Subject:
Regarding informing data subjects in accordance with the Law No. 6698 on the Protection of Personal Data concerning the collection of personal data belonging to customers/visitors
I. Information Notice
1. Introduction
This information notice has been prepared by MOBIEN GLOBAL MOBİLYA İTH.İHR.LTD.ŞTİ (“Company”) to ensure that the personal data of our guests, including individuals and the personnel, employees, or representatives of corporate guests, are processed in accordance with the Constitution of the Republic of Turkey, international human rights conventions to which our country is a party, and particularly Law No. 6698 on the Protection of Personal Data (“KVKK”) and related legislation, and to ensure that the data subjects whose data are processed can effectively exercise their rights.
All personal data shared with our Company may be processed lawfully, in connection with and proportionate to our operational and service purposes.
2. Definitions
The terms personal data, special categories of personal data, and data processing used in this information notice are based on the definitions provided in the KVKK.
Personal data: Any information relating to an identified or identifiable natural person.
Processing of personal data: Any operation performed on data such as collection, recording, storage, preservation, alteration, rearrangement, disclosure, transfer, retrieval, classification, or prevention of use, whether fully or partially automated, or non-automated provided that it forms part of a data recording system.
Special categories of personal data: Data concerning a person’s race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and attire, association, foundation or trade-union membership, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data.
3. Principles of Personal Data Processing
In accordance with Article 4 of the KVKK, personal data belonging to data subjects shall be processed by the Company in compliance with the principles of:
Lawfulness and fairness,
Accuracy and being kept up to date where necessary,
Being processed for specific, explicit, and legitimate purposes,
Being relevant, limited, and proportionate to the purpose of processing,
Being retained only for as long as necessary for the purpose of processing or as required by the relevant legislation.
4. Purposes of Processing Personal Data
Your personal data may be processed for the following purposes:
Fulfilling obligations arising from contractual relationships between the Company and the customer/visitor and other legal, administrative, or contractual obligations,
Evaluating complaints, requests, and suggestions for customer/visitor satisfaction,
Developing customized services and campaigns to improve the customer/visitor experience,
Determining the type of communication activities to be carried out with customers/visitors,
Resolving any potential disputes that may arise between the Company and customers/visitors in the future,
Exercising and protecting the legal rights of the Company,
Fulfilling the Company’s legal obligations,
Assessing customer/visitor satisfaction.
Such processing will be carried out in accordance with the data processing conditions specified in Articles 5 and 6 of the KVKK.
5. Transfer of Personal Data
Our Company acts in compliance with the KVKK regarding the transfer of personal data. Except for the exceptions stipulated in the law, personal and special category personal data are not transferred to other real or legal persons without the explicit consent of the data subject. In cases of legal exceptions, utmost care is taken to comply with the format and limitations prescribed by the law during such transfers.
Your personal data may be transferred to:
Authorized public institutions and organizations, and legally authorized private individuals to fulfill legal obligations,
Contracted transportation companies for airport transfer organization requested by corporate or individual customers/visitors,
Judicial authorities to ensure the execution or follow-up of legal processes,
Affiliates, subsidiaries, group partners, and international stakeholders,
Contracted data management platforms on an anonymized basis,
Business partners in the same sector or airline companies resulting from mergers, acquisitions, or demergers,
Companies operating in IT, education, electronics, finance, food, construction, culture, arts and design, media and communication, automotive, health and social services, textile and apparel, trade and retail, tourism, aviation, accommodation, food and beverage, transportation, logistics, and telecommunications sectors, as well as online service providers,
all in accordance with the procedures and principles set out in the GDPR and related regulations, and pursuant to Articles 8 and 9 of the GDPR.
6. Method and Legal Basis for Collecting Personal / Special Category Personal Data
Your personal data may be collected by our Company through various channels and methods, whether automatic or non-automatic, depending on the services provided or commercial activities, including directly via our call centers, websites, mobile applications, social media platforms, verbally, in writing, or electronically.
Your personal data shared during the contractual processes and throughout the provision of our services may be processed and updated during the term of the relevant agreements and for the legally required periods thereafter, as long as the Company has a legitimate interest in retaining such data.
The legal bases for processing your personal data are your explicit consent as per Article 5(1) of the GDPR and the circumstances listed under Article 5(2)(a), (c), (ç), (e), and (f) and Article 6(3), which set out exceptions to the need for explicit consent.
7. Rights of the Data Subject under Article 11 of the GDPR
Data subjects may contact the Company, acting as data controller, to:
Learn whether their personal data are processed,
Request information if their data have been processed,
Learn the purpose of processing and whether their data are used in line with this purpose,
Know the third parties to whom their data are transferred domestically or abroad,
Request correction if their data are incomplete or inaccurate,
Request the deletion or destruction of their data under Article 7 of the KVKK,
Request notification of these operations to third parties to whom the data have been transferred,
Object to the occurrence of any result that is to their detriment by means of analysis of processed data exclusively through automated systems,
Demand compensation for damages in case of unlawful processing.
Explicit Consent
I have read and understood the information notice prepared in accordance with Law No. 6698 on the Protection of Personal Data. I freely and explicitly consent to the processing of my personal data collected by the methods described in the notice, for the purposes and in line with the principles set out therein, including their transfer abroad when necessary, and to the retention and processing of my data for the duration required by applicable legislation or the Company’s legitimate interests following the termination of the contractual relationship.