CLARIFICATION
TEXT ON THE PROCESSING OF PERSONAL DATA
SECTION
1 - INTRODUCTION
1.1 Introduction
This
Clarification Text has been prepared by DESE Group Companies (“”Company“”) in
order to enlighten the Company's customers regarding the processing of their
personal data by the Company within the scope of the Personal Data Protection
Law No. 6698 (“Law”).
Detailed
information on the processing of your personal data within the scope of this
Clarification Text can be found in the DESE Group Companies Personal Data
Protection and Processing Policy at [www.desecrew.com].
1.2 Scope
This
Clarification Text includes the methods of obtaining personal data and their
legal reasons, the purposes of processing, the rights of personal data owners,
and the ways to exercise these rights.
SECTION
2 - ISSUES RELATED TO THE PROCESSING OF PERSONAL DATA
2.1 Methods and Legal Grounds for
Obtaining Personal Data
Your
personal data is collected electronically or physically. Your personal data collected
for the legal reasons specified in this Clarification Text may be processed and
shared within the framework of the personal data processing conditions
specified in Articles 5 and 6 of the Law.
2.2 Purposes of Processing Personal
Data
Your
personal data is processed for the following purposes:
·
Planning
and/or execution of our Company's human resources policies and processes,
·
Planning
and/or execution of activities to ensure the legal and technical security of
our Company and related persons who are in business relations with our Company,
·
Planning
and/or execution of the activities necessary for the recommendation and
promotion of the products and services offered by and/or on behalf and account
of our Company to the relevant persons by customizing them according to the
tastes, usage habits and needs of the relevant persons,
·
Carrying
out the necessary work and carrying out the relevant business processes in
order to benefit the relevant persons from the products and/or services offered
by and/or on behalf and account of our Company,
·
Carrying
out the necessary work by our relevant business units for the realization of
the commercial and/or operational activities carried out by our Company and
carrying out the related business processes,
·
It
is processed for the purposes of planning and/or execution of our Company's
commercial and/or business strategies.
·
Your
name, surname, occupation, address, telephone and fax numbers, e-mail address
and other contact information,
·
Your
family and demographic information,
·
Your
identity and passport details,
·
Your
travel and route information,
·
Your
ticketing and booking details,
·
Your
information on invoicing and payment instruments,
·
Your
camera/video/photo records collected for security purposes,
·
Your
health data collected to fulfill our legal responsibilities regarding
accidents,
·
Your
details for making payments and receiving refunds,
·
Your
information that you have communicated to our employees within the scope of
your requests and complaints regarding products and services,
·
Your
information regarding your use of our website and other communication channels,
·
For
users of our website, other information arising from your visit to our website,
use of our services, interaction with our content and advertisements, including
computer/hardware and connection information, page view statistics, traffic
information to and from the page, ad data/advertising data, IP addresses and
standard web log information/standard web log information;
·
This
information is collected to the extent permitted and within the limits
permitted by the relevant legislation and the agreements made through the
channels through which organizations and persons authorized to represent such
as the website, mobile or digital applications, social media, companies whose
activities we carry out in the capacity of intermediary/agency, customer
interviews, SMS, written/digital applications made to other websites, support
service organizations, including those from which services are received,
contact you or may contact you in the future, by obtaining your consent where
legally mandatory.
2.4 Your personal data collected by
these methods may also be processed and transferred for the purposes specified
in Articles 2.3 of this Information within the scope of the personal data
processing conditions and purposes specified in Articles 5 and 6 of Law No.
6698.
SECTION
3 - TRANSFER OF PERSONAL DATA
Your
personal data may be shared with the Company's business partners and suppliers,
legally authorized institutions and organizations and legally authorized
private legal entities within the framework of the personal data processing
conditions and purposes specified in Articles 8 and 9 of the Law, within the
framework of the personal data processing conditions and purposes specified in
Articles 8 and 9 of the Law, for the purposes of carrying out the necessary
work by the relevant business units for the realization of the commercial
activities carried out by the Company and the execution of the related business
processes, planning and execution of the Company's commercial and / or business
strategies and ensuring the legal, technical and commercial-business security
of the Company and the relevant persons who have a business relationship with
the Company.
As
personal data owners, if your requests regarding your rights specified below
are submitted to the Company by the methods specified under the heading of
Exercise of Rights by Data Owners, your requests will be evaluated and
finalized by our Company as soon as possible and in any case within 30 (thirty)
days.
4.1 Rights of Personal Data
Subjects Pursuant to Article 11 of the Law
Personal
data subjects have the following rights pursuant to Article 11 of the Law:
·
Learn
whether personal data is being processed,
·
Request
information if their personal data has been processed,
·
To
learn the purpose of processing personal data and whether they are used for
their intended purpose,
·
To
know the third parties to whom personal data are transferred domestically or
abroad,
·
To
request correction of personal data in case of incomplete or incorrect
processing,
·
To
request the deletion or destruction of personal data within the framework of
the conditions stipulated in Article 7 of the Law,
·
In
case of incomplete or incorrect processing of personal data and to request
notification to third parties to whom personal data has been transferred for
actions to be taken regarding the deletion or destruction of personal data,
·
By
analyzing the processed data exclusively through automated systems objecting to
a result that is unfavorable to oneself,
·
In
the event that personal data is damaged due to unlawful processing of personal
data, it has the right to demand the compensation of the damage.
4.2 Cases where Data Subjects do
not have the Right to Request as per the Provisions of the Law
Pursuant
to the provision of paragraph 2 of Article 28 of the Law, the situations where
the data subject has no right to request are listed below:
·
Processing
of personal data is necessary for the prevention of crime or criminal
investigation,
·
Processing
of personal data made public by the data subject himself/herself,
·
Personal
data processing is necessary for the execution of supervisory or regulatory
duties and disciplinary investigation or prosecution by the authorized and
authorized public institutions and organizations and professional organizations
in the nature of public institutions based on the authority granted by law,
·
In
cases where personal data processing is necessary for the protection of the
economic and financial interests of the State in relation to budget, tax and
financial matters, the above-mentioned rights will not be exercised in relation
to the data.
According
to paragraph 1 of Article 28 of the Law, in the following cases, since the data
will be outside the scope of the Law, the requests of the data subjects will
not be processed in terms of these data:
·
·
Processing
of personal data for purposes such as research, planning and statistics by
anonymizing them with official statistics.
·
Processing
of personal data for the purposes of national defense, national security,
public security, public safety, public order, economic security,
confidentiality of private life or personal rights or for the prevention of
criminal offenses. for artistic, historical, literary or scientific purposes or
within the scope of freedom of expression, provided that such processing does
not constitute a violation of freedom of expression.
·
Processing
of personal data within the scope of preventive, protective and intelligence
activities carried out by public institutions and organizations authorized by
law to ensure national defense, national security, public security, public
order or economic security.
·
Processing
of personal data by judicial authorities or enforcement authorities in relation
to investigation, prosecution, trial or execution proceedings.
4.3 Exercise of Rights by Data
Subjects
Data
subjects may exercise the aforementioned rights by contacting
[www.desecrew.com]
They
will be able to use the “Form for Applications to be made by the Personal Data
Owner to the Data Controller” available at the link.
·
Applications
shall be made by one of the following methods together with the documents that
will identify the identity of the relevant data subject:
·
The
form should be completed and a wet signed copy sent by hand, through a notary
public or by registered letter with return receipt [Adalet Mah. Manas Bulv.
No:4 B K:26 D:2601 Folkart Towers A Tower Bayraklı/İzmir/Turkey] to the address
below,
·
Following
a method stipulated by the Personal Data Protection Board.
·
The
Company responds to data subjects who wish to exercise such rights within the
limits stipulated in the Law within a maximum period of thirty (30) days as
stipulated in the Law. In order for third parties to make an application
request on behalf of personal data subjects, there must be a special power of
attorney issued by the data subject through a notary public on behalf of the
person who will make the application.
·
Although
data subject applications are processed free of charge as a rule, if necessary,
charges may be made over the fee tariff stipulated by the Personal Data
Protection Board.
·
The
Company may request information from the relevant person in order to determine
whether the applicant is a personal data owner or not, and may ask questions to
the personal data owner about his/her application in order to clarify the
matters specified in the application.