Customer KVKK Disclosure Text

1. Introduction

As Hakan Hac and Umrah Organization Inc. (“Tebliğ Tourism”, “Company” or “We”), we are committed to ensuring the confidentiality of your personal data while delivering the products and services we offer to our guests and to processing your data with utmost care in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK” or “Law”) and secondary legislation.

We would like to inform you about the following matters in accordance with Article 10 of the KVKK as part of this Disclosure Text.

2. Identity of the Data Controller

According to the KVKK, the data controller is: Hakan Hac and Umrah Organization Inc.

Contact information is provided at the end of this document.

3. How Can We Obtain Your Personal Data?

As Tebliğ Tourism, we can contact our guests through various channels. Your personal data may be collected either fully or partially through automated means or through non-automated means as part of any data recording system.

3.1. Face-to-Face Sales Transactions

Your personal data can be obtained at our sales offices, agencies, or other physical sales points, for example:

• Printed or digital sales contracts and forms filled out by you,
• Face-to-face meetings with our sales consultants,
• Identity/passport presentation (for invoice/formal process/ticketing, etc.),
• POS devices and other payment tools used in payment transactions
• can be collected.

3.2. Distance Sales Transactions

Your personal data can be collected, for example:

• When you visit our website or create reservations/orders by becoming a member,
• When you call our call center (including call recordings),
• When you contact us via WhatsApp,
• When you correspond via e-mail/SMS with our customer service or employees,
• When you create location-based service requests as part of the services offered by our company (depending on the nature of the service).

3.3. Obtaining Through Third Parties

If your relationship with our company has occurred through an intermediary / partner / authorized sales channel, we may also obtain your personal data through these parties.

4. How Long Do We Retain Your Personal Data?

Your personal data is retained for the period required by the relevant legislation or necessary for the purpose for which it is processed. At the end of this period, your data will be deleted, destroyed, or anonymized in accordance with the KVKK. For example, there may be a 10-year retention obligation due to the relevant legislation regarding commercial records and documents.

5. What Personal Data Do We Process?

As Tebliğ Tourism, we may process your personal data in the following categories as part of the services we provide:

• Identity and contact data: Name, surname, TCKN, passport information, date of birth (for ticketing, etc.), address, e-mail, telephone/cell phone number, other information in the identity, visa application form information, population registration copy
• Visual/auditory records: Photo, call center voice recordings.
• Financial data: Payment method, payment details, (if applicable) masked card information, POS slip information, bank information for refunds, invoice information, and financial records.
• Customer transaction and reservation/order data: Reservation/order code, contract number, details of purchased products/services, transaction history; information regarding your current or past bookings related to accommodation/transportation/activity purchases, your package tour preferences, and travel information; support records.
• Request/complaint data: Contents of written/oral requests and complaints, your special requests.
• Insurance data: Travel insurance policy information and details.
• Occupation and demographic data: Profession information; (if you give marketing consent) marital status, marriage date, children information, etc.
• Location data (depending on the nature of the service): Instant/fixed location information (if necessary for the provision of address/location-based services).
• Special category personal data: Personal health information is processed to the extent necessary for organizing your special needs (e.g., health condition, allergy, mobility) during travel/accommodation if there are health conditions concerning you or your relatives that may require such special needs or if you request changes or cancellations due to health reasons. It is your responsibility to obtain explicit consent from the relevant person regarding the health information of your relatives if related health events arise during your travel.
• Other Information: Documents you provide that reveal the reason for not being able to participate in the accommodation service or tour.

As a rule, we do not request/process your special category personal data. However, in cases where it is necessary for the performance of the service and it is shared by you, we may process it based on your explicit consent in accordance with Article 6 of the KVKK and limited to the purpose.

6. What Purposes and Legal Grounds Do We Process Your Personal Data?

We may process your personal data for the following purposes under Articles 5 and 6 of the KVKK:

6.1. Establishment and Performance of Contract (KVKK Art. 5/2-(c))

• Providing products and services such as tours/hotels/transportation/activities/event tickets/insurance/visa consultancy,
• Creation and management of reservations/orders, operational notifications (flight time changes, etc.),
• Conducting membership processes,
• Management of refund/cancellation/change processes,
• Performing identity verification processes when required by the nature of the service (ticketing/reservation, etc.).

For example; in order to realize your preferred package tour, we can make accommodation reservations, carry out related activity reservation/sale processes if you purchase accommodation and activities, arrange the necessary operational notifications (including operational notifications), and inform third parties responsible for organizing transfer/welcoming processes. If your special category data needs to be processed during the reservation process, we process your data after obtaining your explicit consent. We may also process your data for the purpose of providing visa consultancy services upon your request.

6.2. Fulfillment of Legal Obligations and Explicitly Stipulated by Law (KVKK Art. 5/2-(ç) and Art. 5/2-(a))

• Invoicing, keeping accounting records, tax legislation obligations,
• Tourism/insurance/other legal obligations,
• Responding to lawful requests of authorized public institutions / judicial authorities / law enforcement / regulatory authorities.

6.3. Legitimate Interest (KVKK Art. 5/2-(f))

• Improving product and service quality, measuring customer satisfaction, business development activities and analyses,
• Evaluating and concluding requests and complaints; addressing negative issues and taking preventive measures against recurrence,
• In case of dispute, proving and protecting the company’s rights,
• Preventing fraud, forgery, and irregularities, ensuring company security and economic/legal safety,
• Conducting internal company processes (IT infrastructure management, internal audits, etc. – to the extent necessary and proportionate).

Moreover; in case of violations of the rules or legal obligations stipulated for the services provided by our company or if there is a need to investigate suspicions of violation, we can process your personal data in accordance with legal retention periods for purposes such as preventing fraud and protecting our rights.

6.4. Public Disclosure (KVKK Art. 5/2-(d)) – To the Extent Appropriate

The evaluation of personal data included in feedback publicly shared on platforms such as social media for the purpose of improving service quality and measuring customer satisfaction (to the extent applicable).

6.5. Special Category Data (KVKK Art. 6) – Explicit Consent

When necessary for organizing special needs (e.g., special menu/allergy at hotel, wheelchair for flight, cancellations/changes due to health), with your explicit consent and limited to the fulfillment of the relevant request.

7. Marketing Communications and Personalized Offers

The following activities depend on your explicit consent:

• Sending commercial electronic communication: If you have explicit consent; processing your name-surname, phone, and email information for campaign/promotion/presentation messages (KVKK Art. 5/1).
• Segmentation and profiling: If you have explicit consent; processing of the following types of data for the planning of marketing activities, segmentation, and profiling analyses to provide you with personalized content/opportunities (KVKK Art. 5/1).

For example; name-surname, gender, date of birth, marital status, phone, email, travel information (preferred holiday destination, spending amount, spending frequency, how many times a year you go on vacation, preferred hotel category, reservation person information), marriage date, children information, occupation information.

You can contact us at any time to withdraw your consent.

8. With Whom and for What Purposes Can We Share/Transfer Your Personal Data?

Your personal data may be shared/transferred with the following recipient groups in accordance with Articles 8 and 9 of the KVKK and limited to the purpose. We would like to emphasize that we never share your personal data with unauthorized third parties for our interests.

8.1. Business Partners / Suppliers

Accommodation and tourism service providers: Hotels, tour operators, guides, organizing companies, activity providers, ticket sales platforms, etc.

• Transportation service providers: Airlines, bus companies, etc.
• Insurance companies: For travel insurance processes.
• Visa processes: Relevant country diplomatic representations, authorized visa application centers, and necessary insurance institutions.
• Suppliers in distance/online orders: Third-party suppliers who actually fulfill the requested product or service (limited to identity/contact/location data depending on the nature of the service).

In international packages, our business partners to whom personal data is transferred may be located abroad. Moreover, in many cases, third parties to whom we transfer your personal data may process your data in their capacity as data controllers.

The information of the main supplier who will actually provide your service (e.g., hotel/airline you will stay at) may be included in your sales contract/addenda; moreover, you can learn it by contacting our sales consultant or our call center.

8.2. IT/Communication Suppliers and Operational Support

Website management, application hosting/server services, CRM/call-center infrastructure, messaging services, fraud prevention services, etc. suppliers.

8.3. Financial Institutions

Banks, payment, and e-money institutions for carrying out payment transactions.

8.4. Consultants and Business Partners

Lawyers for legal processes, certified accountants/auditors for financial processes (under confidentiality obligations and limited to purpose).

8.5. Authorized Public Institutions and Organizations / Private Individuals

In the case of legal obligation or lawful official request (court, prosecution, law enforcement, tax inspection, etc.).

9. Transfers within the Context of Marketing Activities

For sending commercial electronic communications, we may share your name-surname, phone, and email information with the service providers from whom we receive messaging services.

• In accordance with the Regulation on Commercial Communication and Commercial Electronic Communication, we may share your permission information and contact data with the Communication Management System (IYS) due to our legal obligations.
• Data processed for segmentation/profiling purposes may be shared with domestic/international suppliers from whom we receive application hosting and server services.

10. Foreign Transfers and WhatsApp (Meta) Notification

Due to packages including foreign travel or the infrastructure/communication channels used, your personal data may be transferred to and/or stored on servers located abroad.

Especially in communications conducted through WhatsApp; the relevant data and service provider Meta Platforms Inc. (WhatsApp) may process/store the data on servers located abroad. The transfers abroad are made in accordance with the conditions stipulated in Article 9 of the KVKK.

11. Your Rights Regarding Your Personal Data and Application Method

As a personal data owner according to Article 11 of the KVKK, you have the following rights:

• To learn whether your personal data is processed,
• To request information regarding it if processed,
• To learn the purpose of processing and whether it is used in accordance with that purpose,
• To know the third parties to whom it has been transferred, domestically or abroad,
• To request correction if processed incompletely/incorrectly and to have the correction communicated to the third parties to whom it has been transferred,
• To request deletion/destruction if the reasons for processing have ceased and to have the process notified to the third parties to whom it has been transferred,
• To object to the emergence of a result against you due to the analysis conducted through automated systems,
• To request compensation for the damages caused due to unlawful processing.

To submit your requests regarding your rights, you can access the Tebliğ Tourism Data Owner Application Form at the following address:

https://www.tebligtur.com/veri-sahibi-basvuru-formu

Your applications will be concluded as soon as possible and no later than within 30 days, depending on their nature. Applications are generally free; however, if additional costs arise, a fee may be requested according to the tariff determined by the Board.

Our Contact Information

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Commercial Title

Hakan Hac and Umrah Organization Inc.

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Address

Yenidoğan Mah. Osman Tiryaki Cad. No:1/6 Merkez - KIRIKKALE

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Telephone

+90 850 304 56 14 or +90 505 110 7666

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Fax

+90 850 304 56 14

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Registered Electronic Mail Address

hakanhacumre@hs03.kep.tr