Personal Data Protection Law
We take the protection of your İnternasyonel personal data seriously. In this personal data protection notice;
(i) in the use of our website (see Section 2.1),
(ii) if tickets are purchased by us (see Section 2.2)
You will be informed about which of your personal data will be processed.
1. Data Controller
Below, we, as the Data Controller (GDPR Article 4(7), KVKK Article 3(1)(ı)),
İnternasyonel (Talatpaşa Mah. Yaşarlı Cad. No: 26/A Kağıthane / İSTANBUL)
(hereinafter referred to as “İnternasyonel,” ‘we’), we will inform you about the processing of your personal data (GDPR Article 4(2), KVKK Article 3(1)(e)) in connection with the use of our website https://internasyonel.com.tr/ (“website”) as well as the sale of our products and services.
If you need more information about the processing of your personal data in connection with the use of our website and the sale of our products and services, please contact us:
Your privacy is as important to us as it is to İnternasyonel. For this reason, we aim to inform you about İnternasyonel’spurposes for processing your data, the manner in which it is processed, and to whom it is transferred. The personal data you share with İnternasyonel via our website and other electronic communication and sales channels will be processed in accordance with this information.
2. Scope, Purpose, and Legal Basis of Personal Data Processing
Your personal data is processed in accordance with the Personal Data Protection Law No. 6698 (“KVKK”), the European Union General Data Protection Regulation (Reg. EU 2016/679) (“GDPR”) and, where applicable, German laws (in particular BDSG 2018) (“Data Protection Legislation”).
We collect and use personal data directly from our users or from other sources (as specified below) in the following circumstances:
2.1. Our Website
2.1.1. Displaying the Website and Creating Log Files
As a user, every time you access our website, our system automatically collects and records data and information from your computer system. In this context, the following data (“technical information”) is collected:
(1) Information about browser type and version,
(2) The user’s operating system,
(3) The user’s internet service provider,
(4) The user’s IP address,
(5) Date and time of access,
(6) Websites that the user’s system accesses to reach our website,
(7) Websites accessed by the user through our website.
The data is also recorded in our system’s log files. This data is not stored together with the user’s other personal data.
In this context, we collect and use this technical information for network security (e.g., to combat cyber attacks), marketing, to better understand our users’ needs, to continuously improve our website, and to ensure that the website is displayed on the user’s computer.
The purpose of storing log files is to ensure the functionality of the website. We also use the data to optimize the website and ensure the security of our information technology systems. In this context, the data is not analyzed for any marketing purposes.
The legal basis for the temporary storage of data and log files is GDPR Article 6(1)(f).
2.1.2. Use of Cookies
Cookies are used on our website. Cookies are text files stored in the web browser or in the web browser on the user’s computer system. When a user accesses a website, a cookie may be stored on the user’s operating system. This cookie contains a specific character string that enables the browser to be identified when the website is accessed again.
Cookies are stored on the user’s computer where they are sent to us. As a user, you have full control over the use of cookies. You can disable or restrict the transmission of cookies by changing your web browser settings. You can delete previously stored cookies at any time. This process may occur automatically. If cookies are disabled for our website, it may no longer be possible to use all of the website’s features.
For more information about the cookies we use, their purposes, and their legal basis, please see our Cookie Policy.
2.1.3. Use of Services Offered on Our Websites
We offer various services and applications on our website. The collection and processing of our users’ or customers’ personal data is necessary to provide the aforementioned services.
We may use your İnternasyonel personal data for the following purposes:
• Support provided to you throughout the transactions you perform on our website via Live Chat,
• Sending you newsletters (see Section 2.1.4) and commercial messages via the communication channels you have selected,
• Contacting you via your chosen communication channels regarding market research and customer satisfaction studies, analyzing the results of these studies and research, and using them for statistical purposes.
• Sending mail, newsletters, and personalized offers related to the Loyalty Program, which may be conducted from time to time.
• To enable us to provide our products and services in accordance with our contractual obligations or legitimate interests, and to fulfill our obligations arising from public and flight safety regulations or airline regulations in the countries where the travel takes place, your personal data may be transferred abroad in compliance with the KVKK.
• Providing you with personalized offers, including the personalized use of the website and profiling,
• Providing you with support regarding the use of the website, including its reminder features,
Pursuant to GDPR Article 6(1)(a) and KVKK Article 5(1), based on the explicit consent you have provided;
• Providing you with the requested quotes and services,
• Managing the Loyalty Program, which may be implemented from time to time,
• Ensuring that Loyalty Program members can set up and effectively manage their accounts, which can be run from time to time.
• Rewarding Loyalty Program members with free flights, BonusPoints, flights paid for with BonusPoints, and extra İnternasyonel services from time to time.
Under Article 6(1)(b) of the GDPR and Article 5(2)(c) of the KVKK, within the scope of a contractual obligation;
• Provide special flight and service offers,
• Creating, listing, reporting, verifying, analyzing, and evaluating databases; generating statistical information,
• To analyze how you use our website and other communication and sales channels, to tailor communication channels to your specific needs in order to provide better service, and to communicate with you through the communication channels you share with us directly or through service providers.
• To research and develop our products and services and your personal preferences related to them, to promote our services or related products, to engage in commercial communication for promotional purposes regarding new products, to provide special flight offers, advantageous flight change offers, and other information you may find interesting,
• Ensuring flight safety and security, protecting the life or property of İnternasyonel employees, İnternasyonel service providers and their employees, or İnternasyonel guests,
• Preventing fraud/scams, conducting internal audits, managing legal and other claims, and ensuring security,
Pursuant to GDPR Article 6(1)(f) and KVKK Article 5(2)(f), within the scope of our legitimate interest;
• Compliance with legal obligations, including adherence to the rules applicable to İnternasyonel, or the performance of a task in the public interest, or compliance with an order from an official authority,
In accordance with GDPR Article 6(1)(c), KVKK Article 5(2)(a), and Article 5(2)(ç), within the scope of fulfilling a legal obligation.
For the purposes mentioned above, we may collect the following types of data from you:
• Your first name, last name, occupation, address, telephone and fax numbers, email address, and other contact information,
• Identity and passport information,
• Ticket and flight reservation details,
• Information about invoices and payment methods,
• Your product order information,
• Your personal interests,
• Information you have provided to us regarding your requests and complaints about our products and services,
• Information about your use of our website and other communication channels,
• Your preferences or past choices regarding products or services.
2.1.4. Newsletter
You can subscribe to our free newsletter via our website. To do so, we collect and process the email address you provide on the webpage. Additionally, the following data is collected during the subscription process:
(1) The IP address of the computer requesting the newsletter
(2) Membership date and time
During the subscription registration process, your consent will be obtained for the processing of your data, and reference will be made to this information notice.
If you enter your email address on our website to receive our newsletter, your email address may be used to send you the newsletter. In this case, our newsletter will contain direct advertisements for the products and services of İnternasyonel Travel and its affiliates and business partners.
In connection with data processing for sending the newsletter, no data will be transmitted to third parties. Data will only be used for the purpose of sending the newsletter.
After subscribing to the newsletter with the user’s consent, the legal basis for processing the data is GDPR Article 6(1)(a) and KVKK Article 5(1).
2.2. Data Processing for Ticket Sales
When you purchase a flight ticket from us (either through our website or through one of our partner agencies), we process your personal data for the following purposes:
• Better fulfillment of travel needs,
Under Article 6(1)(b) of the GDPR and Article 5(2)(c) of the KVKK, within the scope of a contractual obligation;
• In addition, the purposes specified in Section 2.1.3 above,
Pursuant to GDPR Article 6(1)(f) and KVKK Article 5(2)(f), within the scope of our legitimate interest.
For the purposes mentioned above, we may collect the following types of data from you:
• Your first name, last name, occupation, address, phone and fax numbers, email address, and other contact information,
• Identity and passport information,
• Ticket and flight reservation details,
• Information about invoices and payment methods,
• Your product order information,
• Your personal interests,
• Information you have provided to us regarding your requests and complaints about our products and services,
• Information about your use of our website and other communication channels,
• Your preferences or past choices regarding products or services.
2.3. Our Legitimate Interest in Data Processing
Where Article 6(1)(f) of the GDPR constitutes the legal basis for data processing, our legitimate interests, separate from the purposes mentioned above, include the following:
• Protection of the company against material and immaterial damages
• Professionalization and development (of our products and services)
• Cost optimization (control and minimization)
2.4. Other Processing Bases
We may process your personal data due to legal obligations, for example, to comply with retention obligations under commercial or tax laws or to fulfill requirements under security laws. For more information about retention periods, please refer to the “Personal Data Processing Period” section.
2.5. Obligation to Specify Personal Data
The mandatory fields that must be filled out on our website are determined based on mandatory legal or contractual requirements. This ensures that the relevant contract or requested service can be fulfilled.
3. Personal Data Processing Period
Your personal data will be deleted when it is no longer needed for the purposes mentioned. Your personal data may need to be retained for the period during which legal proceedings may be initiated against İnternasyonel (statutory period). In addition, personal data will be retained to the extent and for the period that İnternasyonel is legally required to retain it. Documentation and retention obligations arise from local laws relating to trade, taxation, and money laundering. These retention periods can be up to 30 years.
4. Transfer of Personal Data to Third Parties
In order to provide our products and services in accordance with our contractual obligations or legitimate interests, and to fulfill obligations arising from public and flight safety regulations or airline regulations in the countries where the travel takes place, we may need to transfer your personal data to third parties within or outside the İnternasyonel. These recipients can be categorized as follows:
İnternasyonel partnerships
Service providers
Transportation
Marketing
Information Technologies
Payment Services
Credit Institutions
Customer Feedback Services
Official authorities
5. Your Rights as a Data Subject
Pursuant to the Personal Data Protection Law No. 6698, you have the following rights:
(a) To learn whether your personal data is being processed,
(b) If your personal data has been processed, you have the right to request information about this,
(c) To learn the purpose for which your personal data is processed and whether it is being used for that purpose,
(c) To know the third parties to whom your personal data has been transferred within or outside the country,
(d) Requesting the correction of your personal data if it has been processed incompletely or incorrectly,
(e) Request the deletion or anonymization of your personal data, provided that the reasons requiring the processing of your personal data no longer exist,
(f) Request that the third parties to whom your personal data has been transferred be notified of the actions specified in paragraphs (d) and (e),
(g) Object to a decision made solely through the automated processing of your personal data that adversely affects you,
(ğ) Requesting compensation for damages incurred as a result of the unlawful processing of your personal data.
You may submit your requests regarding the rights mentioned above in writing to the postal address listed in Section 1 above or by sending an email to [info@internasyonel.com.tr] using the email address you previously provided to İnternasyonel and which is registered in the İnternasyonel system.
In the application;
(a) Name, surname, and signature if the application is in writing,
(b) For citizens of the Republic of Turkey, their Turkish ID number; for foreigners, their nationality, passport number, or foreign ID number, if applicable.
(c) The address of the principal place of residence or business address for the purpose of service of process,
(d) If available, the email address, telephone number, and fax number to be used for notifications,
(e) The subject matter of the claim must be identified.
Your requests included in the application will be finalized as soon as possible and within 30 days at the latest, depending on the nature of the request. If a written response is provided to the application, a processing fee of 1 Turkish Lira may be charged for each page exceeding 10 pages. If the response to the application is provided on a recording medium such as a CD or flash drive, a fee equivalent to the cost of the recording medium may be charged.
If you do not receive a response to your application or if the response is insufficient, you may file a complaint with the Personal Data Protection Board (KVKK Articles 14 and 15).
Personal Data Protection Board
Address: Nasuh Akar Mah. Ziyabey Cad. 1407 Sok. No: 4 06520 Balgat-Çankaya/Ankara, Türkiye
Phone: +90 312 216 5050
Website : http://www.kvkk.gov.tr
6. Consent
If you consent to the processing of your personal data, we hereby inform you that you may withdraw this consent at any time.
If you have given your consent on this website, please visit the page where you gave your consent or log in to your registered account to withdraw your consent in the settings.
If you have consented to receive the newsletter, you can withdraw your consent by clicking the “Unsubscribe” link in the newsletter.
In all other cases, or if you encounter difficulties in withdrawing your consent on this website, please do not hesitate to contact us at [info@internasyonel.com.tr].
The withdrawal of your consent will only apply prospectively and will not affect the lawfulness of data processing carried out in the past. In some cases, we may continue to process your personal data based on a different legal basis, such as the performance of a contract, despite the withdrawal.
7. Information Regarding the Sending of Commercial Electronic Messages
Pursuant to Law No. 6563 on the Regulation of Electronic Commerce, regarding commercial electronic communications, you agree to receive commercial electronic communications about the promotion of products and services offered by İnternasyonel and its affiliates and business partners, new products and services, special flight offers, and other information related to your trip or that you may find interesting.
You can always change your communication preferences by following the links in the messages sent to you and stop the delivery of such messages through some or all communication channels.
8. Disclaimer and Privacy Notice
This Privacy Notice applies only to the “https://internasyonel.com.tr/” website. Other websites are not covered by this Privacy Notice and have their own privacy policies.
9. Additional Information Regarding Users Located Within the European Union
This section applies only when the services provided by İnternasyonel are used by persons located in European Union member states.
9.1. İnternasyonel Transfer of Personal Data
Personal data may be transferred to third countries or İnternasyonel organizations. To protect you and your personal data, such data transfers are subject to the condition that appropriate safeguards are in place in accordance with legal requirements (in particular the application of EU standard contractual clauses) or to an adequacy decision issued by the European Commission (GDPR Article 45).
For information on EU standard contract clauses, see [http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:039:0005:0018:EN:PDF]. The European Commission provides information on existing adequacy decisions at [https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en#dataprotectionincountriesoutsidetheeu].
You can request a copy of the security measures implemented at [info@internasyonel.com.tr].
Additionally, we have an obligation to provide personal data to German and İnternasyonel authorities (in accordance with local and İnternasyonel regulations and agreements, as well as GDPR Article 6(1)(c)).
9.2. Right to Object Pursuant to Article 21 of the GDPR
You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data, including profiling, based on Article 6(1)(e) or (f) of the GDPR.
The data controller may not process your personal data unless they can demonstrate compelling legitimate grounds for doing so that override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims.
When personal data is processed for direct marketing purposes, you always have the right to object to the processing of your personal data for marketing purposes, including profiling to the extent that it relates to such direct marketing.
If you object to the processing of your data for direct marketing purposes, your personal data will no longer be processed for such purposes.
In the context of using information society services and without prejudice to Directive 2002/58/EC, you may exercise your right to object using automated means based on technical specifications.
9.3. Your Rights as a Data Subject
Your rights under the European Union General Data Protection Regulation (Reg. EU 2016/679) and, where applicable, German law (in particular BDSG 2018) are as follows:
• Access rights
• Right to correction
• Right to erasure (“Right to be forgotten”)
• Right to restrict processing
• Right to data portability
• Right to object (see Section 9.2 above)
To exercise your rights, you can send an email to [info@internasyonel.com.tr]. Please note that we are required by law to process your personal data in order to fulfill your request and for identity verification purposes.
