Protection of Personal Data


Website Confidentiality Agreement



How to use and protect the information we obtain about you and the services you request while you visit this website and benefit from the services we provide through this site are subject to the conditions set forth in this “Privacy Policy”. By visiting this website and requesting to benefit from the services we offer through this website, you accept the terms set forth in this “Privacy Policy”.



I. Purpose of personal data protection and processing policy



Due to the sensitivity of the works we have been dealing with as Skyway Travel until today, the data received from our customers or prospective customers have been kept confidential and have never been shared with third parties. Protection of personal data is the basic policy of our company. Even before there was any legal regulation, our companies and affiliates attached great importance to the privacy of personal data and adopted this as a working principle, and gave their employees working instructions in line with this principle. As Skyway Travel, we undertake to comply with all responsibilities brought by the Law on the Protection of Personal Data. Our company’s principles regarding the protection of personal data also cover our affiliates.



II. Scope and modification of the personal data protection and processing policy



This Policy, prepared by our company, has been prepared in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”). The law has entered into force with all its provisions as of today. The data obtained from you with your consent or in accordance with other laws listed in the Law will be used to improve the quality of the services we provide, improve the services offered to you, and our quality policy. Again, some of the data we have is depersonalized and anonymized. These data are used for statistical purposes and are not subject to Law enforcement and our Policy. The Skyway Travel Personal Data Protection and Processing Policy aims to protect the automatically obtained data of our customers, prospective customers, employees, customers, and employees of companies working in solution partnership with us, or other persons and includes regulations regarding these.



Our company has the right to change our policy and our Regulations, provided that they comply with the law and that personal data is better protected.



III. Basic rules regarding the processing of personal data



a) Compliance with the law and the rules of honesty: Skyway Travel questions the source of the data it collects or receives from other companies and attaches importance to obtaining them in accordance with the law and honesty. In this context, it makes necessary warnings and notifications to third parties (agencies and other intermediary institutions) that sell the services offered by Skyway Travel in order to protect personal data.

b) Being accurate and up-to-date when necessary: ​​Skyway Travel attaches importance to the fact that all data within the institution are correct and do not contain false information, and finally, if there is a change in personal data, they are updated if they are communicated to it.

c) Processing for specific, clear, and legitimate purposes: Skyway Travel processes data only for the purposes it offers and for which it receives consent from individuals during the service. It does not process, use and make use of data other than for business purposes.

d) Being connected, limited, and measured for the purpose for which they are processed: Skyway Travel uses data only for the purpose for which they are processed and to the extent required by the service.

e) Retention for the period stipulated in the relevant legislation or required for the purpose for which they are processed: Skyway Travel retains the contractual data as long as the conflict periods of the Law and the requirements of commercial and tax law. However, when these purposes disappear, it deletes or anonymizes the data.



It should be noted that, whether Skyway Travel collects or processes the data with consent or in accordance with the law, these principles listed above still apply.



According to article 11 of the Personal Data Protection Law, you have the following rights. In order to facilitate these rights, an application form has also been prepared by Skyway Travel for you.



Persons whose personal data are processed, by applying to our contact announced on our website by Skyway Travel, regarding their own data;



a) Learning whether your personal data is processed or not,

b) If personal data has been processed, requesting information about it,

c) Learning the purpose of processing personal data and whether they are used in accordance with its purpose,

ç) To know the third parties to whom personal data is transferred in the country or abroad,

d) Requesting correction of personal data in case of incomplete or incorrect processing,

e) Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in the law,

f) Requesting notification of the transactions made pursuant to subparagraphs (d) and (e) to third parties to whom personal data has been transferred,

g) Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,

h) To request the compensation of the damage in case of loss due to unlawful processing of personal data,



has rights. As Skyway Travel, we respect these rights.



Maximum Savings Policy/Stinginess Policy



According to this policy, which is called the maximum savings policy or the stinginess policy, the data that reaches Skyway Travel is processed into the system only as necessary. Therefore, which data we collect is determined by the purpose. Unnecessary data is not collected. Other data transmitted to our company are transferred to company information systems in the same way. Redundant information is not recorded in the system, deleted, or anonymized. These data can be used for statistical purposes. Health data, which is one of the special quality data, is taken only in order to provide better service to customers and protect their health and is kept in the system with care.



Deletion of personal data



Personal data is deleted, destroyed, or anonymized by our company, automatically or upon the request of the person concerned, when the periods required to be kept by law, the completion of the judicial processes, or other requirements are eliminated.



Accuracy and data timeliness



As a rule, the data contained within Skyway Travel is processed as declared by the relevant persons. Skyway Travel does not have to investigate the accuracy of the data declared by customers or people who contact Skyway Travel, and this is not done legally and is due to our working principles. The declared data is considered correct. The principle of accuracy and timeliness of personal data has also been adopted by Skyway Travel. It updates the personal data that our company has processed from the official documents it receives or upon the request of the person concerned. It takes the necessary measures for this.



Privacy and data security



Personal data is confidential and Skyway Travel respects this confidentiality. Only authorized persons can access personal data within the company. All necessary technical and administrative measures are taken to protect the personal data collected by Skyway Travel and prevent it from falling into the hands of unauthorized persons and prevent our customers and prospective customers from being victims. In this framework, it is ensured that the software complies with the standards, that the third parties are carefully selected, and that the data protection policy is complied with within the company.



Additional health data may be requested or collected from our employees due to Covid-19 and epidemic diseases, and the collected data may be shared with the relevant official authorities.



IV. Data processing purposes



Skyway Travel’s collection and processing of personal data will be carried out for the purposes specified in the clarification text. Data is collected and processed for the purpose of establishing the contract and providing better service to customers.



V. Customer, prospective customer, and business and solution partners’ data



Collection and processing of data for the contractual relationship



If a contractual relationship is established with our customers and prospective customers, the collected personal data can be used without the customer’s consent. However, this use takes place in line with the purpose of the contract. The data is used to the extent of better execution of the contract and the requirements of the service and updated when necessary by contacting the customers. On the other hand, the data left to us by our prospective customers (prospective customers) are processed in order to provide them with an easier and higher quality service afterward. If this data has not turned into a contractual relationship upon request, it will be deleted.



Business and Business Partners Data



Skyway Travel adopts the principle of acting in accordance with the law when sharing data with both business and solution partners. Data is shared with business and solution partners with the commitment of data confidentiality and only as much as the service requires, and these parties are compelled to take measures to ensure data security.



Advertising data processing



About Regulation of E-Commerce. About Commercial Communication and Commercial Electronic Messages by Law. In accordance with the regulation, e-mails for advertising purposes can only be sent to people with prior approval. The explicit consent of the person to whom the advertisement is sent is required. Again, Skyway Travel complies with the details of the “approval” determined in accordance with the same legislation. Personal data for sending electronic messages About Commercial Electronic Messages. In accordance with the regulation, it is transferred to Message Management System Inc.



Data transactions made due to the legal obligation of the company or expressly stipulated in the law



Personal data may be processed without obtaining separate approval for the purpose of expressly stating the processing in the relevant legislation or fulfilling a legal obligation determined by the legislation. The type and scope of data processing must be necessary for the legally permitted data processing and must comply with the relevant legal provisions.



Company data processing



Personal data may be processed in line with the service offered by the company and its legitimate purposes. However, the data cannot be used for illegal services in any way.



Processing of special data



According to the Law, data related to the race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and dress, membership to associations, foundations or trade unions, health, sexual life, criminal convictions, and security measures, and biometric and genetic data is personal data of special nature. Skyway Travel also takes adequate measures determined by the Board in the processing of sensitive personal data.



Skyway Travel can only process sensitive data for the purpose for which they were collected, with the consent of individuals, in order to provide better services. The facility you have booked through us may request some personal data from the guests, including special personal data such as health data of themselves and their relatives, in accordance with the circular and legal regulations within the scope of Covid-19. This personal data can be shared with official authorities and health institutions when necessary.



Data obtained through membership transactions



If you are a member of Skyway Travel, the personal data that you share with us for the membership process is processed in our systems. If you become a member of our system with Facebook, Google, or other social media tools; Information provided to the partners of the relevant social media tool, such as your name, surname, profile picture, and e-mail address, is accessed and this information is transferred to Skyway Travel systems.



Data processed by automated systems



Skyway Travel acts in accordance with the law regarding data processed through automatic systems. The information obtained from these data cannot be used against the person without the explicit consent of the people. However, Skyway Travel can make decisions about the people it will process using the data in its own system.



Cookie Policy



As with many websites, Skyway Travel uses cookies, etc., in order to improve the visiting experience of website users and increase service quality. uses technologies. The Skyway Travel Cookie Policy has been prepared to inform website users about cookies and the types of cookies used, and to guide them on how to manage their cookie preferences.



If you do not approve of the use of cookies, we ask you not to continue with the website or to change your cookie preferences as shown in this Policy. We would like to remind you that some features of the website may lose their functionality if cookies are not allowed.



What is a cookie?



Cookies are small text files that are stored on your computer or mobile device when you visit a website. These files contain your IP address, login information, pages you access, etc. data is stored. Thanks to cookies, your website preferences can be remembered, your session can be kept open, or you can be presented with the content you are interested in. For detailed information about cookies, you can visit www.aboutcookies.org and www.allaboutcookies.org.



Types of Cookies



Cookies are divided into different types according to criteria such as their storage time on mobile devices and by whom they are placed. The basic distinction within the scope of these criteria is as follows:



Session Cookies: Session cookies are temporary cookies and are deleted from the device after closing the browser. The main function of these cookies is to ensure that the website functions properly.



Persistent Cookies: Persistent cookies remain on the device even after closing the browser until they are deleted by the user or expired.



First-Party Cookies: First-party cookies are cookies placed on the device by the website operator visited.



Third-Party Cookies: Third-party cookies are cookies placed on the device and controlled by people other than the website operator visited.



In the case of the collection, processing, and use of personal data on the websites and other systems or applications of Skyway Travel, the relevant persons are informed about the privacy statement and, if necessary, about the cookies. People are informed about our practices on web pages. Personal data will be processed in accordance with the law.



When you visit our website, we present the following information to your attention regarding the cookies we use/will use on our page.



Cookies Used on the Skyway Travel Website



Skyway Travel uses different types of cookies in accordance with its Privacy Policy.



Mandatory Cookies: These are technical cookies that enable the website to function correctly and allow you to use its features. They are in the session cookie category. If these cookies are blocked, it will result in the inability to use the website features. Your consent is not required for the use of mandatory cookies.



Analytical Cookies: Analytical cookies are used to improve your website experience. Analytical cookies allow us to understand how you use the website (eg which pages you visit, duration of visit, etc.). In this way, we can improve the content we offer or change the website design.



Functionality Cookies: When you visit the website again, your language preferences, region selection, etc. allow it to be remembered.



Targeting/Advertising Cookies: Different first-party and third-party cookies are used for targeting and advertising purposes on the Skyway Travel website. It is possible to block these cookies by changing your browser settings or by changing your cookie preferences as shown in this Policy.



How Can You Change Your Cookie Preferences?



It is possible to personalize or completely block cookies by changing the settings of the browser you use. You can find detailed information on the steps to be followed for different browsers from the links below:



To manage cookie preferences in other browsers, you can review the help or support page of the relevant browser.



Domestic and International Transfer of Personal Data



Your personal data is shared with hotels located abroad, airlines, suppliers providing transfer services, and the relevant foreign agency in order to complete your reservation and provide the service to you. Your personal data may also be shared with other electronic platforms in the country and abroad so that you can search, make reservations and stay in hotels that do not have a contract with Etstur.com for the realization of your trip.



Your Rights Regarding Your Personal Data



By applying to Skyway Travel as a data owner;



• Learning whether your personal data is processed or not,



• If your personal data has been processed, requesting information about it,



• To learn the purpose of processing your personal data and whether they are used in accordance with the purpose,



• Knowing the third parties to whom your personal data is transferred, in the country or abroad,



• Requesting correction of your personal data in case of incomplete or incorrect processing and requesting notification of the transactions made within this scope to the third parties to whom your personal data has been transferred,



• Requesting the deletion or destruction of your personal data in the event that the reasons requiring it to be processed disappear, although it has been processed in accordance with the provisions of the Law No. 6698 and other relevant laws, and to notify the third parties to whom your personal data has been transferred,



• Objecting to the emergence of a result against you by analyzing your processed data exclusively through automated systems,



• You have the right to demand compensation for the damage in case you suffer damage due to the unlawful processing of your personal data.



If you submit your requests regarding your rights listed above to our Company in accordance with the application procedures set forth in the Communiqué on Application Procedures and Principles to the Data Controller, Skyway Travel will conclude your request free of charge as soon as possible, depending on its nature, and within 15 (fifteen) days at the latest. However, if the process requires an additional cost, Skyway Travel may charge the fee in the tariff determined by the Personal Data Protection Board.



Functional and Analytical



Cookies contain data about remembering your preferences, using the website effectively, optimizing the site to respond to user requests, and how visitors use the site. Due to their nature, these types of cookies do not contain usernames, etc. may contain your personal information.



Third-Party Cookies



Skyway Travel websites/mobile applications/mobile websites work with third-party reliable, well-known advertising providers. Third-party service providers place their own cookies in order to serve you specific advertisements. Cookies placed by third parties collect and process the browsing information of visitors on websites and analyze how they are used.



Commercial cookies



In line with your interests and choices, it serves to increase your user experience by presenting products/content that are similar to the product/content you are targeting and by offering a more advanced, personalized advertising portfolio. In the above-mentioned session, permanent, functional and analytical, and commercial cookies are kept in the background for approximately 2 (two) months, and the necessary adjustments can be made in the personal internet browser settings. The removal process from these settings may vary based on the internet browser.



How can I delete cookies?



Many internet browsers are set to automatically accept and use cookies from the time they are first installed on your computer. By using the help or settings menus of your internet browser, you can prevent cookies or give a warning when cookies are sent to your device. You can use your browser’s instruction or help options screen to learn about the different ways to manage cookies and to get detailed information on how to adjust the settings of the browser you are using.



VI. Data of our employees



Processing of data for business relationship



Personal data of our employees can be processed without consent to the extent necessary in terms of business relations and health insurance. However, Skyway Travel ensures the confidentiality and protection of the data of its employees.



Processing by Legal Obligations



Skyway Travel may process the personal data of its employees without obtaining separate approval for the purpose of expressly stating the processing in the relevant legislation or fulfilling a legal obligation determined by the legislation. This issue is limited to the obligations arising from the law.



Processing for the Benefit of Employees



Skyway Travel may process personal data without obtaining consent for transactions in the interest of company employees, such as private health insurance. For disputes arising from business relations, Skyway Travel may also process employee data.



Processing of special data



According to the Law, data related to the race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and dress, membership to associations, foundations or trade unions, health, sexual life, criminal convictions, and security measures, and biometric and genetic data is personal data of special nature. Skyway Travel also takes adequate measures determined by the Board, in addition to the consent of the person concerned, in the processing of sensitive personal data. Special categories of personal data can only be processed without the consent of the person, only in relation to the cases permitted by the Law, and in a limited manner. In order for our employees to benefit from insurance and health services, the qualified data obtained from them is used only for the purpose.



Data processed by automated systems



Data processed by automated systems regarding employees can be used in internal promotions and performance evaluations. Our employees have the right to object to the result against them, and they do so by following internal procedures. The objections of the employees are also evaluated within the company.



Telecommunications and internet



Computers, telephones, e-mails, and other applications allocated to employees within the company are allocated to employees for business purposes only. The employee cannot use any of these means allocated to him by the company for his private purposes and communication. The company can control and audit all data on these vehicles. The employee undertakes that he/she will not keep any other data or information other than work on the computer, phones, or other tools allocated to him from the moment he/she starts the job.



VII. Transfer of personal data in and out of the country



Personal data may be shared with business and solution partners for Skyway Travel to see the service.



Skyway Travel will be able to transfer personal data to the following persons and institutions for certain purposes;



» Limited to the business partners of Skyway Travel in order to ensure the fulfillment of the purposes of the establishment of the business partnership,



» Solution partners of Skyway Travel limited to ensuring the execution of commercial activities of our company that require the participation of affiliates,



» To the affiliates of Skyway Travel.



Skyway Travel has the authority to transfer personal data within the scope of the conditions determined by the Board in the law, in accordance with the other conditions in the Law, and subject to the approval of the person, within the country and abroad.



VIII. Rights of the person concerned



Skyway Travel accepts that within the scope of the Law, the data subject has the right to obtain consent before the data is processed and that it has the right to determine the fate of the data after the data is processed.



Regarding personal data, by applying to our relevant person announced on our website by Skyway Travel;



a) Learning whether their personal data is processed or not,

b) If personal data has been processed, requesting information about it,

c) Learning the purpose of processing personal data and whether they are used in accordance with its purpose,

ç) To know the third parties to whom personal data is transferred in the country or abroad,

d) Requesting correction of personal data in case of incomplete or incorrect processing,

e) Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7,

f) Requesting notification of the transactions made pursuant to subparagraphs (d) and (e) to third parties to whom personal data has been transferred,

g) Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,

h) In case of loss due to unlawful processing of personal data, it has the right to demand compensation for the damage.



However, individuals do not have a right to anonymized data within the Company. Skyway Travel may share personal data with relevant institutions and organizations in order to exercise the legal powers of a judicial duty or state authority in accordance with the business and contractual relationship.



IX. Privacy Policy



Whether employees’ or other people’s data in Skyway Travel is confidential. No one can use, copy, reproduce, transfer to others, or use this data for any other purpose without compliance with the contract or the law.



X. Transaction security



All necessary technical and administrative measures are taken to protect the personal data collected by Skyway Travel and prevent it from falling into the hands of unauthorized persons and prevent our customers and prospective customers from being victims. In this framework, it is ensured that the software complies with the standards, that the third parties are carefully selected, and that the data protection policy is complied with within the company. Safety measures are constantly being renewed and improved.



XI. Audit



Skyway Travel carries out the necessary internal and external audits on the protection of personal data.



XII. Notice of Violations When Skyway Travel is notified of any breach of personal data, it takes immediate action to remedy the breach. It minimizes the harm to the person concerned and compensates for the damage. When personal data is obtained by unauthorized persons, it immediately notifies the Personal Data Protection Board.