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 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 Turkish Airlines GDPR Privacy Notice on https://www.turkishairlines.com/en-tr/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 GDPR, personal data can only be processed in the presence if at least one of the conditions set forth under the GDPR and/or required by international legislation. In this respect, as Turkish Airlines, we may rely on different legal bases, including:
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 purposes of processing of your personal data, you may refer to the Turkish Airlines GDPR Privacy Notice on https://www.turkishairlines.com/en-tr/legal-notice/gdpr-privacy-notice.):
Under certain circumstances, we may transfer your personal data that we process to third parties residing within borders or abroad, in accordance with applicable laws.
The categories of third parties that we may transfer your data to can be listed categorically as follows:
Where permitted by law you are entitled to a number of rights:
| ||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.|
| ||Request a copy of your personal data we hold.|
| ||Learn to which third-party recipients your data is disclosed.|
| ||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.|
| ||Obtain the personal data you provided to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.|
| ||Object to negative consequences that you experienced as a result of analysis of the processed personal data by solely automatic means.|
| ||Object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing purposes).|
| ||If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.|
Under the GDPR, these rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in the GDPR. We will inform you of relevant exemptions we rely upon when responding to any request you make.
In most cases we will not charge a fee for your requests. However, where the request is manifestly unfounded or excessive we may charge a reasonable fee based on the administrative costs generated by your request.
You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data based on Article 6 (1) (e) or (f) of the GDPR, including profiling based on those provisions.
We shall no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.
If you object to processing for direct marketing purposes, your personal data shall no longer be processed for such purposes.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.
If you have any concerns about how we process your data, or if you would like to opt-out of direct marketing, based on the laws applicable to you, you can reach out to:
Türk Hava Yolları Genel Yönetim Binası Yeşilköy Mah. Havaalanı Cad. No:3/1 34149
00 90 212 463 63 63
If you live in Germany and have an unresolved concern you can also contact our German DPO:
+49 069 955171 22/53
Turkish Airlines Inc. Hamburger Allee 4 (Westendgate) 60486 FRANKFURT
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