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General Data Protection Regulation (GDPR)




Website Confidentiality Agreement

By visiting our websites; You receive information about the services we offer you through our websites, while you benefit from our services. How the information we obtain regarding you and the services you request will be used and protected is subject to the terms set forth in this "Confidentiality Agreement". By visiting our websites, you accept the terms stated in this "Confidentiality Agreement".

PROCESSING OF PERSONAL DATA LIGHTING TEXT

We are Nexonya. (“Nexonya”), as the data controller, processes your personal data within the scope of the Personal Data Protection Law No. and we fulfill the requirements for the protection of the data we process by taking the technical and administrative measures specified in the relevant legislation.

With this notice, in the capacity of data controller, you fulfill the obligation of disclosure specified in Article 10 of the KVKK, and thus, all other websites accessed via https://www.nexonya.com and/or managed by Nexonya (“Website”). We aim to inform you, our visitors, in detail about the processing processes of your personal data that we have processed in particular activities.

1. How to collect your personal data?

2. For what purposes and on what legal grounds do we process your personal data?

3. Which personal data do we process?

4. For what purposes and with whom may we share your personal data?

5. What are your rights regarding your personal data and how can you exercise these rights?

How can we obtain your personal data?

1. COLLECTION OF YOUR PERSONAL DATA

As Nexonya, we collect the personal data of our website visitors in fully or partially automated ways; Cookies in the website, visiting the website, filling out the forms on the website, filling the "Contact Forum" in the "Contact Us" tab of the website, contacting us from the phone numbers on the website. We reach the roads.

2. PURPOSE OF PROCESSING AND LEGAL REASON FOR COLLECTION

Your personal data that we have obtained through the collection methods described above, the website; Connection/login-out date (log record) and time information regarding your visit, IP address, User name and password information, transaction security data, Information on content search, Legal approval given for sending electronic commercial messages, Request and complaint information, Legal status given Approvals Customer Transaction Data E-mail address, Telephone number, Address information, Billing address Contact Data Information obtained through the cookies used Marketing Data Name-Surname, T.C. ID number, Passport Number, Date of Birth Identity Data are collected for reasons.

If you choose the "Debit-Credit Card" section from the "Payment options", your name-surname, card number, card type, expiration date of the card, CVV number of the card on the card evaluated in the Customer transaction data category are not processed by Nexonya as the data controller and the relevant Your information will be processed by the contracted organizations in accordance with the completion of your payment transaction and the service relationship between us.

3. Which personal data do we process?

As Nexonya, we may process your personal data in different categories within the scope of the services we offer to our valued guests.

• Your identity and contact information; Name, surname, TCKN, passport, etc. your information and e-mail address, telephone number, mobile phone number, information contained in your identity, address information

• Your audio and visual recordings; Your photo, your call center records

• Your financial information; your financial records or payment information regarding the services you have received from our company

• Your current and past transaction information; your hotel or package tour preferences or travel information regarding your current or past reservation.

• Your request and complaint information; Written or verbal records of your requests and complaints regarding the services offered by Nexonya, or your special requests regarding an existing reservation

•Your insurance information; Details on your travel insurance policy

• Your personal data of special nature; In case you have a health condition that may cause you to have special needs during your travel or if you request a reservation change or cancellation due to your illness, we may process your health information, which is in the nature of sensitive personal data.

4-a For what purposes do we process your personal data?

As Nexonya, we may process your personal data for the following purposes and for legal reasons:

• In order to provide you with the products and services you have requested in the best way, we process it on the basis of the legal reason 'it is directly necessary or relevant for the establishment and performance of the contract' in subparagraph c of the 2nd paragraph of Article 5 of the Law. As Nexonya, we bring you many products and services, especially tour reservations. We process your personal data such as your identity, contact, request or financial information so that we can offer you the products and services you request or to make your membership through our website, and in this way, we monitor the making of your reservations, the operation process and your membership process. For example, we make hotel reservations for a package tour of your choice, buy your flight tickets on your behalf, inform the people who will meet you, and provide you with informative communications about your trip. If it is necessary to process your special data during the reservation process, we will process your data by requesting your explicit consent.

• In order to improve our product and service quality, the 'legitimate interest of the data controller' in clause f of paragraph 2 of Article 5 of the Law and from time to time the 'data subject has been made public by himself/herself in clause d of paragraph 2 of Article 5 of the Law' We are processing based on legal reason. As Nexonya, we are always looking for ways to provide better service to our guests. We carry out business development activities and analyzes for purposes such as increasing the quality of our products and services, measuring the satisfaction of our guests, getting to know our customers and their preferences better, and creating more efficient business strategies. We process your personal data in order to carry out these business processes. Or, we may process your personal information in the feedback you have given publicly on social media for the purpose of improving our products and services and measuring customer satisfaction.

•In order to carry out commercial communication activities, we process with your 'explicit consent' in accordance with the 1st paragraph of the 5th article of the Law. As Nexonya, we offer many products and services. We can send you notification content to introduce these products and services we offer and to inform you of innovations and opportunities that will excite you. It is entirely your choice to receive these notifications; give us your permission to send these messages to you whenever you want. You may grant or withdraw your consent.

• In order to finalize your requests and complaints, based on the legal grounds of 'legitimate interest of the data controller' in clause f of paragraph 2 of Article 5 of the Law and 'fulfillment of the legal obligation of the data controller' in clause 3 of paragraph 2 of Article 5 of the Law. we are processing. Your requests and feedback are very important to us. We may process your personal data in order to evaluate your requests regarding how we can offer the services we offer you better and to solve the problems you experience or to take the necessary measures to prevent them from happening again.

• In order to create financial records, we process on the basis of the legal reason 'it is directly necessary or relevant for the establishment and performance of the contract' in subparagraph c of the 2nd paragraph of Article 5 of the Law. We may process your personal data while conducting the financial processes of our company. For example; Your personal data may be processed during the issuance of invoices for the services we provide, the creation of financial records or the execution of financial audits.

• In order to carry out in-company activities, we process it on the basis of the legal reason "legitimate interest of the data controller" in subparagraph f of the 2nd paragraph of Article 5 of the Law. As in almost every company, we can process your personal data while conducting certain processes and creating records while carrying out our business activities. For example, we manage our information technology infrastructure, reward the performance of our employees or perform internal audit operations.

• In order to fulfill the legal obligations to which we are subject, we process it based on the legal grounds of 'fulfilling the legal obligation of the data controller' in paragraph 2 of paragraph 2 of the Law and "explicitly stipulated in the laws" in paragraph 2 of paragraph 2 of the Law. As a company, we are subject to many legal obligations. For example, we may process your personal data and share your information with authorized public or private institutions in order to fulfill certain obligations arising from regulations such as tourism, tax and insurance regulations. In particular, we may process your personal data in response to lawful information requests made by authorities such as judicial authorities, police forces, regulatory and supervisory authorities.

4-b For what purposes and with whom may we share your personal data?

In certain circumstances, we may share your personal data with third parties. Below we summarize the parties with whom we may share your personal data and the reasons for sharing it. We would like to underline that, as Nexonya, we never share or open your personal data to unauthorized third parties for our own benefit.

The third parties we may share your personal data with and the reasons for sharing are as follows:

• We may share your personal data with our business partners. We may share your personal information with our suppliers, such as hotels and similar accommodation service providers, companies that provide transportation services such as airlines or bus companies, insurance companies that provide travel insurance services, or companies that provide organization services, which enable us to offer you the products you receive within the scope of our package tour services. Our business partners, to whom we transfer your information, may be abroad, especially when you purchase tour packages that include international travel. In many cases, third parties to whom we transfer your personal data may also process your personal data as data controllers.

• We may share your information with our suppliers. At some points where we communicate with you, we use the services of third parties other than Nexonya. In this context, we receive services from suppliers in matters directly related to our services, such as sending commercial messages, managing our website, and providing our information technology infrastructure. However, we may share your personal data with lawyers in order to protect the legal and economic security of our Company. In these cases, we may transfer your personal data to suppliers.

• We may transfer your information to financial institutions. We may share your personal data with banks or payment institutions to process payments for our services.

• We may share your personal information with authorized public institutions or private individuals if legally requested. In accordance with our legal obligations to which we are subject, we may need to share your information with authorized public institutions or related institutions due to the insurance and tax legislation to which we are subject, routinely or upon request. For example, we may share your information with public institutions to respond to information requests submitted to us by the courts within the scope of criminal investigations or during tax audits.

5. What are your rights regarding your personal data and how can you exercise these rights?

regarding your personal data;

*Learning whether your personal data is processed,

*If your personal data has been processed, requesting information about it,

*To learn the purpose of processing your personal data and whether they are used in accordance with the purpose,

*Knowing the third parties to whom your personal data is transferred at home or abroad,

*Requesting correction of your personal data if it is incomplete or incorrectly processed,

* Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the KVKK,

* Requesting notification of the transactions made pursuant to subparagraphs (d) and (e) to third parties to whom personal data has been transferred,

* Objecting to the emergence of a result against you by analyzing your processed data exclusively through automated systems,

* If you suffer damage due to the unlawful processing of your personal data, you have the right to demand that your damage be remedied.

Within the scope of your aforementioned rights, you may submit your requests in person or through a notary public in writing, in accordance with the "Communiqué on the Procedures and Principles of Application to the Data Controller", or by registered electronic mail (KEP) address, secure electronic signature, mobile signature or previously notified to Nexonya by Nexonya. You can send it by using your e-mail address registered in the system.

Your application will be answered in accordance with the relevant provisions stipulated in the KVKK and Nexonya may request some confirming information from you in order to confirm that the applicant is the right person; this information will only be requested in order to determine who the real data owner is and to share the application results with the right person.



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