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General Data Protection Regulation (GDPR)

WEBSITE PRIVACY AGREEMENT

 

By visiting our websites, you can receive information about the services we provide to you through our websites and benefit from our services. The use and protection of the information we obtain about you and the services you request are subject to the terms specified in this “Privacy Agreement.” By visiting our websites, you accept the terms specified in this “Privacy Agreement.”

 

PERSONAL DATA PROCESSING INFORMATION NOTICE

 

We, Nexonya (“Nexonya”), act as the data controller and process your personal data in accordance with the Law No. 6698 on the Protection of Personal Data (“PDPL”) and relevant regulations. We comply with the requirements of PDPL, its secondary legislation, binding decisions of the Personal Data Protection Board, and the technical and administrative measures stated in the relevant legislation to ensure the protection of the processed data.

 

Through this notification, we fulfill the obligation of informing as a data controller under Article 10 of the PDPL. In doing so, we aim to provide detailed information to our visitors about the processing of your personal data within the context of activities conducted through https://www.nexonya.com and/or all other websites under Nexonya’s administration (“Website”).

 

  1. How is your personal data collected?

 

  1. For what purposes and on what legal grounds do we process your personal data?

 

  1. Which personal data do we process?

 

  1. For what purposes and with whom may we share your personal data?

 

  1. What are your rights regarding your personal data and how can you exercise these rights?

 

  1. How can we obtain your personal data?

 

 

COLLECTION OF YOUR PERSONAL DATA

At Nexonya, we collect personal data of our Website visitors either wholly or partially through fully automated or semi-automated means. This includes cookies present within the Website, your visits to the Website, filling out forms present on the Website, completing the ‘Contact Form’ within the “Contact Us” section of the Website, and reaching out to us through the phone numbers provided on the Website.

 

PURPOSE OF DATA PROCESSING AND LEGAL BASIS FOR COLLECTION

The personal data obtained through the collection methods described above is processed by Nexonya for the following purposes and legal reasons:

 

Internet Site Data: Connection/entry-exit date (log record) and time information related to your visit, IP address, username, and password information for transaction security data, information related to content searches, legal consent for electronic commercial communications, request and complaint information, granted legal consents, customer transaction data, email address, phone number, address information, billing address.

Communication Data: Information obtained through the use of cookies.

Marketing Data: Full name, T.R. ID number, Passport Number, Date of Birth, Identity Data.

If you choose the “Bank-Credit Card” section under “Payment Options,” the following information related to your card will be categorized under Customer Transaction Data: name-surname on the card, card number, card type, card expiration date, CVV number. Nexonya, as the data controller, does not process this information. These details will be processed by the organizations we have an agreement with for the completion of the payment process and for the service relationship between us.

 

WHICH PERSONAL DATA DO WE PROCESS?

At Nexonya, as part of the services we provide to our valued guests, we may process various categories of your personal data:

  • Identity and Contact Information: Your name, surname, ID number, passport information, as well as your email address, phone number, mobile phone number, and address details.
  • Visual and Auditory Records: Your photograph, call center records.
  • Financial Information: Financial records or payment details related to the services you have obtained from our company.
  • Current and Past Transaction Information: Your current or past hotel or package tour preferences, travel information related to your reservations.
  • Request and Complaint Information: Written or verbal records of requests and complaints you have communicated to us regarding the services provided by Nexonya or special requests related to an existing reservation.
  • Insurance Information: Details related to your travel insurance policy.
  • Sensitive Personal Data: In the event of a health condition that may require special considerations during your travel or if you need to request reservation changes or cancellations due to illness, we may process your sensitive personal data, which may include health information.

 

4-A PROCESSING YOUR PERSONAL DATA FOR WHICH PURPOSES?

 

At Nexonya, we may process your personal data for the following purposes and based on legal grounds:

 

  • To provide you with the requested products and services in the best possible manner, we process your personal data based on the legal ground stipulated in Article 5/2-c of the Law, which relates to the necessity of processing personal data for the establishment, exercise, or protection of a contract. Nexonya offers various products and services, primarily including tour reservations, to you. In order to provide you with the requested products and services or to register your membership through our website, we process your personal data such as identity, contact, request, or financial information. This enables us to facilitate your reservations, manage operational processes, and monitor your membership journey. For instance, to organize a preferred package tour, we make hotel reservations, book flight tickets on your behalf, notify the relevant individuals to welcome you, and communicate information about your travel. If processing sensitive personal data is necessary during the reservation process, we will obtain your explicit consent before processing such data.
  • To enhance the quality of our products and services, we process your personal data based on the legal ground stated in Article 5/2-f of the Law, which pertains to the legitimate interests of the data controller, and occasionally, based on the legal ground stipulated in Article 5/2-d of the Law, which refers to the data subject’s personal data being made public by themselves. Nexonya consistently seeks ways to provide better service to our guests. In pursuit of this, we conduct activities and analyses for business development, including but not limited to enhancing the quality of our products and services, measuring guest satisfaction, gaining deeper insights into our customers and their preferences, and formulating more effective business strategies. We process your personal data to carry out these activities. Additionally, we may process the personal information included in the feedback you provide through public channels, such as social media, to enhance our products and services and measure customer satisfaction.
  • For the purpose of conducting commercial communication activities, we process your personal data by obtaining your “explicit consent” in accordance with Article 5/1 of the Law. At Nexonya, we offer a wide range of products and services. To introduce these offerings to you, inform you about exciting new developments and opportunities, we may send you notification content. Receiving these notifications is entirely at your discretion; you can allow us to send you these messages whenever you wish, or you can withdraw your consent that you’ve previously provided.

 

  • For the purpose of resolving your requests and complaints, we process your personal data based on the legal grounds stipulated in Article 5/2-f of the Law, which pertains to the legitimate interests of the data controller, and Article 5/2-c of the Law, which pertains to fulfilling the legal obligations of the data controller. Your requests and feedback are of utmost importance to us. To evaluate your requests regarding how we can better provide you with our services and to address any negative experiences you may have encountered, or to take necessary precautions to prevent their recurrence, we may process your personal data.

 

  • For the purpose of creating financial records, we process your personal data based on the legal ground stipulated in Article 5/2-c of the Law, which pertains to the necessity of processing personal data for the establishment, exercise, or protection of a contract. While managing our company’s financial processes, we may process your personal data. For instance, personal data can be processed when generating invoices for the services provided, creating financial records, or conducting financial audits.

 

  • For the purpose of conducting internal company operations, we process your personal data based on the legal ground stated in Article 5/2-f of the Law, which pertains to the legitimate interests of the data controller. Similar to most companies, during the course of our business operations, we process personal data when conducting specific processes and creating records within the company. For instance, we manage our information technology infrastructure, reward our employees’ performances, and carry out internal audit operations.
  • For the purpose of fulfilling our legal obligations, we process your personal data based on the legal grounds stipulated in Article 5/2-c and Article 5/2-a of the Law, which pertain to fulfilling the legal obligations of the data controller and the explicit provisions of the law, respectively. As a company, we are subject to various legal obligations. For instance, to fulfill certain obligations arising from regulations such as tourism, tax, and insurance legislations, we may process your personal data. We may also share your information with authorized public institutions or private organizations. Particularly in response to lawful information requests made by authorities such as judicial bodies, law enforcement agencies, regulatory and supervisory authorities, we may process your personal data to comply with these requests in accordance with the law.

 

 

 

4-B SHARING YOUR PERSONAL DATA FOR WHICH PURPOSES AND WITH WHOM?

 

In certain situations, we may share your personal data with third parties. Below, we summarize the parties with whom we may share your personal data and the reasons for sharing. It is important to emphasize that at Nexonya, we never share or provide unauthorized third parties with access to your personal data for our own benefit.

 

The third parties with whom we may share your personal data and the reasons for sharing are as follows:

  • We may share your personal data with our business partners. Within the scope of our package tour services, we may share your personal information with our suppliers, such as hotels and accommodation service providers, transportation companies providing air or bus services, insurance companies providing travel insurance services, or companies providing event organization services, which enable us to offer you the products you purchase. Especially when purchasing package tours involving international travel, the business partners to whom we transfer your information may be located abroad. In many cases, the third parties to whom we transfer your personal data may also process your personal data as data controllers.

 

  • We may share information with our suppliers. At certain points where we communicate with you, we make use of the services of third parties outside of Nexonya. In this context, we directly obtain services from suppliers in matters such as commercial communication campaigns, website management, and provision of our information technology infrastructure. Additionally, to protect the legal and economic interests of our company, we may share your personal data with legal advisors. In these situations, we may transfer your personal data to our suppliers.

 

  • We may transfer your information to financial institutions. In order to facilitate payments related to our services, we may share your personal data with banks or payment service providers.

 

  • We may share your personal information with authorized public institutions or private individuals when legally requested. In accordance with our legal obligations, we may routinely share your information with authorized public institutions or, upon request, with relevant authorities due to insurance and tax regulations we are subject to. For instance, we may share your information with governmental agencies during tax audits or in response to information requests from courts as part of criminal investigations.

 

 

 

 

WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA AND HOW CAN YOU EXERCISE THESE RIGHTS?

You have the following rights concerning your personal data:

  • 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 for their intended purpose,
  • To know the third parties in Turkey or abroad to whom your personal data has been transferred,
  • To request the correction of your personal data if they are incomplete or inaccurate,
  • To request the deletion or destruction of your personal data within the framework of the conditions stipulated in Article 7 of the PDPL,
  • To request the notification of the operations carried out as per paragraphs (d) and (e) to third parties to whom your personal data has been transferred,
  • To object to a result against you arising from the analysis of your processed data solely through automated systems,
  • If you suffer any damages due to the unlawful processing of your personal data, you have the right to request compensation for such damages.

Your request will be answered in accordance with the relevant provisions of the PDPL, and Nexonya may request some confirming information from you to verify your identity. This information will only be requested for the purpose of confirming your identity as the actual data subject and sharing the results of the application accurately with the right person.