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GENERAL CLARIFICATION TEXT ON PROCESSING OF PERSONAL DATA

As AIR ANKA HAVA YOLLARI ANONİM ŞİRKETİ (Air Anka or Company) we place great importance on confidentiality and security of your personal data, and we make all necessary efforts to process and store data belonging to people related to our company in accord with the Personal Data Protection Law ("PDP Law") numbered 6698.
In this scope, our company, in the capacity of Data Controller, processes your personal data in accord with the PDP Law and the terms and conditions detailed below, in scope of the limits specified under the applicable legislations.
1.    Identity of the Data Controller
PDP Law, Article 3, Paragraph 1, Sub-paragraph (ı) defines data controller as "Real or legal bodies who determine the purposes and means of processing of personal data and who are responsible for establishing and managing the data recording system." In this scope, the data controller is AIR ANKA HAVA YOLLARI ANONİM ŞİRKETİ. Contact information of our company is as follows:
AIR ANKA HAVA YOLLARI ANONİM ŞİRKETİ 
Address: 09 Eylül Mah. Akçay Cad. 289/14 35040 Gaziemir / İZMİR
Branch Office: Kazımdirik Mah. 296 Sokak No:8 Folkart Time B-1 Girişi K:9 D:914 Bornova / İZMİR
   Tel:  +90 232 247 26 52

2.    Purposes of Processing of Your Personal Data
Your personal data is processed in accord with the general principles specified under Article 4 of the PDP Law and the data processing conditions specified under Articles 5 and 6 of the same, for the following purposes;
•    To plan and implement human resources management and policies;
•    To plan and/or implement application, selection and evaluation processes for employee candidates;
•    To promote goods and service offered by the Company on written and visual media, to implement loyalty card membership services, and to conduct corporate/product-oriented image studies;
•    To provide and develop better and higher quality services for our clients;
•    To fulfil online product sale processes in accord with the contract provisions;
•    To manage member-specific promotion / advertisement / campaign / raffle and announcement activities, and to implement customer satisfaction activities and information drives including surveys, etc. in order to increase quality in customer relations management;
•    To manage support services activities in order to evaluate after-sales client demands regarding products including damages, replacement, returns, suggestions, etc.;
•    To conduct market research in regard of sales and/or marketing of products and services;
•    Planning and/or implementation of the processes for providing the clients with the tools and/or information suitable for the channels they use to access and/or use the products and/or services;
•    Planning and/or implementation of supply chain management processes;
•    Planning and/or management of data analysis, research, statistical study, trend analysis and advertisement activities in order to manage product and/or service marketing processes;
•    Planning and management of commercial partnerships and strategies;
•    To ensure legal, commercial and physical security of our company and our business partners;
•    To ensure physical space security of our stores and main offices in scope of the legitimate interests of our company;
•    To ensure corporate function of the company, and to conduct and manage finance and/or accounting activities;
•    To take necessary measures to ensure compliance with standards in regard of occupational health and safety matters and to improve such compliance;
•    To ensure utmost level of data security and to establish databases;
•    To provide and develop services like membership, etc. provided at the website of the company (www.airanka.com.tr);
•    To follow up on requests and complaints of relevant parties, and to provide feedback to relevant parties;
•    To rectify errors discovered on the website of the company and to ensure compliance with the Confidentiality Policy of the Company as announced of the site.

3.    The Allowed Recipients and Purposes of Transmission of Processes Personal Data
In scope of the purposes detailed above and in accord with the personal data processing conditions specified under Articles 8 and 9 of the PDP Law, your personal data may be transmitted to;
•    Business partners, consulting firms, suppliers, private establishments and organisations, and public establishments and institutions to the extent required to fulfil legal obligations and commercial activities of the company;
•    Relevant suppliers for evaluation of customer demands in case any fault is claimed in any product sold in our stores;
•    Relevant banks for payment and collection transactions required in scope of execution and performance of contracts subject to processing of your personal data;
•    Courts and other public establishments and institutions requesting information to the extent required for fulfilment of legal obligations of the company;
•    Law firms and other consultants to the extent required for provision of legal support for establishment, utilisation and protection of the rights of the company; and
•    Archiving firms or cloud service providers in order to ensure data security.
All necessary technical and administrative precautions are taken to ensure data security during and after transmission of our your personal data.

4.    Method and Legal Grounds of Personal Data  Collection
In accord with Articles 4, 5 and 6 of the PDP Law numbered 6698, your personal data is collected;
•    In compliance with the law and rules of honesty;
•    Accurately and as current as needed;
•    For specific, clear and legitimate purposes;
•    In relation to, limited to and proportionate to purpose of processing; and
•    To be stored only for the period of time specified under the relevant regulations or required for the purpose of processing.

Your personal data may be collected by means of automated or non-automated methods and various channels, through offices, call centres, internet sites, social media platforms, mobile applications and other similar means, in physical environment, in electronic environment or through closed-circuit video systems and through other legal means and methods. In addition, the collected personal data may also vary according to the service, product or commercial activity provided by the company.
Your personal data is processes based on the following legal grounds as specified under (Article 5 of) the PDP Law numbered 6698; 
•    Presence of explicit consent of the data owner as specified under Article 5, Paragraph 1 of the Law;
•    Explicit allowance of personal data collection under the legislations the company is subject to, particularly the Turkish Commercial Code and the Tax Procedural Law, based on the legal grounds of "explicit allowance under the law" as specified under Subparagraph 5/2 (a) of the Law;
•    Physical impossibility as specified under Subparagraph 5/2(b) of the Law;
•    Requirement of collection of personal data for fulfilment or maintenance of relevant contractual obligations, opening of current balance accounts, and performance of payment and collection transactions, on the legal grounds of "establishment or performance of a contract" as specified under Subparagraph 5/2 (c) of the Law;
•    Requirement of collection of personal data for preparation of official declarations or statements, compliance with data retention time requirements under the legislations the Company is subject to, fulfilment of other obligations under applicable legislations, compliance with information requests from courts and other authorised public establishments and institutions and fulfilment of other legal obligations, based on the legal grounds of "fulfilment of legal obligations of the data controller" as specified under Subparagraph 5/2 (ç) of the Law;
•    Based on the legal grounds of "public disclosure by the data owner" as specified under Subparagraph 5/2 (e) of the Law;
•    Personal data constituting evidence in potential disputes involving the Company and requirement of legal consulting and technical support in this regard, based on the legal grounds of "establishment, utilisation or protection of a right" as specified under Subparagraph 5/2 (e) of the Law; and
•    Processing of personal data for legitimate interests of the Company based on the legal grounds specified under Subparagraph 5/2 (f) of the Law.
Your private personal data may be processed for the purposes detailed under this Clarification Text based on the following legal grounds specified under Article 6 of the PDP Law;
•    Explicit Consent (Article 6/2);
•    Allowance under laws (Article 6/3: For private personal data excluding subjects of health and sex life);
•    Processing of data on subjects of health and sex life for purposes of medical diagnostics, treatment and care services, preventative medicine, protection of public health, and planning and management of health services and financing (Article 6/3).
Personal data collected on basis of the legal grounds detailed above will be processed and transmitted only for the purposes specified under this Clarification Text and only the to the extent of personal data processing conditions and purposes specified under Articles 5 and 6 of the PDP Law.

5.    Rights of the Personal Data Owner
Any demand regarding your rights as the personal data owner notified to the Company by the means detailed under the following clause of this Clarification Text will be resolved in thirty days at the latest according to the nature of the request. However, in case the procedure necessitates any additional cost, the company will have the right to claim a fee according to the tariff determined by the Personal Data Protection Board. 
In accord with Article 11 of the PDP Law, the personal data owner has the following rights;
•    To learn whether the personal data is processed;
•    To demand information on any personal data which is processed;
•    To learn the purpose of processing of the personal data and whether such processed personal data is used in compliance with its purpose;
•    To learn domestic or foreign third parties who receive transmission of the personal data;
•    To demand correction on any personal data which is processed incomplete or erroneously and to demand notification of actions taken to this extent to third parties who receive transmission of said personal data;
•    To demand deletion or disposal of personal data in case the reasons necessitating processing of data have ceased to exist despite the data being processed in accord with law, and to demand notification of actions taken to this extent to third parties who receive transmission of said personal data;
•    To protest against any result that might arise against favour of the data owner due to analysis of the processed data solely by automated systems;
•    To claim damages in case the data owner is exposed to any damage due to unlawful processing of the data.

6.    Application Process and Right to Information
In case you have any concern regarding your personal data, please apply to AIR ANKA HAVA YOLLARI ANONİM ŞİRKETİ using the address and contact information provided on our website.
In accord with Article 13, Paragraph 1 of the PDP Law you can send your demands regarding your rights specified under Article 11 of the same in print or to the email address [[email protected]] from a registered electronic mail (KEP) address or the electronic mail address you have previously reported to the company or registered in our system. 
Your application must include information and documentation regarding;
•    Your name and surname, and your signature if your application is drawn in print;
•    Your Republic of Turkey Identification Number for Turkish citizens or your passport number or national identification number for foreign nationals;
•    Your residence address or business address for official notification;
•    Your electronic mail address, phone number and fax number, if any, for official notification; and
•    Subject of your demand.
The Company will resolve your demands in this scope as soon as possible and in thirty days at the latest, according to nature of the demand. However, in case the procedure necessitates any additional cost, the company may claim a fee according to the tariff determined by the Personal Data Protection Board. In addition, your applications will only be answered to the extent related to your person, and any application related to your partner, your relatives or your acquaintances will not be accepted. 

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