Turkish Airlines Privacy Notice For Miles&Smiles

Introduction

Türk Hava Yolları Anonim Ortaklığı (hereinafter referred to as “THY”, “Company” or “We”), pays the utmost attention to the lawfulness of the processing of personal data relating to its customers. The Turkish Airlines Privacy Notice (“Privacy Notice”) herein have been prepared in accordance with relevant legislation primarily the Article 10 of Law No. 6698 on Protection of Personal Data ("Law") and the EU General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”) to ensure that the personal data of our customers are processed in a transparent manner during processes within the scope of the Miles&Smiles Program (“Miles&Smiles”).

In this respect, within this Privacy Notice we provide you information on, as a data controller, which personal data of yours we process and for what purposes within Miles&Smiles membership, the third parties we share your data with, your rights and methods that you may contact us.

For more detailed information about the processing of your personal data, you may read the Privacy Notice on the Protection and the Processing of Personal Data on https://www.turkishairlines.com/en-int/legal-notice/privacy-policy/index.html. If you are a passenger subject to GDPR, please find more detailed information on https://www.turkishairlines.com/en-pl/legal-notice/gdpr-privacy-notice/

Your personal data can be collected within services we provide with Miles&Smiles program via Turkish Airlines’ online channels, documented forms, sales offices, check-in counters, kiosks, call center, internet service provided inside the plane and IFE, member request and concerns, admission points to the plane, authorized travel agencies for the sale of Turkish Airlines products and services, GDSs, online sales channels, questionnaire and evaluation activities, program partners and other airlines verbally, in written form or digitally.

As per the Law, your personal data may only be processed where one or more conditions that are stipulated under Law are present. As THY, regardless of the purpose for which we process your personal data, we process it in accordance with the provisions of national and international law, primarily the general principles stated under Article 4 of the Law and by relying on conditions for lawful data processing listed under Article 5 and 6 of the Law.

• It is explicitly permitted by any law
• The processing is directly related to the execution or performance of a contract
• The fulfillment of obligations which THY is subjected to in accordance with the current national or international regulation
• Our legitimate interests, provided that they do not negatively affect the fundamental rights and freedoms of our Customers.

In addition to the above-listed conditions for processing personal data, in some cases we may request your explicit consent to process your personal data. In such cases, your personal data is processed limited to the scope of the explicit consent you have provided with your freewill. You have the opportunity to withdraw your explicit consent at any time.

General information on your personal data processed by THY are as follows (For more detailed information about the processing of your personal data, you may read the Privacy Notice on the Protection and the Processing of Personal Data on https://www.turkishairlines.com/en-int/legal-notice/privacy-policy/index.html.):

• Identity and Contact Information: Personal data such as name, surname, identification number, passport information and contact information such as e-mail address, address, phone and cell phone number or social media contact information that you have provided to us while creating accounts, changing membership status, making plane ticket reservations or applying for exclusive services offered by THY and its partners.
• Flight Information: Reservation or ticket information or other information related to your flights,
• Advanced Passenger Information (“API”): Personal data relating to your name, nationality, birth date, gender, type and number of your travel documents and its date of validity, and its issuing country.
• Evaluations and requests: Information regarding your assessments, complaints and requests relating to our services.
• Payment Information: Credit/Debit card information, bank account information, IBAN information, balance and receivable information and other financial data,
• Membership Program Information: If you are a member, information regarding Miles&Smiles ve Turkish Airlines Corporate Club membership programs.
• Special Service Requests: Provided that you have your request and approval, information about the disease, disability, allergy and special dietary requirements and the information contained in the documents related to them, to provide the service you need during your travel.
• Households and Relatives Information; households information obtained in case of creating family membership required identity, contact of your relatives in case creating Companion application that allows quick ticketing transactions

We process personal data of customers who accepts Miles&Smiles Program Rules and Conditions and becomes a member for the following purposes (For more detailed information about the processing of your personal data, you may read the Privacy Notice on the Protection and the Processing of Personal Data on https://www.turkishairlines.com/en-int/legal-notice/privacy-policy/index.html.):

• to provide Miles (“Miles”) from flights with Turkish Airlines and with program partner airlines,
• to introduce a personal security code (“PIN Code”) and a card for each member,
• to design and provide special services to program members via our more than a a hundred program partners (https://www.turkishairlines.com/en-nl/miles-and-smiles/program-partners/index.html ) operating in a wide range of sectors such as airlines companies, car-rental companies, banks which provide credit cards used to accumulate Miles, hotels, insurance companies, health service providers, tourism companies, organizations providing shopping and entertainment services, telecommunication companies, educational institutions and energy companies,
• to spend Miles at Shop&Miles and to provide Miles for spendings with a credit card,
• to benefit our Miles&Smiles credit card holder members with Miles in different rates according to the sector,
• to make our members and their preferred relatives benefit from various advantages (such as free tickets, cabin upgrades) with earned Miles&Smiles Miles according to the membership status,
• to perform transactions such as buying Miles, transferring Miles, activating Miles that are outdated, paying ticket taxes with Miles and converting Miles,,
• to enable booking a ticket from the website and mobile applications, to design special campaigns for Miles&Smiles members through various surveys, to offer special opportunities for our members' birthdays, to cut celebration cakes, to organize special surprises and services for our members such as valet parking and private driver service,
• in case you request a [Family Membership], to take necessary actions within the Miles collected by family members, (If you open a family membership account, all members within the family can view the account movements of other family members) As a general feature of loyalty programs, to reward loyal member behavior and shape the program according to the member expectations. follow-up of member behavior,
• in case you have a RFID baggage card, to inform you by SMS about the status of your baggage at the airport,
• to reward loyal members as a general feature of loyalty programs and to follow member behaviours to customize the program according to the member’s expectations.
• Carrying out the sales operations of products/ services and after-sales support services via https://www.shopandmiles.com,
• Carrying out the customer relationship management operations,
• Carrying out activities in accordance with the legislation,

Under certain circumstances, we may transfer your personal data that we process to third parties residing within borders or abroad, in accordance with the provisions of national and international law, particularly Article 8 and 9 of the Law.

The categories of third parties that we may transfer your data to can be listed categorically as follows:

• Our business partners residing within borders or abroad; e.g. ground operation service providers at airports, agencies, transportation service providers, global distribution systems, partner airlines that will provide you services during connecting flights,
• Group companies, e.g. certain services offered by THY are carried out by our affiliates, within this context, your personal data may be shared with our relevant affiliates. You may find more detained information regarding our group companies on Türk Hava Yolları Anonim Ortaklığı Policy on Protection and Processing of Personal Data or from the following link: https://www.turkishairlines.com/en-tr/press-room/about-us/index.html
• Suppliers; e.g. software companies that we procure technical services, research companies, agencies that perform special campaign service for members, supply companies, security firms, transportation service providers,
• Foreign countries that the transportation is carried out to and private and public institutions authorized by national or international legislations; e.g. to enforcement agencies, executive or judicial bodies in relation to ongoing investigations or when travelling to United States of America, to United States National Security Council etc.

According to the Law on Electronic Commerce no. 6563 and the Regulation on Commercial Communication and Commercial Electronic Communications, in accordance with the consent given, your personal data may be processed in order to provide information about our services, to promote our goods and services and to keep you informed about our campaigns. In accordance with the relevant legislation, your permissions regarding commercial electronic communication must be recorded in the Communication Management System (CMS), and within this scope, the contact address (phone number or e-mail address), permission date, communication channel, recipient type and data of permission source will be shared with CMS. You can visit https://iys.org.tr for detail information.

As data subjects, you are entitled to a number of rights under Article 11 of the Law in relation to your personal data. We would like to inform you about the rights that you are entitled to and the ways you may use them.

The rights you have under the Article 11 of the Law are as follows:

	Learn whether data relating you is being processed.
	Request further information if personal data relating to you has been processed.
	Learn the purpose for the processing of personal data and whether data are being processed in compliance with such purpose.
	Learn the third-party recipients to whom the data are disclosed within the country or abroad.
	Request rectification of the processed personal data which is incomplete or inaccurate and request such process to be notified to third persons to whom personal data is transferred.
	Request deletion or destruction of personal data in the event that the data is no longer necessary in relation to the purpose for which the personal data was collected, despite being processed in line with the Law and other applicable laws and request such process to be notified to third persons to whom personal data is transferred
	Object to negative consequences that you experienced as a result of analysis of the processed personal data by solely automatic means.
	Demand compensation for the damages that you have suffered as a result of an unlawful processing operation.
	If you are a passenger subject to GDPR, please find more detailed information on https://www.turkishairlines.com/en-pl/legal-notice/gdpr-privacy-notice/

In order to easily exercise your rights listed above and send us your relevant requests You may contact us through our contact information below. We will respond you in the shortest time possible, based on the nature of your request and within 30 days at the latest. As a general rule, responses to data subject requests are given free of charge; however, we reserve the right to charge you according to the tariff to be determined by the Personal Data Protection Board in case the request requires additional costs.”

Türk Hava Yolları A.O. Genel Yönetim Binası Yeşilköy Mah. Havaalanı Cad. No:3/1 34149 Bakırköy/İstanbul/Türkiye

00 90 212 463 63 63

https://www.turkishairlines.com/en-tr/any-questions/customer-relations/index.html