Data Privacy Statement on the Protection and Processing of Personal Data
Introduction
The Consultant Danışmanlık Anonim Şirketi (“The Consultant” or “We”) pays the utmost attention to the lawful protection of its customer personal data.
We have prepared The Consultant’s Data Privacy Statement on the Protection and Processing of Personal Data (the “Data Privacy Statement”), in order to ensure compliance with the national and international legislation in effect, in particular the Law #6698 on the Protection of Personal Data (the “Law”) and the European Union General Data Protection Regulation (the “GDPR”).
The security of our customers’ personal data is at the forefront of our work. We understand that your privacy is important. We are committed to protecting your privacy and personal information you provide or as you access and use materials on/from www.theconsultant.com.tr (the “Site”), including the Site subscription pages or other websites or apps that post a link to this Privacy Statement. In addition, information that you submit to The Consultant as part of your email or phone call requests for any information, or through The Consultant’s newsletter subscriptions, will be treated in accordance with this Data Privacy Statement.
We have attempted to prepare easy to read Data Privacy Statement and we have provided our customers with all possible information while we are processing personal data for the purposes of compliance with our legal obligations and to ensure a better customer experience. Detailed information regarding the types of personal data and the purposes for processing personal data are detailed under section 3 “How do we process your personal information?” heading.
We have also listed your rights in accordance with the Law, which you may find under section 8 ”The exercise of rights by data subjects”. We implement measures to ensure that our customers manage their preferences regarding their own personal data and highly respect our customers preferences. In this regard, you may convey your requests to us by communication channels listed under section 8 “The Exercise of Rights by the Data Subjects”, and detailed explanations regarding the matter are provided within the section named “Rights of the Data Subjects”.
1. How do we obtain your personal data?
This Data Privacy Statement contains our declarations and explanations concerning the processing of personal data relating to our customers and other natural persons establishing contact with us, excluding our employees, in compliance with the provisions of the Law and the GDPR.
The Consultant may, at its discretion, make changes to this Data Privacy Statement in order to provide accurate and up-to-date information concerning practices and regulations relating to the protection of personal data. Additionally, data subjects will be informed by appropriate means in the event of a substantial change to the Data Privacy Statement.
This Data Privacy Statement is prepared in order to outline which personal data The Consultant processes within the scope of its activities, the purposes for processing, the parties to whom personal data are transferred and the purposes for such transfers. This Data Privacy Statement covers the following methods through which personal data are collected:
- Landline, cell phone, email, surveys, fairs, events, meetings including online, conferences, exhibitions, by verbal, written or electronic environments, by automatic and non-automatic means,
- If you request to receive service from these channels: the website located at www.theconsultant.com.tr (“Website”); software and applications provided through computers or other smart devices (“Application”); social media accounts administered by persons authorized to provide services on behalf of The Consultant (“Social Media”), instant messaging applications (“Messaging Platforms“) that mediate the service provided by The Consultant such as WhatsApp Business, Telegram, Facebook Messenger, WeChat, BiP etc. and other channels shall be referred to as (“Digital Platforms”).
2. Which personal data do we process?
Personal data processed by The Consultant differ in accordance with the nature of the legal relationship established with our Company. In this respect, categories of personal data collected by our Company through all channels, including Digital Environments, are as follows:
We collect personal data from you when you request copies of our publications, subscribe to our newsletters, send information regarding our services or employment opportunities or request the same via phone including mobile phone, databases, or register for various events, such as seminars or trainings and other The Consultant-organized and/or sponsored events. If you do not provide such information, you will not be able to benefit from any of the above.
Personal data that we collect includes: name and surname; contact information in order to subscribe to our newsletters or to request information about services (email address, phone number, mobile phone number, social media contact information, address); financial information (credit/debit card information, bank account information, IBAN information and other financial information); subject areas of interest and/or demographic information.
3. How do we process your personal information?
As per the Law, personal data can only be processed in the presence if at least one of the conditions set forth under Articles 5 and 6 of the Law and/or required by international legislation.
In this respect, as The Consultant, We may rely on different legal bases, including: i) it is expressly provided for by the laws, ii) 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) iii) complying with obligations under national and international regulations and iv) our legitimate interests provided that such interests do not have a negative impact on our customers’ fundamental rights and freedoms.
In addition to the above-listed conditions for processing personal data, we may request you to explicitly consent to the processing of your personal data. If this is the case, personal data will be processed limited to the scope of your freely given explicit consent. You may at any time revoke your explicit consent.
Therefore, personal data will be processed by The Consultant, within the framework of national and international legislation, in accordance with the conditions for processing personal data set forth under Articles 5 and 6 of the Law and within the scope of the below-listed purposes:
- To inform you or keep you informed about updates to the services and notifying you about other products and services offered by The Consultant that may be of interest to you, including information regarding publications and events;
- Tailoring your experience at the Site with relevant The Consultant materials;
- Understanding the Site’s user population, identifying subject areas of interest, and determining whether the Site is designed to work with the computer settings of a majority of our visitors;
- Measuring and improving the effectiveness of The Consultant marketing programs across different channels;
- Improving our web content and navigation; and
- for compliance with a legal obligation. This includes anti-fraud and anti-money laundering measures as well as tax and social security requirements.
4. Transfer of your personal data
Your personal data may be shared with parties who provide product or service to us or on behalf of our Company and with our suppliers and business partners that we get support for the establishment, execution and termination of our relationship, including the parties collaborating with us for the purposes of providing products and services to you. Your personal data may also be shared with public institutions and private persons authorized by law within the scope of their authorization. In such cases, our company takes all precautionary measures to ensure that the parties carry processing and transfer activities in accordance with the rules stated in this Data Privacy Statement and other related law.
Personal data may be shared with group companies, business partners, public institutions and private persons authorized by law pursuant to conditions and purposes of processing personal data as stated under Article 8 and 9 of the Law, and may be transferred abroad, limited with the stated purposes and in accordance with the principles and procedures stated under Article 9 of the Law and decisions of the Personal Data Protection Board.
Your personal data may only be transferred abroad where;
- your explicit consent is obtained, or
- where your explicit consent is not obtained but one or more data processing condition(s) which stated in the Law are met,
- the transferred country found to be offering adequate protection by the Personal Data Protection Board decision or;
- Within the scope of the provisions in the relevant laws.
- in case of the protection in the transferred country found to be inadequate, a written undertaking to provide adequate protection between our Company and the Data Controller that the data are being transferred to have been reached and the approval of the Personal Data Protection Board have been obtained.
5. Retention of personal data
Our company determines the retention periods by taking into consideration of the applicable law and purposes of data processing. In this respect, where applicable, we particularly consider the issues of period of limitation and legal obligations regarding the processing of personal data. Once the purpose for processing personal data ceases, unless another legal reason or basis allowing the retention of the personal data exists, data will be deleted, destroyed or anonymized.
6. Use of cookies
As Turkish Airlines, we utilize technologies such as cookies, pixels, GIFs (“Cookies”) to improve your user experience during your use of our websites and applications. The use of these technologies is in accordance with the Law and other related regulations that we are subjected to.
For further information regarding cookies, please refer to the following link
7. Rights of the data subjects
In accordance with Article 11 of the Law, data subjects are entitled to the following rights:
- Learn whether data relating to him/her are being processed;
- Request further information if personal data relating to him/her have 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 about him/her that are concluded as a result of analysis of the processed personal data by solely automatic means; and
- Demand compensation for the damages he/she has suffered as a result of an unlawful processing operation.
8. The exercise of rights by the data subjects
You can use your rights mentioned above and communicate the related requests to us via contact information below.
Data subjects’ requests concerning the above-listed rights shall be concluded by us within thirty days at the latest, in accordance with the limitations provided by the Law.
Data subject requests shall normally be concluded free of charge. However, The Consultant reserves its right to demand a fee from the tariff specified by the Board, in case the request requires additional costs.
Our Company may request certain information from the data subject in order to determine that the applicant is in fact the Data Subject, and additional questions can be directed to the applicant to clarify matters regarding the applications.
The Consultant Danışmanlık Anonim Şirketi
Telephone: +90312 4000990
Email: [email protected]
Address: Ilkbahar mahallesi, Güney Park Küme Evleri,19/B number 12, Woop Point Offices
Çankaya, Ankara, Türkiye, 06550
9. Data security
We take all appropriate technical and other measures to safeguard your personal data and to mitigate risks arising in connection with unauthorized access, accidental data loss, deliberate erasure of or damage to personal data.
13. Definitions
- Explicit consent: Consent that is provided for a specific subject, upon being informed and freely given.
- Anonymization: Rendering personal data by no means identified or identifiable with a natural person even by linking with other data.
- Related person/Data subject: Refers to the natural person whose personal data are processed.
- Personal data: Refers to any information relating to an identified or identifiable natural person.
- Special Categories of Personal data: Refers to data that has been subjected to a more stringent protection regime under the Law which may cause the Data Subject to be victimized or discriminated against in cases of disclosure or loss.
- Processing of personal data: Refers to any operation that is performed upon personal data such as collection, recording, storage, preservation, alteration, adaptation, disclosure, transfer, retrieval, making available for collection, categorization or blocking its use by wholly or partly automatic means or otherwise than by automatic means which form part of a filing system.
- Data recording system: Refers to the registration system in which personal data is configured and processed according to certain criteria.
- Data controller: The natural or legal person determining the purposes and means of the processing of personal data and who is responsible for the establishment and management of a data recording system.
