Policy Concerning the LPPD

Law on the Protection of Personal Data

SCOPE AND OBJECTIVE

This policy has for objective to regulate the processing of personal data which originate or which are directly obtained as a result of legal, commercial or financial relations between NOYAN HEALTH & TRAVEL and its customers, its staff as well as the natural and legal persons it contacts and it is in interaction with; to determine the rules to be respected, to declare and announce them in the framework of the Law nr. 6698 on the Protection of Personal Data (LPPD) and the Booklet on the Policy Concerning the PPD.

Obligation of Clarification

Due to the legal necessities and requirements imposed in the framework of the Law nr. 6698 on the PPD (Law on the Protection of Personal Data) which entered into force on 07.04.2016, it has been necessary to establish a legal framework with regards to personal data that are processed during the relations between NOYAN HEALTH & TRAVEL and its customers, its staff as well as the natural and legal persons it contacts and it interacts with

NOYAN HEALTH & TRAVEL gives a particular attention to the security and confidentiality of the personal data belonging to its customers, its staff and to the natural and legal persons it contacts and interacts with. In this framework, a priority is given to the security of personal data belonging to the relevant persons during the performance of services.

Due to the provisions of the above-mentioned law, all kinds of personal data that can be linked with a natural person (including personal data of private nature) are considered as personal data in the framework of the Law on the PPD. These personal data are processed by NOYAN HEALTH & TRAVEL as a Data Controller by using the methods explained below and in the framework of the limits imposed by the legislation.

“The Processing of Personal Data” means all kinds of procedures realized on data such as obtaining, recording, stocking, conserving, modifying, reorganizing, making public, transferring, taking charge of, making available, classifying or preventing the use of such data by using totally or partially automated means or by non-automatic means as a party of any data recording system.

Objective and Legal Basis of the Processing of Personal Data

According to the legislation, personal data can be collected by NOYAN HEALTH & TRAVEL in verbal or written forms in the electronic or physical environments by using automated or non-automated methods such as recording to the platform, using the telephone, fax, e-mail, SMS and other social networks, mobile applications; making audiovisual recordings etc.

In the framework of article 5 of the Law on the PPD nr. 6698,

1. There is the explicit consent of the data subject,
2. It is expressly provided for by the laws,
3. It is necessary for the protection of the life or physical integrity of the person himself/herself or of any other person who is unable to explain his/her consent due to a de facto impossibility or whose consent is not deemed legally valid,
4. Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract made with NOYAN HEALTH & TRAVEL as a result of an approval and/or signature,
5. It is necessary for complying with a legal obligation to which NOYAN HEALTH & TRAVEL is subject,
6. Personal data have been made public by the data subject himself/herself,
7. Data processing is necessary for the establishment, exercise or protection of any right,
8. Processing of data is necessary for the legitimate interests pursued by NOYAN HEALTH & TRAVEL, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.

Also, in the framework of article 6, personal data are processed

1. With the explicit consent of the data subject
2. In other cases provided for by laws

in the context of the above mentioned conditions and objectives concerning the processing of personal data.

Sharing and Transfer of Personal Data

Personal data belonging to a relevant person may be shared with and transferred to the third parties indicated below by NOYAN HEALTH & TRAVEL when required by its activities and its responsibility, by taking the necessary electronic and physical measures in cases where this is imposed by public institutions and organisations due to the legislation: solution partners located inside and outside the country and with which NOYAN HEALTH & TRAVEL has commercial, legal and economic relations; project partners; program and cooperation partners; companies, institutions and organisations which provide goods and services; independent auditors, banks and financial institutions ; other companies, persons and organizations which/who provide assistance and support; lawyers; financial counsellors; legal counsellors; counsellors in the fields of informatics, quality and finance. This sharing and transfer is also valid for abroad.

NOYAN & TRAVEL may transfer, process and conserve the personal data belonging to a relevant person by using servers that provide support in storage, archiving, informatics technologies; hosting companies; programs; cloud computing and other electronic environments within Turkey or abroad, especially in EU countries, in the United Stated and England, on condition that all the necessary security measures are taken.

Method for the Collection of Personal Data

The personal data mentioned below belonging to a relevant person are collected through totally/partially automated means or as a party of any data recording system and they are conserved by taking into consideration limitation periods brought by the relevant legislation: all the contracts/data sheets that have been signed after being approved and/or accepted; the other documents; the approvals, acceptations and notifications made with an electronic approval and/or signature; data obtained in verbal, written, audiovisual or electronic environments where we contact the relevant person or where it is possible to contact him/her in the future by using the administrative centre of NOYAN HEALTH & TRAVEL; physical environments, call centres, websites, mobile applications; web procedures, social networks and other public environments; communications with users; the scanning of legal data, market researches, the Identity Sharing System, the SMS, the numeric applications submitted on websites; written/numeric applications submitted to the sale teams

Personal data collected by NOYAN HEALTH & TRAVEL due to the legal reasons mentioned above may be processed and transferred in the framework of the objectives of this policy which have been previously explained, by taking into consideration the conditions concerning the processing of personal data indicated in articles 5 and 6 of the Law nr. 6698 on the Protection of Personal Data.

Rights of the User

(according to article 11 of the Law nr. 6698 on the PPD)

The relevant persons may communicate with NOYAN HEALTH & TRAVEL from the e-mail address mentioned below and may request the following on their persona data;

1. to learn whether his/her personal data are processed or not,
2. to demand for information as to if his/her personal data have been processed,
3. to learn the purpose of the processing of his/her personal data and whether these personal data are used in compliance with the purpose,
4. to know the third parties to whom/which his/her personal data are transferred within the country or abroad,
5. to request the rectification of the incomplete or inaccurate data, if any,
6. to request the erasure, destruction or anonymization of his/her personal data when the reasons requiring the processing of personal data are no more valid,
7. to request that the operations carried out pursuant to articles (5) and (6) mentioned above be reported to third persons to whom personal data have been transferred
8. to object to the occurrence of a result against the person himself/herself by analysing the data processed solely through automated systems,
9. to claim compensation for the damage arising from the unlawful processing of his/her data, if any, and to claim other rights indicated in the legislation.

Data Controller to Which an Application May Be Made in the Framework of the Law

NOYAN HEALTH & TRAVEL is the person recorded as Data Controller at the VERBIS system (Registry of Data Controllers) at the address www.kvkk.gov.tr.  

In the framework of the rights indicated above, the relevant person may send his/her requests, complaints, propositions personally or through a public notary to the address of NOYAN HEALTH & TRAVEL mentioned below or he/she may also send them to the e-mail address indicated below by also indicating the e-mail address that had been notified by the user during the opening of the account and that had been recorded to the website.

The first name, family name, the Turkish Republic identity number, the residence address or work address to be used for notifications, the mobile phone number, the e-mail address, the subject matter of the request shall be indicated in applications. Moreover, information and documents related to the request shall also be sent with the application.

The official language is Turkish in the correspondences to be made with NOYAN HEALTH & TRAVEL. That’s why, all kinds of applications, correspondences, problems, complaints and propositions shall be written and sent in the Turkish language.

If the application is sent in written and in the physical environment, it shall be made with a handwritten signature.           

In principle, the answers given to requests, problems, propositions and complaints are not subject to any fee. However, if the answer to be given requires the payment of a charge or any other cost, NOYAN HEALTH & TRAVEL reserves the right to request the fees indicated in the regulations concerning the Law on the PPD or those indicated in the tariff determined by other authorities.

In order to get more information on your problems, your requests, your propositions and your complaints on the Policy Concerning the PPD, please contact us by using the contact details indicated below.

Moreover, you can obtain the Booklet on the Policy Concerning the PPD from NOYAN HEALTH & TRAVEL.