CONFIDENTIAL AND PRIVILEGED
Subject: Informing data subjects in accordance with the Law on Protection of Personal Data No. 6698 regarding the acquisition of personal data of customers/visitors
I. Privacy Notice.
1. Introduction
This information text has been prepared by Omnia Nisata Europe Industry and Trade Inc. ("Companies") to ensure the processing of personal data of individuals who are our guests and the employees, staff, or representatives of our corporate guests in compliance with the Constitution of the Republic of Turkey, international agreements to which our country is a party regarding human rights, and relevant legislation, primarily the Law on Protection of Personal Data No. 6698 ("KVKK"), and to enable the effective exercise of the rights of the data subjects whose data is processed. All personal data shared with our Companies can be processed in a lawful manner, in connection with our activities and services, and in a proportional manner.
2. Definitions
The terms "personal data," "sensitive personal data," and "data processing" used in this information text are based on the definitions provided in the KVKK - General Data Protection Regulation (GDPR). The term "personal data" mentioned in the KVKK refers to any kind of information relating to an identified or identifiable natural person; the term "processing of personal data" refers to any operation performed on personal data, whether fully or partially automated or not, such as obtaining, recording, storing, preserving, modifying, reorganizing, disclosing, transferring, sharing, acquiring, classifying, or preventing its use; and the term "sensitive personal data" refers to data concerning individuals' race, ethnicity, political opinion, philosophical belief, religion, sect or other beliefs, appearance, association, foundation, or union membership, health, sexual life, criminal conviction, security measures, as well as biometric and genetic data.
3. Principles of Personal Data Processing
According to Article 4 of the KVKK, personal data belonging to data subjects shall be processed by the data controller Companies in compliance with the law and honesty principles, accurately and if necessary up to date, for specific, clear, and legitimate purposes; in connection with the purpose they are processed, limited and proportionate; and in compliance with the rules regarding the retention period prescribed by the relevant legislation or necessary for the purpose of processing.
4. Purposes of Personal Data Processing
Your personal data will be processed within the scope of the following purposes:
• Fulfillment of contractual obligations arising from the contractual relationship between the Companies and the customer/visitor, and fulfillment of other legal, administrative, or contractual obligations,
• Evaluation of complaints, requests, and wishes for customer/visitor satisfaction,
• Development of special services and campaigns for customers/visitors to enhance their service experience,
• Determination of the type of communication activities to be conducted with customers/visitors,
• Resolution of potential disputes between the Companies and the customer/visitor,
• Exercise and protection of the Companies' rights granted under legal grounds,
• Fulfillment of the Companies' legal obligations,
• Evaluation of customer/visitor satisfaction,
In accordance with the personal data processing conditions specified in Articles 5 and 6 of the KVKK.
5. Transfer of Personal Data
Our companies act in accordance with the regulations stipulated in the KVKK- General Data Protection Regulation (GDPR) regarding the transfer of personal data. Unless otherwise stated in the legislation, personal data and sensitive personal data are not transferred to other individuals or legal entities by us without the explicit consent of the data subject. In exceptional cases stipulated by the KVKK and other relevant legislation, utmost care is taken to ensure compliance with the specified procedures and limitations when transferring personal data to authorized administrative or judicial institutions or private organizations.
Your personal data may be transferred in accordance with the following procedures and principles set forth in the legislation and the conditions and purposes for transferring personal data specified in Articles 8 and 9 of the KVKK:
• To authorized public institutions and organizations and legally authorized private individuals for the fulfillment of legal obligations,
• To transportation companies with which we have agreements for the organization of airport transfers in line with the requests of our corporate or individual customers/visitors,
• To relevant judicial authorities for the conduct and monitoring of judicial processes,
• To our affiliates, subsidiaries, group partners, and international stakeholders,
• Anonymously to data management platforms with which we have contractual relationships,
• To airline companies and business partners operating in the same sector arising from situations such as mergers, divisions, and acquisitions,
• To companies and online service providers operating in the fields of information technology; education; electricity and electronics; finance; food; construction; culture, art, and design; media, communication, and publishing; automotive; health and social services; textiles, ready-to-wear, and leather; trade and retail; tourism, aviation, accommodation, food and beverage services; transportation, logistics, communication, and telecommunications, within the framework of the procedures and principles stipulated in the relevant legislation.
6. Method and Legal Basis for the Collection of Personal Data/Sensitive Personal Data
Your personal data is collected by our companies through automated or non-automated methods; directly by our companies and call centers we receive services from, through websites, call centers, mobile applications, social media platforms, orally, in writing, or electronically. Your personal data provided during the contractual relationship with our companies and at each stage of this process will be processed and updated in compliance with the relevant legislation for the periods during which you benefit from the products and services offered by our companies and for the periods in which our companies have a legitimate interest in storing the information according to the relevant legislation.
The legal basis for the processing of your personal data by our companies is the explicit consent provided by the data subject in accordance with the first paragraph of Article 5 of the KVKK and the exceptions to explicit consent stipulated in subparagraphs (a), (c), (ç), (e), and (f) of Article 5 and the third paragraph of Article 6. Your personal data is collected by our companies in compliance with all applicable legislation and for the purposes stated in clauses 4 and 5 of this Privacy Notice.
7. Rights of the Data Subject under Article 11
Data subjects have the right to apply to the Companies acting as data controllers and request information regarding the processing of their personal data, whether their personal data is being processed or not; to request information about the purposes of the processing and whether these purposes are being met; to be informed about the third parties to whom their personal data is transferred domestically or abroad; to request the correction of their personal data if it is incomplete or incorrect; to request the deletion or destruction of their personal data in accordance with the conditions stipulated in Article 7 of the KVKK; to request that the actions taken under paragraphs (d) and (e) of Article 11 of the KVKK be notified to the third parties to whom their personal data has been transferred; to object to the occurrence of a result against them by solely analyzing the processed data through automated systems; to request the compensation of damages in case of suffering damage due to the unlawful processing of their personal data.
Explicit Consent
I have read and understood the information provided in this Privacy Notice prepared in accordance with Law No. 6698 on the Protection of Personal Data. I freely and explicitly consent to the processing of my personal data collected through the methods specified in this Privacy Notice, including the transfer of such data, including international transfers, within the scope of the purposes and principles mentioned in this notice. I also consent to the storage and processing of my data for the periods during which the relevant legislation requires or our Companies have a legitimate interest in storing the data after the termination of the contractual relationship.
