Data Protection
The Purpose and Legal Basis for the Processing of Your Personal Data, and Your Related Rights
As Dm Seyahat Turizm Ticaret Ltd. Şti. (“Company”), we aim to provide better service to our users and, in accordance with the Law on the Protection of Personal Data No. 6698 (“Law”), as well as the Law No. 6493 on Payment and Securities Settlement Systems, Payment Services, and Electronic Money Institutions, the Law No. 5651 on the Regulation of Publications Made on the Internet and the Fight Against Crimes Committed Through Such Publications, the Law No. 6563 on the Regulation of Electronic Commerce, and other relevant legislation; we collect and process your personal data in accordance with the aforementioned laws to fulfill the purposes and legal obligations outlined below. As has been the case to date, these personal data will continue to be processed—subject to your explicit consent or the exceptions provided for by the Law—in accordance with the purposes and scope determined by our Company, with appropriate information security measures in place, and will be retained for the periods prescribed by the Law.
Detailed information regarding the purposes for which our Company processes your personal data and the purposes for which it is transferred to individuals located within or outside the country is provided below.
Reservation User Data (“User Data”)
| Personal Data | Purpose of Data Processing | Legal Basis | Status and Purpose of Domestic/International Data Transfers |
| Financial Information (Bank Account Information) Identification Information (Turkish ID Number, First Name and Last Name) | Processing the return | The conclusion and performance of the contract; the necessity of processing personal data belonging to the parties to the contract; the data controller’s legal obligation; the establishment, exercise, or defense of a legal claim | Certified Public Accountant – Provision of financial advisory servicesIndependent Auditor – Conduct of audit activities |
| Identification Information (Turkish ID Number, First Name and Last Name)Contact Information (Phone Number, Email Address)Customer Transaction Information (Payment Information, IP Address)Visual and Audio Information (Audio Recording) | Fraud control; review and resolution of dispute claims, requests from the prosecutor’s office, and consumer arbitration board requests | The data controller’s legal obligationEstablishment, exercise, or protection of a rightLegitimate interest | Consultants – Resolution of legal disputesBusiness Partner – Evaluation of the transaction by POS Bank and provision of call center servicesAuthorized Public Institutions and Organizations – Legal notification obligations |
| Contact Information (Phone Number) Identification Information (Last 5 Digits of Turkish ID Number, First Name and Last Name) | Feeding data into fraud prevention/monitoring systems and processes; Verifying phone numbers in cases of fraud | Explicit Consent | – |
| Financial Information (Bank Account Information)Contact Information (Phone, Email)Identification Information (First Name, Last Name) | Review of requests for expenditure objections | The data controller’s legal obligation: The establishment, exercise, or protection of a right | Business Partner – Review of the dispute by POS Bank |
| Contact Information (Phone, Email)Identification Information (First Name, Last Name) | Internal Unit Audit | The establishment, exercise, or protection of a right | – |
| Location Data (IP)Customer Transaction Information (Transaction History)Identification Information (National ID Number, First Name and Last Name)Contact Information (Phone Number, Email Address, Address) | Ensuring transaction security | Establishment, exercise, or protection of a right; Legitimate interest | Authorized Public Institutions and Organizations – Legal obligation to provide notice (Address information is not disclosed) |
Our company transfers the personal data it collects, within the scope of the data processing purposes listed above, subject to compliance with the conditions set forth in Articles 8 and 9 of the Law and the implementation of necessary security measures, and solely for the purposes specified in the table above.
Your personal data is collected electronically and processed for the purposes listed here.
As the data subject, you may contact our Company, which acts as the Data Controller, at any time In Article 11 of the Law You may exercise your rights as specified.
In order to exercise your rights as set forth in the law, please submit a handwritten, signed petition clearly stating which rights you wish to exercise, or the form you can download by clicking here You may submit the information provided in the form along with documents verifying your identity. Our company will respond to written requests from data subjects containing the above-mentioned requests within 30 (thirty) days.
Applications will be free of charge unless the Personal Data Protection Board issues a decision to publish a fee schedule. If the response to an application exceeds 10 (ten) pages, a processing fee of 1.00 (one) TL will be charged per page. If the response is requested to be provided on a storage medium such as a CD or flash drive, a fee will be charged based on the cost of the requested storage medium.
If you are acting on behalf of another person regarding the matter in question, you must have specific authorization for this purpose, which must be documented; the application must include the individual’s identification and address information; and documents verifying your identity must be attached to the application.