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Privacy Notice on measures taken due to the Covid-19 Pandemic

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 of its customers and business partners. The Privacy Notice on Measures Taken Due to The COVID-19 Pandemic (“Privacy Notice”) herein have been prepared in accordance with the Article 10 of Law on Protection of Personal Data numbered 6698 (“Law”) to ensure that the personal data of our customers that are buying tickets, making reservations or similar operations at our ticket sale offices, check-in counters at airports or our agencies and accordingly taking a flight are processed under full control and in a transparent manner.

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, the third parties we share your data with, and 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/

How Do We Collect Your Personal Data? What Is the Legal Basis for Processing Your Personal Data?

Your personal data can be collected via printed documents (such as PCR test result and special permission information submitted by the customer etc.) and in some cases via digital applications (such as HES code application and E-Pulse (E-Nabız) application) in order to comply with the measures taken due to the COVID - 19 pandemic and to fulfil various legal obligations. 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 listed herein.

In this respect, as Turkish Airlines, we may rely on different legal bases, including:

  • it is expressly provided for by the laws,
  • the necessity to establish a contractual relationship with you and to perform our obligations under a contract (provision of airline transport services and other related services)
  • complying with obligations under national and international regulations and
  • our legitimate interests provided that such interests do not have a negative impact on our customers’ fundamental rights and freedoms.

Your personal data concerning health is processed in accordance with the third paragraph of Article 6 of the Law by persons or authorized institutions and organizations under the obligation of secrecy for the purpose of protecting public health, preventive medicine, medical diagnosis, treatment and care services, planning the finance of and managing health services.

Which Personal Data We Process?

Your personal data processed within the scope of the measures on COVID-19 pandemic 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 Information: Name, surname, identification number, passport information (For more detailed information about processing of Identity/Passport Information you may read the “Turkish Airlines Protection of Personal Data Announcement for the Processing of Identity/Passport Information” published on https://www.turkishairlines.com/en-tr/legal-notice/privacy-policy/processing-of-identity-passport-information/)
  • Contact Information: E-mail address, phone and cell phone number, address information.
  • Advanced Passenger Information (“API”): Name, nationality, birth date, gender, type and number of your travel documents and its date of validity, and its issuing country.
  • Customer Process Information: Personal data recorded in channels such as call centers (CDR), credit card statements, box office receipts, customer instructions and other changes recorded in channels relating to an instruction or request attributable to a person.
  • Health Data: PCR test result, symptoms (fever, cough etc.), medication and previous treatment information received for first aid in medical emergencies, allergic and pregnancy status, blood pressure, pulse, respiration and relevant health information such as fever.
  • Other Information: HES code information of Turkish citizens and foreign passengers taking domestic flight as obliged by Republic of Turkey Ministry of Health, special permission document within the scope of circulars issued by Republic of Turkey Ministry of Interior, and personal data requested pursuant to national and international rules of civil aviation.

Why Do We Process Your Personal Data?

Your personal data are processed by Turkish Airlines for the purposes of protection of public health, preventive medicine, medical diagnosis, rendering treatment and care services, compliance with national and international regulations that THY is subject to and fulfillment of the obligations resulted from relevant regulations, performing flight operations in accordance with national and international aviation rules, compliance with the rules set by civil aviation authorities, control of the necessary documents within the scope of the COVID-19 pandemic and making examinations and confirmations on the documents, keeping records of these examinations, compliance with information storage, reporting, record keeping, informing and other obligations stipulated by the law, arrangement and informing and reservation procedures such as refund/postponement/cancellation regarding your flight.

To Whom We Transfer Your Personal Data and Why?

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.

Third parties that we may transfer your data can be listed categorically as follows:

  • Our business partners or suppliers residing within borders or abroad: e.g., ground operation service providers at airports, transportation service providers, call centers, global distribution systems (GDS), partner airlines that will provide you services during connecting flights.
  • Foreign countries that the transportation is carried out to and private and public institutions authorized by national or international legislations: e.g. to Turkish Republic Ministry of Health and other authorized healthcare organizations.

What are Your Rights as Data Subjects?

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.

Contact Information

Türk Hava Yolları A.O. Genel Yönetim Binası

Yeşilköy Mah. Havaalanı Cad. No:3/1 34149 Bakırköy/İstanbul/Turkey

00 90 212 463 63 63

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