Website Confidentiality Agreement

During your visit to this website and your useof the service through this Site, how the information that we receive regardingyou and the services you request will be used and protected are subject to this‘’Confidentiality Agreement’’. You hereby accept the conditions stipulated inthis ‘’Confidentiality Agreement’’ when you visit this website and request touse the services we provide through this Site. 

I. Purpose of personal data protection andprocessing policy 
Until today, data and information of ourcustomers or potential customers are kept confidential and have never beenshared with third parties by virtue of the sensitivity of our business as ETS. Personaldata protection is our essential policy. Even before any legal regulation, ourcompany and subsidiaries had attached a great importance to the confidentialityof personal data, adopted as a working principle and gave working instructionsto the employees in compliance with this principle. As ETS, we undertake toadhere to all responsibilities of Privacy Act. The principle of our company toprotect personal data also covers our subsidiaries. 

II. Scope and change of personal dataprotection and implementation policy 
This Policy prepared by our Company has beenregulated in accordance with “Law on Protection of Personal Data” no. 6698(“KVKK”). The Law has entered into force with all of its provisions as oftoday. The data received with your consent or pursuant to the other regulationsas per to the Law shall be used to make our service more quality and to improveour services and quality policy. Again, some of the data we obtain are removedfrom the scope of personal data and anonymized. These data are used forstatistical purposes and not subject to the enforcement of Law and our Policy. PersonalData Protection and Implementation Policy of ETS aims and regulates theprotection of the data which are automatically obtained from our customers,potential customers, employees and the customers and employees of the companiesin cooperation with us for solution partnership and the other parties. 
Our company reserves the right to change ourPolicy and Regulation – provided to comply with the Law and protect thepersonal data in a better way. 

III. General principles on processing of thepersonal data 
a) Being in compliance with the law and goodfaith: ETS questions the source of the data it collects or sent by othercompanies and attaches importance to handling these in compliance with the lawand good faith. Within this framework, it warns and notifies the third parties(agencies and other intermediary firms) that sell the services provided by ETS toprotect the personal data. 
b) Being accurate and up to date, if necessary: ETSattaches importance to the accuracy of all of the data kept within theorganization, to the fact that they don’t include any misinformation and thatpersonal data are updated only if the changes are notified. 
c) Being processed for specified, explicit, andlegitimate purposes: ETS processes the data limited to the services andpurposes for which consent of the persons are taken during the services. Itshall not process, use and make use of the data out of business purposes. 
d) Being relevant, limited and proportionate tothe purposes for which data are processed: ETS uses the data only forprocessing purposes and to the extent what the service requires.
e) Being stored only for the time designated byrelevant legislation or necessitated by the purpose for which data arecollected: ETS keeps the contractual data as long as it’s required by thecommercial and taxation law as well as the periods of conflicts of law. Nevertheless,it shall delete or anonymize the data in case the reasons necessitating theirprocessing cease to exist. 

It’s crucial to state that whether ETS collectsor processes the data by one’s will or in compliance with the law, the abovementionedprovisions shall apply anyhow. 

You shall have the following rights pursuant toArticle 11 of Law on Protection of Personal Data. A separate application shallbe prepared by ETS for you to facilitate your related rights. 

The persons whose personal data have beenprocessed may apply to our official announced on our website by ETS and shallbe entitled to;
a) Learn whether or not your personal data havebeen processed, 
b) Request information as to processing if yourdata have been processed,
c) Learn the purpose of processing of thepersonal data and whether data are used in accordance with their purpose,
ç) Know the third parties in the country orabroad to whom personal data have been transferred,
d) Request rectification in case personal dataare processed incompletely or inaccurately,
e) Request deletion or destruction of personaldata within the framework of the conditions set forth under article 7, 
f) Request notification of the operations madeas per clauses (d) and (e) to third parties to whom personal data have beentransferred,
g) Object to occurrence of any result that is toyour detriment by means of analysis of personal data exclusively throughautomated systems, 
ğ) Request compensation for the damages in casethe person incurs damages due to unlawful processing of personal data.
As ETS, we respect to these rights.

Maximum Savings Policy/Scrimping Policy 
Pursuant to our policy called as maximum savingspolicy or scrimping policy, the data received by ETS are processed into thesystem as required. Thus, which data we will collect shall be determinedaccording to the purpose. Unnecessary data shall not be collected. Other data submittedto our company are transferred to the information system of the company in thesame way. Redundant information is not stored in the system, they are deletedor anonymized. These data may be used for statistical purposes. Health dataamong the special quality data are only kept in the system to provide betterservice to the customers and to protect their health. 

Deletion of personal Data 
When the retention period necessitated by theLaw expires, judicial procedures are completed or other requirements no longerexists, these data shall be deleted, removed or anonymized automatically, bythe company or upon the request of the relevant person.

Data obtained via membership process

In case you become the member of ETS, the personal data given during sign up transaction are processed on our systems. If you become member via Facebook, Google or other social media channels, your information provided by related social media channel to its partners such as your name, surname, your profile picture and e-mail address are accessed and conveyed to ETS systems.

Accuracy and Currency of Data 
The data within the body of ETS are processed asdeclared by the relevant persons as a rule. ETS is not obliged to check up onthe accuracy of the data declared by the customers or the persons in touch withETS and it’s also contrary to the Laws and our working principles. The declareddata are regarded as correct and accurate. The principle of accuracy andcurrency of personal data has also been adopted by ETS. The personal dataprocessed upon the request of the relevant person or from official documentsthat are submitted to our company are updated. Necessary precautions are takenfor this purpose. 

Confidentiality and data security 
Personal data are confidential and ETS obeys therule of confidentiality. Only authorized persons shall access the personaldata. All necessary technical and administrative measures are taken to protectthe personal data collected by ETS and to prevent the damage on our customersand potential customers. Within this framework, it shall be ensured that thesoftware complies with the standards, third parties are selected with cautionand data protection policy is observed within the company. 

Purpose to Use CookiesCookie Type
Google(analytics, doubleclick)Measuring 
Advertisement 
In-site improvement
Functional and analytical cookies 
Commercial cookies
FacebookAdvertisementCommercial cookies
AdjustMeasuring 
In-site improvement
Functional and analytical cookies 
Commercial cookies
HotjarMeasuring 
In-site improvement
Functional and analytical cookies 
Commercial cookies
3rd party companies (criteo, rtbhouse)AdvertisementFunctional and analytical cookies 
Commercial cookies


IV. Purpose of data processing 
Collection and processing of personal data by ETSshall be executed in line with the purposes stipulated in the letter ofclarification. The data are collected and processed to draw up contracts andprovide better services to the customers. 

V. Data of customer, potential customer andbusiness and solution partners 

Collection and processing of data forcontractual relationship 
In case of a contractual relationship with ourcustomers and potential customers, the collected personal data may be usedwithout the approval of the customers. However, this use shall be for thepurpose of the contract. The data shall be used for better execution of thecontract and as required by the services and updated, if necessary, bycontacting the customers. Nevertheless, the data provided to us by ourpotential customers shall be processed to easier and more quality serviceslater. These data shall be deleted upon requests in case of lack of anycontractual relationship. 

Data of Business and Solution Partners 
ETS adopts as a principle to act in compliancewith the laws when exchanging the data both with business and solutionpartners. The data are shared with the business and solution partners with theunderstanding of data confidentiality and as required by the services and it’sdefinitely ensured that these parties take measures regarding the datasecurity. 

Data processing for advertisement purposes 
Electronic messages for advertisement purposescan only be sent to the persons with prior consent in compliance with the Lawon the Regulation of E-Commerce and the Law on Commercial Communication andCommercial Electronic Messages. An explicit consent of the person is requiredto send advertisements. ETS obeys the details of ‘’the consent’’ specified inthe same legislation. The consent to be obtained should cover all commercialelectronic messages that are sent to the electronic communication addresses ofthe recipients to promote and market the goods and services of the company, topromote the business or to increase the recognition level of the company withcontents including greetings and wishes. This consent may be obtained via anyelectronic communication channel or at physical medium in written. Theimportant thing is to obtain the declaration of the recipient that he/sheaccepts to receive commercial electronic messages and to have his/her full nameand electronic communication address.Personal data in order to send electronic messages About Commercial Electronic Messages. In accordance with the regulation, it is transferred to service providers and Message Management System Inc. 

Data processing due to legal obligations ofthe company or being stipulated explicitly in the Law 
Personal data may be processed without priorconsent when it’s stipulated explicitly in the relevant legislation or tofulfill a legal obligation specified in the legislation. Type and scope of thedata processes are required for data processing activity that is permitted bythe Laws and they should comply with the relevant legal provisions. 

Data processing of the company 
Personal data may be processed pursuant to the legalpurposes and the services of the company. However, the data shall not be usedfor services contrary to the laws under any circumstances. 

Processing of personal data of special nature 
According to the relevant laws, the following are considered personal data of a special nature: race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, attire and dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures, biometric and genetic data. ETS takes the adequate measures determined by the Commission for the Processing of Personal Data of Special Nature. ETS may only process data of special nature for the purpose for which it was collected and with the consent of the individual, in order to provide better services. The facilities and/or airlines you book through us may request certain personal data from guests and passengers, including personal data of special nature such as the health data belonging to them and their relatives, in accordance with circulars and legal regulations issued within the scope of Covid-19. These personal data may be shared by ETS, by the airline and, when necessary, with official authorities and health institutions in order to provide the service subject to reservation.

Data processed with automatic systems 
ETS acts in compliance with the Law for dataprocessed with automatic systems. The information obtained from these datawithout the explicit consent of the persons shall not be used against theperson. However, ETS may take decisions regarding the persons that it willperform process by using the data within the system. 

User information and internet
In case the personal data are collected,processed and used at the web sites and other systems or applications of ETS,the relevant persons shall be informed of the cookies if necessary withconfidentiality notification. The persons shall be notified about our practiceson the web pages. The personal data shall be processed in compliance with theLaw.

VI. Data of our employees
Processing of the data for business relations

Personal data of the employeesmay be processed without obtaining consent to the extent of requirements ofhealth insurance and business relations. However, ETS hereby undertakes theprotection and confidentiality of the data of the employees. 

Processing as per Legal Obligations
ETS may also processes the personal data of theemployees without obtaining a separate consent to fulfill a legal obligationstipulated in the legislation or in case it’s explicitly specified in thelegislation. This case is limited to the obligations arising from the Law. 

Processing in Favor of the Employees 
ETS may process the personal data withoutobtaining the consent for the procedures in favor of company employees likeprivate health insurances. For the disputes arising from the businessrelations, ETS may also process the data of the employees. 

Processing of special quality data
Pursuant to the Law, race, ethnic origin,political opinion, philosophical belief, religion, sect or other beliefs,clothes, membership of association, foundation or union, health, sexual choice,juridical sentence and data regarding safety measures and biometric and geneticdata are among the special quality data. Besides the consent of the relevantperson, ETS also takes adequate measures determined by the Board for theprocessing of special quality data. Special quality data may be processedlimited to and related to the cases permitted by the Law without the consent ofthe person. The quality data obtained from the employees shall only be used forthe corresponding purpose to allow them to benefit from the insurance andhealth services. 

Data processed with automatic systems 
The data processed regarding the employees withautomatic systems may be used for in-house promotions and performanceassessments. The employees reserve the right to appeal to the results againstthem and they should perform this process in compliance with the internalprocedures. Appeals of the employees shall be evaluated again within thecompany. 

Telecommunication and internet
The computers, telephone, e-mail and otherapplications allocated to the employees within the company shall only be usedfor business purposes. The employee cannot use any of these means allocated tohimself/herself by the company for private purposes or communication. Thecompany may control and monitor the data on these means. The employeeundertakes not to keep any data or information apart from the business purposeson the computer, telephones or other means allocated to himself/herself as ofhis/her employment date. 

VII. Transferring of the personal datadomestically and internationally 
Personal data may be shared with business andsolution partners and ETS subsidiaries for the purpose of providing theservices by ETS. 

ETS will be entitled to transfer the personaldata for certain purposes to the following person and institutions; 
» Business partners of ETS limited to thepurpose of execution of the aims of the establishment of the businesspartnership, 
» The suppliers of ETS to the extent ofproviding the necessary services by our company to fulfill its commercialactivities and procured by the supplier as external sources, 
» Solution partners of ETS limited to ensuringthe execution of the commercial activities which require the participation ofthe affiliates of the company, 
» Subsidiaries of ETS. 

ETS is authorized to transfer the personal datadomestically and internationally within the conditions determined by the Boardand in compliance with the other provisions in the Law and depending on theconsent of the person. 

VIII. Rights of the relevant person 
ETS hereby agrees that the relevant person mustprovide his/her consent before processing the data within the scope of the Lawand he/she reserves the right to determine the destiny of the data after thedata is processed. 

Regarding the personal data, the relevantpersons holds the right to do the following by applying to our official announcedon the web page by ETS; 
a) To be informed whether his/her personal dataare processed or not, 
b) To request information if the personal dataare processed, 
c) To learn the purpose of processing thepersonal data and whether the data are used for the corresponding purposes, 
ç) To get information on the third parties towhom the personal data are transferred in the country and abroad, 
d) In case the personal data are processedincompletely or inaccurately, to request the correction, 
e) To request that personal data are deleted orremoved within the framework of the conditions stipulated in article 7, 
f) To request that the processes performed asper clause (d) and (e) are notified to the third parties to whom the personaldata are transferred, 
g) To appeal to the negative results againsthimself/herself arising from the analysis of the data processed exclusivelythrough the automatic systems, 
ğ) In case the personal data are damaged due tothe processing of the data contrary to the Law, to request that the damages areindemnified. 
Nevertheless, the persons don’t reserve anyright on the anonymized data within the company. ETS may share the personaldata as required by a juridical function or governmental authority as per thebusiness and contractual relationship. 

The owners of the personal data shall submittheir requests regarding the above-mentioned rights to the contact address Merdivenköy Mh. Nur Sk. 1/8 C Blok Kadıköy, Istanbul  bycompletely filling out and putting their wet signatures on the application formgiven at www.etstur.com.tr, the official website of thecompany, through registered letter with return receipt with the copies of theiridentity cards (only front page for birth certificate). The applications shallbe replied within the shortest time according to the content of the applicationow within 30 days at the latest after the delivery to the company. You need toapply with registered letter with return receipt. Besides, only the questionsabout you shall be replied and any applications made regarding your spouse,relative or friends shall not be accepted. ETS can only request information anddocument from the application holders.

You can also submit your requests using a secure electronic signature.

  1. Confidentiality Principle
    The data of the employees and other personswithin ETS are confidential. Nobody can use, copy, reproduce, transfer thesedata for other purposes apart from the business purposes. 

    X. Process security 
    All necessary technical and administrativemeasures are taken to protect the personal data received by ETS and to preventthe retention of them by unauthorized persons and to prevent the damage on ourcustomers and potential customers. Within this framework, it’s ensured that thesoftware complies with the standards, third parties are selected with care anddata protection policy is followed within the company. 

    XI. Inspection 
    ETS carries out the internal and externalinspections for protection of the personal data. 

    XII. Notification of Violations 
    ETS shall immediately act to remedy theviolations in case a violation of personal data is notified. It shall mitigateor indemnify the damage of the relevant person. In case the personal data areobtained by the unauthorized persons, this case should be immediately notifiedto the Board of Personal Data Protection. 

    Regarding the notification of the violations,you can also make an application as per the procedures provided at http://etstur.com.

Contact 
You can contact us for further questions on the confidentialityagreement by using the following contact information. 

EtsErsoy Turistik Servisleri A.Ş.
Address: Merdivenköy Mh. Nur Sk. 1/8 C Blok
Kadıköy, Istanbul 
Phone: +90 216 542 99 99
Fax: +90 216 349 86 40
Mail address: misafirimiz@etstur.com
Central Registration System No: 0381004079000024 

Protection of Personal Data Application Form