Introduction as Anatolian Routes Turizm, Organizasyon, Taşımacılık, Ticaret Ltd.Şti. (“Anatolian Routes,” “Company“, or “We“), we take utmost care to ensure the privacy and lawful processing of your personal data while providing services to our guests. In this information text prepared in accordance with Article 10 of the Personal Data Protection Law No. 6698 (“Law”), we would like to provide you with information on the following topics:
- How can we obtain your personal data?
- What personal data do we process?
- For what purposes and on what legal grounds do we process your personal data?
- With whom and for what purposes can we share your personal data?
- What are your rights regarding your personal data and how can you exercise these rights?
1. How can we obtain your personal data?
As Anatolian Routes, we can establish contact with our guests through various channels. For example:
- During your visits to our agents or branches,
- When you call our call center and provide your information,
- When you visit our website or sign up and make a reservation,
- You may share your personal data with us during your communications via email with our customer services or other Anatolian Routes employees. Additionally, if your relationship with our company is established through an intermediary, we may obtain your personal data through these intermediaries.
2. What personal data do we process?
As Anatolian Routes, we may process your personal data in various categories within the scope of the services we provide to our valued guests.
- Identity and contact information; Your name, surname, ID number, passport information, email address, phone number, mobile phone number, and address information. Visual and audio recordings;
- Your photograph, call center records.
- Financial information; Financial records or payment information related to the services you have received from our company.
- Current and past transaction information; Your current or past reservation preferences for hotels or package tours, or travel information.
- Request and complaint information; Written or verbal records of requests and complaints you have submitted to us regarding the services provided by Anatolian Routes or specific requests related to your existing reservation. Insurance information;
- Details related to your travel insurance policy.
- Occupation information; Details related to your profession.
- Other information; Your marriage date and children information.
- Sensitive personal data; In case you have special needs during your travel due to a health condition that may cause such needs or if you request a reservation change or cancellation due to your illness, we may process your health information, which is considered sensitive personal data.
3. For what purposes and on what legal grounds do we process your personal data?
As Anatolian Routes, we may process your personal data based on the following purposes and legal grounds:
- To provide you with the requested products and services in the best possible way, we process your personal data based on the legal ground of “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract,” as specified in Article 5(2)(c) of the Law. As Anatolian Routes, we offer a wide range of products and services, including tour reservations. In order to provide you with the products and services you requested or to complete your membership on our website, we process your personal data such as identity, contact, request, or financial information, enabling us to make your reservations, manage the operation process, and track your membership. For example, we make hotel reservations for the package tours you prefer, purchase flight tickets on your behalf, notify the persons who will welcome you, and provide you with informative communications about your travel. In case the processing of your sensitive data is necessary during the reservation process, we will process this data with your explicit consent.
- To improve the quality of our products and services, we process your personal data based on the legal ground of “legitimate interests pursued by the data controller” as specified in Article 5(2)(f) of the Law, and occasionally based on the legal ground of “personal data being made public by the data subject” as specified in Article 5(2)(d) of the Law. As Anatolian Routes, we constantly seek ways to provide better service to our guests. We conduct business development activities and analyses to improve the quality of our products and services and measure guest satisfaction. We process your personal data to carry out these business processes. Alternatively, we may process your personal information included in the feedback you provide publicly on social media in order to improve our products and services and measure customer satisfaction.
- To handle your requests and complaints, we process your personal data based on the legal grounds of “legitimate interests pursued by the data controller” as specified in Article 5(2)(f) of the Law, and “fulfillment of the data controller’s legal obligation” as specified in Article 5(2)(c) of the Law. Your requests and feedback are important to us. We process your personal data to evaluate your requests and resolve any issues you may have encountered or take necessary measures to prevent their recurrence.
- To create financial records, we process your personal data based on the legal ground of “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract,” as specified in Article 5(2)(c) of the Law. We may process your personal data while carrying out our financial processes. For example, issuing invoices related to the services we provide or creating financial records or conducting financial audits may require the processing of your personal data.
- To carry out internal operations, we process your personal data based on the legal ground of “legitimate interests pursued by the data controller” as specified in Article 5(2)(f) of the Law. Like any other company, we process your personal data when conducting certain processes and creating records within the company. For example, we manage our information technology infrastructure, reward our employees’ performance, or carry out internal audit operations.
- To fulfill our legal obligations, we process your personal data based on the legal grounds of “fulfillment of the data controller’s legal obligation” and “explicitly prescribed by the laws” as specified in Article 5(2)(c) and Article 5(2)(a) of the Law. As a company, we are subject to many legal obligations. For example, we may process your personal data to fulfill certain obligations arising from regulations such as tourism, tax, or insurance legislation and share your information with authorized public institutions or private organizations. Especially in response to lawful information requests made by authorities such as judicial authorities, police forces, or regulatory bodies, we may process your personal data to respond to these requests in compliance with the law.
For what purposes do we process your data, in order to conduct marketing communications and offer you personalized opportunities;
- If you have given your explicit consent, we process your name, surname, phone number, and email address to inform you about our promotions and announcements by sending commercial electronic messages, based on the legal ground of “explicit consent” as specified in Article 5(1) of the Law.
- If you have given your explicit consent, we process your name, surname, gender, date of birth, marital status, phone number, email address, travel information (your preferred holiday destination, spending amount, frequency of travel, how many times you go on vacation annually, preferred hotel category, and reservation contact information), marriage date, children information, and occupation information to plan marketing activities, conduct segmentation and profiling analyses for personalized marketing activities. We process this information based on the legal ground of “explicit consent” as specified in Article 5(1) of the Law. In this way, we can provide you with personalized content that suits you from our products and services as Anatolian Routes.
- You can withdraw your consent at any time by contacting us.
4. For what purposes and to whom can we share your personal data?
In certain cases, 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. We would like to emphasize that as Anatolian Routes, we never share or provide unauthorized third parties access to your personal data for our own benefit.
The third parties with whom we may share your personal data and the reasons for sharing are as follows:
- We may share your personal data with our business partners. As part of our package tour services, we may share your personal information with suppliers such as hotels and similar accommodation service providers, transportation companies such as airlines or bus companies, insurance companies providing travel insurance services, or companies providing organization services. Especially when you purchase tour packages involving international travel, our business partners to whom we transfer your information may be located abroad. In many cases, the third parties to whom we transfer personal data can process your personal data as data controllers.
- We may share your information with our suppliers. In certain points where we provide communication with you, we benefit from the services of third parties other than Anatolian Routes. In this context, we receive services from suppliers for matters directly related to the management of our website, provision of our information technology infrastructure, and similar services. However, we may share your personal data with lawyers to protect the legal and economic security of our company. In such cases, we may transfer personal data to suppliers.
- We may transfer your information to financial institutions. In order to make payments related to our services, we may share your personal data with banks or payment service providers.
- We may share your personal information with authorized public institutions or private individuals if it is legally required. We may need to share your information with authorized public institutions or organizations we are subject to, either routinely or upon request, due to our legal obligations or regulations such as tourism, tax, or insurance legislation. For example, we may share your information with public institutions during criminal investigations in response to information requests sent to us by courts or to comply with tax audits.
For what purposes and to whom do we transfer your data for marketing communications and personalized offers?
- If you have given your explicit consent, we process your name, surname, phone number, and email address to inform you about our promotions and announcements by sending commercial electronic messages, based on the legal ground of “explicit consent” as specified in Article 5(1) of the Law.
- If you have given your explicit consent, we process your name, surname, gender, date of birth, marital status, phone number, email address, travel information (your preferred holiday destination, spending amount, frequency of travel, how many times you go on vacation annually, preferred hotel category, and reservation contact information), marriage date, children information, and occupation information to plan marketing activities, conduct segmentation and profiling analyses for personalized marketing activities. We process this information based on the legal ground of “explicit consent” as specified in Article 5(1) of the Law. In this way, we can provide you with personalized content that suits you from our products and services as Anatolian Routes. You can withdraw your consent at any time by contacting us.
5. What are your rights regarding your personal data and how can you exercise these rights?
As a data subject, you have various rights regarding your personal data under Article 11 of the Law. In this section, we would like to provide you with information on the rights you have and how you can exercise these rights.
The rights you have under Article 11 of the Law are as follows:
- You can learn whether your personal data is being processed by us,
- If your personal data has been processed by us, you can request information regarding this processing,
- You can learn the purposes of the processing and whether your personal data is being used for these purposes,
- You can learn the third parties to whom your personal data is transferred domestically or internationally,
- If we have processed your personal data inaccurately or incompletely, you can request the correction of such data and, if applicable, request the transmission of these corrections to third parties to whom your personal data has been transferred.
- Even if your personal data has been processed in accordance with the law, if the reasons requiring the processing of your personal data have ceased to exist, you can request the deletion or destruction of your personal data and, if applicable, request the transmission of these changes to third parties to whom your personal data has been transferred.
- If an unfavorable result arises against you as a result of the analysis of the data we process solely through automated systems, you can object to this result.
- If you suffer any damages due to the unlawful processing of your personal data, you can request the rectification of such damages caused by unlawful data processing.
You can exercise these rights by contacting us and submitting your requests in accordance with the requirements of the legislation. To enable you to exercise these rights easily and have control over your personal data, we have prepared the Anatolian Routes Data Subject Application Form, which you can access at www.anatolianroutes.com. After filling out the application form, you can submit the document to us using one of the methods specified within the form. Depending on the nature of your application, we will respond to your requests as soon as possible and no later than thirty days. As a rule, requests from data subjects are answered free of charge; however, an additional fee may be charged if required by the legislation.
Trade Name: Anatolian Routes Turizm, Organizasyon, Taşımacılık, Ticaret Ltd. Şti.
Address: İskele Mahallesi, No: 28, Dalya Otel, No: 6, Datça/Muğla, Türkiye
Telephone: +90.549.486 60 00
Registered Email Address: anatolianroutes@hs01.kep.tr