, risk management; |
| Cookie Data | Control, execution and development of operational activities, development of after-sales processes, business development, collection of revenues, in-house evaluation, online behavioral advertising and marketing, customer portfolio management, measuring and improving service quality, communication, optimization, audit, risk management and control, promotion, analysis, determination of areas of interest, scoring, profiling, marketing, sales, advertising, communication, conduction of complaint management processes, registration, problem / error reporting; |
| Payment Data | Managing the billing process, accounting, development of after-sales processes, business development, collection of revenues, in-house evaluation, scoring, profiling, customer portfolio management, after-sales services, communication, marketing, auditing, control, processes carried out with payment service providers; |
| Survey Responses | Information requested from users who respond to periodic surveys organized by TRIPENIA within TURNA, statistical analysis, database creation and direct marketing aimed at these users by third party natural and legal persons with whom TRIPENIA cooperates within the scope of all processing activities mentioned above for the purpose of making TURNA functions available and performing these functions by TRIPENIA in accordance with TURNA’s intended use; |
| Travel Data | Drawing up and performance of the agreement, execution and development of operational activities, development of after-sales services and after-sales processes, business development, collection of revenues, in-house evaluation, online behavioral advertising and marketing, customer portfolio management, measuring and improving service quality, communication, optimization, audit, risk management and control, promotion, analysis, determination of areas of interest, scoring, profiling, marketing, sales, advertising, communication, complaint management processes, registration, problem / error reporting; |
The said data shall be processed pursuant to the personal data processing conditions and purposes specified by the Article 5 and 6 of the Law No. 6698 within the framework of the obligations arising from legal regulations, activities performed and the agreements made with third party natural or legal persons who have business relations with TRIPENIA, for the purposes of the fulfillment of legal and commercial obligations, obligations of TRIPENIA arising from agreements concluded with its partners/clients/suppliers, establishing a right, protecting the rights, conducting the commercial and legal evaluation processes, conducting the legal and commercial risk analyzes, conducting the legal compliance process, fulfilling the decisions of authorized institutions, organizations and authorities, and responding to their requests.
TRIPENIA shall retain the personal data it receives for the period required for the purpose in which they are processed in order for the Users to make the best use of the Service in order to fulfill the obligations arising from the nature of Terms of Use Agreement and pursuant to the conditions set forth in this Disclosure Text and the Terms of Use Agreement.
In addition, TRIPENIA may retain personal data for a limited and prescribed period of time pursuant to the applicable legislation for the purpose of conducting administrative or judicial proceedings under any dispute arising out of the Terms of Use Agreement.
TRIPENIA shall share the personal data of the User, the new data obtained by using this personal data or the personal information that the Users enter into TURNA with their positive actions primarily for the purpose of fulfilling the requirements of the Membership Agreement and performing the Services, improving the user experience (including enhancement and customization), ensuring the security of the Users, detecting and preventing fraud, improving Services, conducting operational evaluation research, correcting errors, verifying User identities, improving system performance and carrying out any of the purposes mentioned in the processing purposes section above to third-party natural and/or legal persons, including outsourcing service providers, airline companies, airport administrations, national and international airline regulation and inspection agencies, airline coordination organizations, law firms, research companies, call centers, software companies providing complaint management and security services, agencies, consultancy companies, companies in the press sector, banks, social media channels, and authorized institutions, organizations, authorities, administrative and judicial bodies within the scope of legal obligations.
In addition, the name and contact information of the User may be shared with the payment institutions in accordance with the framework agreement of the payment institution to be approved by the User at the payment stage and pursuant the Regulation on Measures for the Prevention of Laundering of Crime Revenues and Financing of Terrorism published in the Official Gazette dated January 9, 2008 and numbered 26751.
Your personal data obtained through cookies placed on your device may be shared with third parties for the purposes and scope specified in this Disclosure Text.
TRIPENIA may transfer personal data to third parties at home or abroad, within the above-mentioned categories and purposes, limited and proportionate to these purposes. When the User wants to log in to TURNA via Facebook or Google, the login information can be shared with Google or Facebook providers abroad for authentication purposes.
TRIPENIA collects your personal data to work in a more qualified manner and to provide you the best experience. Your data is collected by using the following methods:
| Data You Have Directly Given to TRIPENIA: | Refers to the personal data provided by TRIPENIA at the discretion of the Users for the performance of the Service and before or in due course of the use of TURNA. This personal data covers all personal data provided directly by the Users to TRIPENIA as a result of their positive action. For example, name-surname, contact information, identity information, flight ticket reservation-sales information, billing information, demographic data are included in this type of data. |
| Data that We Obtain When You Use Our Platform: | Data that We Obtain When You Use Our Platform: It includes personal data about the usage habits of Users obtained through certain software or technological tools during the service provided by TRIPENIA. For instance, location data and preferred destinations, as well as areas of interest and usage data, are included in such data. |
For online behavioral advertising and marketing purposes, TRIPENIA may associate the behavior of user, even if he/she is not a member, who visits the site with a cookie in the browser and define remarketing lists based on metrics such as the number of pages displayed, the duration of the visit and the number of target completions.
Your personal data collected by using these methods may be processed and transferred for the purposes set out in this Disclosure Text in accordance with the basic principles stipulated by the LPPD and within the scope of the personal data processing conditions and purposes set forth in Articles 5 and 6 of the LPPD No. 6698.
TRIPENIA undertakes to protect personal data securely. Technical and administrative measures to ensure the proper level of security in order to prevent unlawful processing and access to personal data and to protect personal data are carried out using various methods and security technologies.
TRIPENIA shall not disclose any personal data obtained in contravention of this Lighting Text and the provisions of LPPD No. 6698 and shall not use it for any purpose other than for processing purposes. TRIPENIA hereby declares that in the event that the personal data of the Users is shared with the outsourcing service providers in accordance with this Disclosure Text, it shall also carry out the necessary warning and audit activities in order to have the outsourcing service providers comply with the commitments under this article.
In case of linking to other applications via TURNA, TRIPENIA shall not undertake any responsibility for the privacy policies and contents of the linked applications.
The User undertakes that the information subject to this Disclosure is complete, accurate and up-to-date, and in case of any changes to this information, she shall update them immediately from the address https://www.turna.com/user/profile. TRIPENIA shall have no responsibility if the user has not provided up-to-date information.
Personal data is deleted, destroyed or anonymized directly by TRIPENIA or upon the request of the User, when the periods required to be kept by law, the completion of judicial proceedings or other requirements are no longer valid.
In the event that you, owner of personal data, submit your claims regarding your rights to TRIPENIA by using the following methods stated below, TRIPENIA shall conclude the claim within the shortest time possible depending on the nature of the claim and within thirty days at the latest and free of charge. For the response, there will be no charge for up to ten pages. A transaction fee of 1 Turkish Lira will be charged for each page more than 10 pages. If the response is submitted on a recording medium such as CD, flash memory, the fee that may be requested by TRIPENIA shall not exceed the cost of the recording medium.
In this context, personal data owners have the rights;
You may communicate your claim regarding the use of your rights mentioned above, in Turkish and along with the documents that determine your identity by hand to the address "YTÜ Yıldız Teknopark, Davutpaşa Kampüsü, C1 Blok No:310 Esenler, İstanbul" of Tripenia Bilişim Turizm Seyahat Acentası ve Ticaret Anonim Şirketi, as data supervisor, through the notary public, to the address [email protected] as registered e-mail or by other means specified by the Personal Data Protection Board.
TRIPENIA reserves the right to verify your identity before responding.
Your application must include;