Introduction

Türk Hava Yolları Anonim Ortaklığı (hereinafter referred to as “THY”, “Company” or “We”), pays the utmost attention to the lawfulness of the processing of personal data of its customers. The Turkish Airlines Protection of Personal Data Announcement (“Announcement”) herein have been prepared in accordance with the Article 10 of Law on Protection of Personal Data numbered 6698 (“Law”) and EU General Data Protection Regulation (“GDPR”) to ensure that the personal data of our customers that are buying tickets, making reservations or during similar operations at our ticket sale offices, check-in counters at airports or our agencies are processed under their full control and in a transparent manner. 

In this respect, within this Announcement we provide you information on, as a data controller, which personal data of yours we process and for what purposes, the third parties we share your data with, your rights and methods that you may contact us. 

For more detailed information about the processing of your personal data, you may read the Türk Hava Yolları Anonim Ortaklığı Privacy Notice on the Processing and Protection of Personal Data on https://www.turkishairlines.com/en-tr/legal-notice/privacy-policy/index.html. If you are a passenger subject to GDPR, please find more detailed information on https://www.turkishairlines.com/en-pl/legal-notice/gdpr-privacy-notice/

How Do We Collect Your Personal Data? What Is Our Legal Basis for Processing Your Personal Data?

Your personal data can be collected while you are buying tickets, making reservations or during similar operations at our ticket sale offices, check-in counters at airports or our agencies via printed documents and/or through electronic systems. As per the Law, your personal data may only be processed where one or more conditions that are stipulated under Law are present. As THY, regardless of the purpose for which we process your personal data, we process it in accordance with the provisions of national and international law, primarily the general principles stated under Article 4 of the Law and by relying on conditions for lawful data processing listed under Article 5 and 6 of the Law.In this respect, as Turkish Airlines, we may rely on different legal bases, including: i) it is expressly provided for by the laws, ii) the necessity to establish a contractual relationship with you and to perform our obligations under a contract (provision of airline transport services and other related services) iii) complying with obligations under national and international regulations and iv) our legitimate interests provided that such interests do not have a negative impact on our customers’ fundamental rights and freedoms.

In addition to the above-listed conditions for processing personal data, we may request you to explicitly consent to the processing of your personal data. If this is the case, personal data will be processed limited to the scope of your freely given explicit consent. Any consent given can be withdrawn at any time

Which Personal Data We Process? 

General information on your personal data processed by THY are as follows (For more detailed information about the type of personal data processed, you may read the Türk Hava Yolları Anonim Ortaklığı Privacy Notice on the Processing and Protection of Personal Data published on. https://www.turkishairlines.com/en-tr/legal-notice/privacy-policy/index.html : 

• Identity and Contact Information: Personal data such as name, surname, identification number, passport information and contact information such as e-mail address, phone and cell phone number or social media contact information that you have provided to us while creating accounts, making plane ticket reservations or applying for exclusive services offered by THY and its partners. For more detailed information about processing of Identity/Passport Information you may read the “Turkish Airlines Protection of Personal Data Announcement for the Processing of Identity/Passport Information” published on https://www.turkishairlines.com/en-tr/legal-notice/privacy-policy/processing-of-identity-passport-information/
• Flight Information: Reservation or ticket information or other information related to your flights, 
• Advance Passenger Information (“API”): Personal data relating to your name, nationality, birth date, gender, type and number of your travel documents and its date of validity, and its issuing country. 
• Evaluations and requests: Information regarding your assessments, complaints and requests relating to our services. 
• Payment Information: Credit/Debit card information, bank account information, IBAN information, balance and receivable information and other financial data, 
• Membership Program Information: If you are a member, information regarding Miles&Smiles ve Turkish Airlines Corporate Club membership programs. 
• Special Categories of Personal Information: Provided that you have your request and approval, information about the disease, disability, allergy and special dietary requirements and the information contained in the documents related to them, to provide the service you need during your travel.
• Marketing Information: reports and evaluations containing information indicating preferences, taste, usage and travel habits attributable to our customers and used for the purposes of marketing, targeting information, cookie records, data generated within data enrichment operations, records of surveys, satisfaction surveys, information and evaluations obtained as a result of campaigns and direct marketing activities etc.

Why Do We Process Your Personal Data? 

THY will process your personal data for the following purposes. (For more detailed information about the purposes of processing of your personal data, you may read the Türk Hava Yolları Anonim Ortaklığı Privacy Notice on the Processing and Protection of Personal Data published on https://www.turkishairlines.com/en-tr/legal-notice/privacy-policy/index.html). 

• Management of flight reservations and other related services: Performing operational transactions such as flight booking, issuing flight tickets, check-in transaction regarding baggage and cargo transportation, flight card preparation, boarding and other services related to your flight. 
• Communication: Informing our customers regarding our regular operations such as establishing communication with you via SMS, e-mail or telephone for the purposes of conveying booking information, confirmation regarding the purchase of your ticket or to provide payment and flight details. (Please be noted that the electronic messages transmitted for the purposes stated above, or for other similar service information and excluding messages transmitted for marketing purposes shall not require the consent of the recipient as per the Article 6 of the Regulation on Commercial Communication and Commercial Electronic Messages and may be transmitted to you by THY without obtaining your consent.) 
• Evaluation of Your Requests and Opinions: Receiving and evaluating the opinions, complaints and evaluations of our customers about our services through written/online forms and surveys, and sending gifts among the products listed on the https://shopandmiles.com website within the scope of customer satisfaction.
• Legal Obligations: Ensuring compliance with the national and international legislation to which THY is subjected to and fulfilling the obligations arising from the relevant legislation, 
• Service Customization: Offering, proposing and introducing the programs, services and products to the related persons and performing the activities for the customization of them according to the usage habits and needs of the related persons, 
• Membership Programs: In case you are a member of our membership programmes, in particular to Miles&Smiles, Turkish Airlines Corporate Club, carrying out the necessary work to take advantage of related loyalty program services and carrying out the relevant business processes. 

To Whom We Transfer Your Personal Data and Why? 

Under certain circumstances, we may transfer your personal data that we process to third parties residing within borders or abroad, in accordance with the provisions of national and international law, particularly Article 8 and 9 of the Law. 

Third parties that we may transfer your data can be listed categorically as follows: 

• Our business partners or suppliers residing within borders or abroad; e.g., Security firms, ground operation service providers at airports, transportation service providers, global distribution systems, partner airlines that will provide you services during connecting flights, 

• Group companies, e.g. certain services offered by THY are carried out by our affiliates, within this context, your personal data may be shared with our relevant affiliates.

• Suppliers; e.g. software companies that we procure technical services, cloud service providers, security firms, transportation service providers.

• Foreign countries that the transportation is carried out to and private and public institutions authorized by national or international legislations; e.g. in accordance with national and/or international civil aviation legislation and regulations, the relevant authorities and authorised third parties of the country where your travel takes place from or over its airspace, to enforcement agencies, executive or judicial bodies in relation to ongoing investigations, to United States National Security Council etc. either when travelling to United States of America or when using the airspace of the United States of America.

Notification About Commercial Electronic Messages

Your personal data may be processed in order to provide information about our services, to promote our goods and services and to inform you about our campaigns in accordance with the Regulation of Regulation on Commercial Communication and Commercial Electronic Messages Numbered 6563. In accordance with the relevant legislation, your commercial electronic mail permissions must be recorded in the Message Management System (IYS), and within this scope, the contact address (phone number or e-mail address), permission date, communication channel, recipient type and permission source data will be shared with the IYS. You can visit https://iys.org.tr for detailed information about IYS.

What are Your Rights as Data Subjects?  

As data subjects, you are entitled to a number of rights under Article 11 of the Law in relation to your personal data. We would like to inform you about the rights that you are entitled to and the ways you may use them. 

The rights you have under the Article 11 of the Law are as follows:

• Learn whether data relating you are being processed, 
• Request further information if personal data relating to you have been processed, 
• Learn the purpose for the processing of personal data and whether data are being processed in compliance with such purpose, 
• Learn the third-party recipients to whom the data are disclosed within the country or abroad, 
• Request rectification of the processed personal data which is incomplete or inaccurate and request such process to be notified to third persons to whom personal data is transferred, 
• Request deletion or destruction of personal data in the event that the data is no longer necessary in relation to the purpose for which the personal data was collected, despite being processed in line with the Law and other applicable laws and request such process to be notified to third persons to whom personal data is transferred, 
• Object to negative consequences that you experienced as a result of analysis of the processed personal data by solely automatic means, 
• Demand compensation for the damages that you have suffered as a result of an unlawful processing operation. 

You can easily use your rights mentioned above and easily communicate the related requests to us via contact information below. We will respond you in the shortest time possible, based on the nature of your request and within 30 days at the latest. As a general rule, responses to data subject requests are given free of charge; however, we reserve the right to charge you according to the tariff to be determined by the Personal Data Protection Board in case the request requires additional costs. 

Contact Information   

Türk Hava Yolları Genel Yönetim Binası 

Atatürk Havalimanı, 

Yeşilköy, 34149 İstanbul 

00 90 212 463 63 63 

00 90 212 465 21 21 

https://www.turkishairlines.com/tr-tr/bilgi-edin/musteri-iliskileri/geribildirim/