A. Providing information as a responsibility to be fulfilled by the data controller 

CAMELOT AIR TRAVEL TOURISM AND TRADE JOINT STOCK COMPANY (“CAMELOT”), we regard the safety of your personal data as a topic to be approached with maximum sensitivity. Your personal data is processed and stored in accordance with the Personal Data Protection Law numbered 6698 (hereinafter to be referred to as “PDPL”). PDPL was published in the Official Gazette dated 07.04.2016 and Issue No. 29677. PDPL was drafted to protect the fundamental rights and obligations of the natural persons whose data is processed, including the right of privacy, which is protected under our Constitution and Turkish Criminal Law, and to determine the obligations of the natural and legal persons who process personal data.

 

Our purpose in issuing our policy on the protection and processing of personal data (“PDP Policy”) is to develop the management instructions and procedural conditions required for the processing and protection of personal data belonging to CAMELOT in accordance with PDPL.

 

Pursuant to PDPL, your personal data will be collected and processed by us, acting in the capacity of data controller. At CAMELOT, we will record, store and update your personal data in the manner explained on this page, pursuant to PDPL and in line with our duties as data controller, and disclose the same to 3rd persons to the extent allowed under the applicable legislation, and we will also classify and process your personal data using the methods defined in PDPL.

Definitions

B.        FOR WHAT PURPOSES IS YOUR PERSONAL DATA PROCESSED? 

Pursuant to article 4 and 10 of PDPL, the below table gives the categories, types and justification for the personal data that is processed.

Pursuant to PDPL, the personal data you shared with CAMELOT will be processed by us partially or totally, and by automated means or non-automated means, provided it is part of a data recording system, and we will collect, record, store, alter, adapt your personal data, and perform any other procedure on the same. Your personal data may be collected in a written/physical or electronic environment when you buy products and services from CAMELOT and participate in training sessions and activities or use CAMELOT services, login/apply to advertisements or marketing announcements, become a member or are registered, and through cookies. 

As data controller, CAMELOT will process your personal data by taking all technical and administrative measures that may be needed 

within the limits laid out in the personal data protection legislation, including specifically the Constitution of the Republic of Turkey, international conventions to which our country is party and Law No. 6698 on the Protection of Personal Data, and in line with the following principles set forth under article 4 of PDPL:

Being in conformity with the law and good faith;

Being accurate and, if necessary, up to date;

Being processed for specified, explicit, and legitimate purposes;

Being relevant, limited and proportionate to the purposes for which data is processed;

Being stored only for the time designated by relevant legislation or necessitated by the purposes for which data is collected.

C. Legal Basis for the Collection and Processing of Personal Data

Pursuant to PDPL, the personal data you shared with CAMELOT will be processed by us partially or totally, and by automated means or non-automated means, provided it is part of a data recording system, and we will collect, record, store, alter, adapt your personal data, and perform any other procedure on the same. Any procedure performed on the data pursuant to PDPL will be deemed “personal data processing”. 

CAMELOT may collect and process data about its users through web pages and call centers for the following purposes:

•           To collect personal information in order to enable interaction through our web page,

•           To provide personalized services to our customers and increase user satisfaction by providing a better user experience,

·     To contact our customers and inform them of our services and campaigns to the extent they have consented,

•           To provide contractual services,

·   To send bulletins, promotions or notifications via email,

•           To run promotions and send notifications via SMS,

•           To respond to your calls and provide you with needed support,

•           To develop our practices in the R&D phase and market products during the management process,

•           To process complaints as per your request or complaints made on social media, or any other complaint raised about our services,

•           To conduct various statistical assessments, create databases, and to use in market research without disclosing the identity of the user.

 

Personal data collection activity carried out by CAMELOT is based on the following reasons pursuant to the 2nd paragraph of article 5 of PDPL:

• Where it is obligatory for our Company to fulfill its legal obligation,
• Where it is obligatory in connection with the legitimate interests of CAMELOT provided that your fundamental rights and freedoms are not breached,
• In situations expressly prescribed by the law,
• Personal data belonging to the parties of a contract may be processed in case it is necessary, provided it is directly related to the conclusion or performance of said contract.

D.        TO WHOM IS YOUR PERSONAL DATA TRANSFERRED?

After acceptance of the Personal Data Protection Policy, you are deemed to have granted consent to the collection, storage, processing, utilization and transfer of your personal data, for which you have granted your explicit consent to share with CAMELOT and the business partners of CAMELOT both in and outside the country, and with its employees and third persons with whom CAMELOT cooperates in connection with the applications and services of CAMELOT. In addition, your personal data will be shared with third persons with whom we are in a contractual relationship, who have assumed the same responsibilities like us in legal and technical terms regarding the protection and safety of data, and who comply with the provisions of the applicable legislation, only if such sharing is necessary and to the extent required in order to provide you with better services, and properly and in a timely manner deliver all notices to you via phone, SMS and/or email. 

CAMELOT may share your website visit or membership data or your traffic details when you are navigating with the public establishments and authorities legally entitled to request such data in order to ensure your safety and in order for CAMELOT to fulfill its legal obligations (when it is legally or administratively required to notify or provide information in certain cases, including but not limited to fighting crime and threats to national or public security).

E.        WHAT ARE YOUR RIGHTS IN REGARD TO YOUR PERSONAL DATA?

Regarding your personal data, you are entitled to;

The provision in article 11 of PDPL numbered 6698 Came into force on 07.10.2016, and pursuant to this article, the rights of the Relevant Person after this date will be as follows:

Relevant Person may apply to CAMELOT in order to: 

1. Find out whether or not their personal data is being processed, 
2. Request information on the procedure if personal data has been processed,
3. Obtain information on the purpose of processing personal data, and whether or not it has been used in line with these purposes,
4. Obtain information about the third persons to whom personal data has been communicated domestically or abroad,
5. Request the correction of personal data that may have been incompletely or inaccurately processed,
6. Request the deletion or destruction of personal data within the scope of the provisions set forth in article 7 of the Law,
7.  In case of correction, deletion or destruction of personal data, to request that such operations be reported to third parties to whom such personal data has been transferred,
8.  Object to the emergence of an outcome that is to the detriment of the data subject as a result of the analysis of data processed exclusively through automated systems,
9.  Request compensation for damages in the event that damage is sustained as a result of the unlawful processing of personal data.
   
    

F. APPLICATION REGARDING YOUR PERSONAL DATA AND HOW TO APPLY

CAMELOT Management Lojistik Anonim Şirketi, acting as data controller, pursuing its activities in accordance with PDPL and residing at Kocatepe Mahallesi Aydede Cad. Koray Apartmanı Apt. No: 16/9 Beyoğlu/İstanbul/Turkey, Mersis Number 0103026915800016, mail address info@CAMELOTglobe.com and phone number (0212) 237 24 20 respects the rights of our valuable data subjects and makes its best efforts to fulfill your requests indicated in your application.  The right to apply to our company with this form prepared as per article 11 of PDPL directly belongs to the personal data owner. In the case of applications made on behalf of third persons, a proper power of attorney, including power to represent the relevant person, must be presented. 

EXPLICIT CONSENT