UNİVER TRAVEL
CLARIFICATION TEXT ON PROCESSING OF PERSONAL DATA
As Univer Travel Turizm Hizmetleri San. ve Tic. Ltd. Şti (hereinafter referred to as «Univer Travel»), we respect and mind the privacy of our guests’ private lives. For this reason, as Univer Travel Turizm Hizmetleri San. ve Tic. Ltd. Şti, we’d like to inform you with the Clarification Text on the Processing of Personal Data («Clarification Text») as part of our duty to inform you under Article 10 of the Law on Protection of Personal Data No. 6698 («KVKK») under the title of data controller.
As the person responsible for compliance with the Law on the Protection of Personal Data No. 6698, we’d like to inform you that with our clarification texts and policies in the agreement on the processing of personal data and nondisclosure on our website www.univertravel.com.tr, we process all types of identifiable data about you in accordance with the law and the rules of good faith, they are accurate and up to date, if necessary, related to the purpose for which they’re processed, limited and measured, for the period specified in the relevant laws or for the period necessary for the purpose for which they’re processed, for specific, clear and legitimate purposes.
As Univer Travel, we would like to point out that we have taken all possible technical and administrative measures to ensure an adequate level of security to prevent the unlawful processing of personal data, to prevent unlawful access to personal data and to ensure the retention of personal data.
Method of Collecting Your Personal Data and Data Collected
The processing of personal data described in this clarification text is carried out in accordance with the Law on Protection of Personal Data, relevant legislation and Univer Travel’s Agreement on Personal Data Protection. You can view our agreement on personal data protection on our website.
In accordance with the Law on Protection of Personal Data, we collect your personal data automatically or non-automatically, verbally, in writing or electronically, through the following methods and other channels that may be added in the future, and we process them within the framework of articles 5, 6 and 8 of the Law on Protection of Personal Data:
1.1. Through our website www.univertravel.com.tr and our other websites («Websites»), our mobile and other applications, our Call Center 4448595 and all kinds of online media belonging to Univer Travel («Media Tools») or cookies that provide communication with your devices on Web Sites («Cookies»), automatically or non-automatically and electronically,
1.2. Through social media accounts operated on behalf of Univer Travel (“Social Media”) automatically or non-automatically and electronically,
1.3. Through all kinds of communication methods, including correspondence through our e-mail addresses («E-mail»), short messages («SMS») or multimedia messages («MMS») sent to Univer Travel for all kinds of purposes and all kinds of communication (“Communication Tools”) automatically or non-automatically and in writing, verbally or electronically,
1.4. Through our call centers providing service to Univer Travel or by service-provider company to Univer Travel (“Call Center”) automatically or non-automatically and verbally or electronically,
1.5. Through third parties such as group companies, business partners, producers or service/product suppliers which Univer Travel serves or from which Univer Travel receives services, automatically or non-automatically and verbally or electronically.
1.6. Hotel activities: Room reservations; check-in and payment at the hotel; accommodations and services during a stay at the hotel; eating/drinking at the hotel cafe or restaurant during a stay; Requests, complaints and/or disputes.
1.7. Participation in marketing programs or events: Signing up for loyalty programs; Participating in customer satisfaction surveys (e.g., Guest Satisfaction Survey); Playing online games or contests; Subscribing to bulletins to receive offers and promotions by e-mail.
1.8. Disclosure of information by third parties: Tour operators, travel agencies (whether online or not), GDS reservation systems and others;
1.9. Data of customers, prospects, business and solution partners
The categories and descriptions of the personal data to be processed in this context are as follows:
Identity information (first and last name, ID number, passport number, etc.),
Your contact information (Your personal data such as e-mail address, phone number, mobile number, social media contact information, address, etc.),
Your process security information (IP address information, information about entering and leaving the website),
Extended customer information (your personal data such as first name, last name, nationality, date of birth, gender, type and number of accommodation documents, etc.),
Information on family members and people related (children, spouse of the relevant person, their identity information, contact information),
Information on customer processes (your personal data such as an order associated with the person and a need-based CDR (Call Detail Record), call center records, credit card statements, bank statements, customer orders, records recorded in appropriate channels, etc.)
Risk management information (various query results and records related to the relevant person submitted by public institutions, security inquiry records about whether you have a disability, address registration system records, IP address tracking records, etc.)
Financial information (credit/debit card information, bank account information, IBAN information, balance information, credit balances and other financial information)
Security information about the physical location (records of entering and leaving the company’s environment, information about visits, camera and sound records, etc.)
Legal process and compliance information (requests for information from judicial and administrative authorities or personal data in decisions, etc.)
Audit and inspection information (information about all types of records and processes related to the legal pursuit and enforcement of our rights, etc.)
Sensitive personal data (sensitive personal data such as information about your health, information about allergies, food preferences, information about disabilities, clearly required by law and necessary for the operation of the company and processed with your explicit consent and necessary for the provision of specific services)
Marketing information (reports and evaluations about the individual’s habits and inclination associated with the individual to be used for marketing purposes, targeting information, cookie records, information derived from data enrichment activities, information and evaluations obtained as a result of surveys of the individual, satisfaction surveys, campaigns and direct marketing studies, etc.)
Demand/complaint management information (information and records collected in the course of demands and complaints to our company regarding our products and services related to the individual, as well as information on reports in which the results are evaluated by the respective business units, etc.)
Purpose of the Processing of Your Personal Data
Your Personal Data collected by the methods through the channels mentioned in this Clarification Text are processed by Univer Travel for the following purposes:
2.1. In the presence of one of the conditions in Article 5 of the Law on Protection of Personal Data, it is possible to process personal data without obtaining the explicit consent of the relevant person:
2.1.1. When expressly provided for by law.
2.1.2. If it is absolutely necessary for the protection of the life or physical integrity of the person or of another person, if the person concerned is physically or legally incapable of giving consent, or if the consent of that person is not legally accepted.
2.1.3. If it is necessary to process the personal data of the contracting parties, provided that this is directly related to the conclusion or performance of an agreement.
2.1.4. If it is compulsory for the data controller to fulfill his/her legal obligation.
2.1.5. If it was made public by the relevant person.
2.1.6. If the data processing is strictly necessary for the establishment, exercise or protection of a right.
2.1.7. If the data processing is absolutely necessary for the legitimate interests of the data controller, provided that it does not adversely affect the fundamental rights and freedoms of the relevant person;
2.2. Within the scope of the Article 6;
2.2.1. For the purpose of fulfilling our legal obligations (such as tax legislation, consumer protection legislation, occupational health and safety legislation, code of obligation, commercial law and other legislation, telecommunication legislation, banking legislation): The processing of your data in the context of e-invoice, e-archive or when required by consumer protection laws, as well as any other processing that can be attributed to the relevant regulation, and the processing of the identity information of our guests staying in our hotels for the purpose of reporting to law enforcement authorities in accordance with our legal obligation in accordance with the Law on the Notification of Identity number 1774 can be given as an example.
2.2.2. If it is absolutely necessary for the protection of your life or physical integrity, if you are physically or legally incapable of giving consent, or if your consent is not legally accepted. the processing of your Personal Data as a result of an incident in case you are unconscious and all kinds of processing as per the related legislation can be given as examples.
2.2.3. For the purpose of establishment or execution of a contract: All kinds of processing such as supply of products and services which you have ordered or purchased online, contacting you in this context if necessary, use of POS machines, return procedures, shipping services, establishment of distant sales agreements as per electronic commerce, sale, supply and delivery of products or services as part of our obligations and any other processing that can be attributed to the relevant regulation can be given as examples.
2.2.4. For the purpose of fulfilling our legal obligations, processing such as replying and resolving questions, complaints and notifications regarding Univer Travel products and services that you place through Websites, Communication Tools or Call Center and processing of health reports that you have shared with Univer Travel as regards to your complaint and any other processing that can be attributed to the relevant regulation can be given as examples.
2.2.5. For the purpose of establishing, using or protecting a right: processing such as storing the records of sale transactions as evidence and any other processing that can be attributed to the relevant regulation can be given as examples.
2.2.6. In order to protect our legitimate interests, without harming your fundamental rights and freedoms: processing such as camera recordings to ensure safety in hotels and measure the quality of services provided to you and reviewing and resolving your requests in this regard and any other processing that can be attributed to the relevant regulation can be given as examples.
Also, Personal Data that you have made public may be processed for the purposes above without your explicit consent. Processing of your Personal Data that you made public in Social Media, your website and other channels and any other processing that can be attributed to the relevant regulation can be given as examples.
2.3. Your Personal Data may be processed for the following purposes given that explicit consent is obtained as per Articles 5.1 and 6.2 of the Law on Protection of Personal Data:
2.3.1. Processing for CRM (Customer Relations Management) works and for offers of exclusive products and services provided for you such as internet advertisements, targeting, re-targeting, cross sales, campaigns, promotions and product/service advertisements,
2.3.2. Processing within the scope of loyalty program and membership services,
2.3.3. Processing for providing targeted content in while you are visiting websites,
2.3.4. Processing for creating new products and services,
2.3.5. Processing for sending electronic commercial messages (such as campaigns, newsletters, customer satisfaction surveys, product and service advertisements),
2.3.6. Processing for sending gifts, promotions and other magazines/periodical publications,
2.3.7. Processing for corporate communications and, in this regard, organizing various events and notifying about these events,
2.3.8. Within the context of SPA service you receive, processing of your personal health data especially for determining the healthy conditions in massage and steam rooms and for providing the best services possible,
2.3.9. For your sensitive personal data to be processed due to your inability to express your consent due to physical impossibility, establishment or execution of a contract, to fulfill our legal obligations, to establish, use or protect a right and to protect our legitimate interests without harming your fundamental rights and freedoms.
Duration of the Processing of Your Personal Data
Your Personal Data you have shared with Univer Travel through channels described in this Clarification Text will be processed in accordance with the required periods set forth in legislation for Protection of Personal Data especially the Law on Protection of Personal Data and any other legislation, and in any case until the legitimate purposes set forth above disappears. If the purpose of the processing of personal data disappears, the data will be deleted, destroyed or anonymized, unless there is another legal reason or basis that allows the retention of the personal data.
Transfer of Your Personal Data to Third Parties and/or Abroad
Univer Travel may transfer your Personal Data collected through the channels and methods described in this Clarification Text to third parties or abroad within the purposes set forth in the Law on Protection of Personal Data and other legislation and this Clarification Text. Your Personal Data:
4.1. may be transferred to the third parties from which we got assistance as regards to the storage, archiving, information technologies (server, hosting, program, cloud computing), security, call center services etc., Group Companies, business partners providing service to us/cooperate with us, suppliers, banks, financial institutions, consulting firms operating in the areas of law, tax etc. which provide service to us, and other related parties, institutions and organizations when transfer is necessary under determined data processing purposes, that are located in Turkey and in other countries primarily in EU countries, United States of America, England, OECD countries, India, China and Russia if above-mentioned purposes under Articles 5.2 and 6.3 of the Law on Protection of Personal Data exist;
4.2. may be transferred to storage places, environments such as cloud, marketing companies, Group Companies, third party firms providing marketing support to us (e-mail, advertising agents for creating campaigns, firms providing CRM services) located in Turkey and in other countries, primarily in EU countries, United States of America, England, OECD countries, India, China and Russia, provided that your explicit consent has been obtained within the scope of the Articles 5.1 and 6.3 of the Law on Protection of Personal Data.
Your Rights Under the Law on Protection of Personal Data Regarding Your Personal Data
By applying to Univer Travel under Article 11 of the Law on Protection of Personal Data, you have right to;
5.1. Learn whether your Personal Data is processed or not,
5.2. Request information as to processing if your Personal Data have been processed,
5.3. Learn the purpose of processing of your Personal Data and whether data are used in accordance with their purpose,
5.4. Know the third parties to whom your Personal Data have been transferred at home or abroad,
5.5. Request rectification in case your Personal Data are processed incompletely or inaccurately,
5.6. Request deletion or destruction of the Personal Data if the grounds for processing Personal Data are no longer valid in terms of principles of purpose, duration and legitimacy,
5.7. Request notification of the operation made to the third parties to whom the personal data has been transferred in case of correction, deletion or destruction of your Personal Data,
5.8. Object to any negative consequence of your Processed Personal Data being analyzed exclusively through automated systems,
5.9. Request compensation for the damages in case you incur damages and these due to unlawful processing of your Personal Data.
Method of Using Rights Originating from the Law on Protection of Personal Data
You may send your questions and requests regarding your personal data in person to the Data Controller, with a petition prepared in accordance with the terms set forth in the Notice of Request Procedures and Principles, to the address Kavacık Mah. Muhtar Sokak Tecom Plaza No.5 İç Kapı No:4 BEYKOZ/İSTANBUL by identifying yourself, or through a notary, or you can send it through other methods located in the Law on Protection of Personal Data and other methods determined by the Personal Data Protection Authority that may be added in the future. Univer Travel will conclude the request as soon as possible, but no later than within 30 (thirty) days free of charge, depending on the nature of the request. If additional costs are incurred in connection with the conclusion of the requests by Univer Travel, Univer Travel may charge the fees according to the tariff established by the Data Protection Authority.
Confidentiality Policy
The data of employees or other people at «Univer Travel» are confidential. No one may use, copy, reproduce, disclose to others or use for any other purpose such data, except for business purposes, without complying with the agreement or law.
Process Security
All necessary technical and administrative measures are taken to protect the personal data collected by «Univer Travel» and to prevent them from falling into the hands of people who do have not authority and to prevent our customers and prospects from being harmed. In this regard, it is ensured that the software complies with the standards, that the third parties are carefully selected and that the data protection policy within the company is respected. Security measures are constantly renewed and improved.
Amendments to the Agreement on the Protection of Personal Data and Confidentiality
This clarification text has been prepared within the framework of the Law on the Protection of Personal Data No. 6698 and other relevant legislation. Necessary amendments may be made in the aforementioned clarification text according to the amendments that occur in the relevant legal legislation and/or the purposes and policies of the processing of personal data by Univer Travel. For the most recent version of the clarification text, please visit https://www.univertravel.com.tr.
10. Explicit Consent Text
I agree and declare that I have been informed about my personal data processed by Univer Travel through the Agreement on the Protection of Personal Data and Confidentiality and the Clarification Text on https://www.univertravel.com.tr in accordance with Article 10 of the Law on the Protection of Personal Data No. 6698 titled “Clarification Obligation of the Data Controller”, that I have understood the subject matter about which I have been informed and that I have learned in detail my legal rights in relation to said records. I expressly consent to the processing of my identity, communication and marketing data for the purposes of advertising, marketing, analysis activities, communication activities, creation and transmission of personalized campaigns, advantages, promotions, advertisements and organization of events.
Details of Data Controller
Title: Univer Travel Turizm Hizmetleri San. ve Tic. Ltd. Şti or “Seller”)
Address: Kavacık Mah. Muhtar Sokak Tecom Plaza No.5 İç Kapı No:4 BEYKOZ/İSTANBUL
Telephone: 444 85 95
Mersis No: 0892070446700001
KEP Address: univertravel@hs01.kep.tr