Customer Data Protection Law Information Text

1. Introduction
Club Jolly Turizm ve Ticaret A.Ş. (“Jolly Tur”, “the Company” or “We”) takes utmost care to ensure the confidentiality of your personal data and to process your data in accordance with the Law No. 6698 on the Protection of Personal Data (“KVKK” or “the Law”) and secondary legislation while providing the products and services we offer to our guests.
In accordance with Article 10 of the KVKK (Law on Protection of Personal Data), we would like to inform you about the following matters within the scope of this Privacy Notice.
2. Identity of the Data Controller
Data controller according to KVKK (Turkish Personal Data Protection Law): Club Jolly Tourism and Trade Inc.
Contact information is provided at the end of this document.
3. How Can We Obtain Your Personal Data?
At Jolly Tur, we communicate with our guests through various channels. Your personal data may be collected entirely or partially through automated methods, or through non-automated methods as part of a data recording system.
3.1. Face-to-Face Sales Transactions
Your personal data will be processed at our company's sales offices, agencies, or other physical sales points, for example:
  • Printed or digital sales contracts and forms completed by you,
  • Your face-to-face meetings with our sales consultants,
  • Identity/passport presentation (for invoices/official transactions/ticketing, etc.),
  • POS devices and other payment instruments used in payment transactions
It can be obtained through this method.
3.2. Distance Selling Transactions
Your personal data, for example:
  • When you visit our website or register and place a reservation/order,
  • When you call our call center (including call recordings),
  • When you contact us via WhatsApp,
  • When you communicate with our customer service or staff through channels such as email/SMS,
  • When you create an address/location-based service request within the scope of services offered through our company channels (depending on the nature of the service)
can be collected.
3.3. Obtaining Through Third Parties
If your relationship with our company was established through an intermediary agency/partner/authorized sales channel, we may also obtain your personal data through these parties.
4. How long do we retain your personal data?
Your personal data will be stored for the period stipulated in the relevant legislation or for the period necessary for the purpose for which it is processed. At the end of this period, your data will be deleted, destroyed, or anonymized in accordance with the Personal Data Protection Law (KVKK). For example, in the case of commercial ledgers and documents, there may be a 10-year retention obligation according to the relevant legislation.
5. Which of your personal data do we process?
As Jolly Tur, we may process your personal data in the following data categories within the scope of the services we offer:
  • Identity and contact information: Name, surname, Turkish National Identity Number (TCKN), passport information, date of birth (for ticketing etc.), address, email, telephone/mobile phone number, other information on identity card, visa application form information, detailed population register extract.
  • Audio/visual recordings: Photograph, call center voice recordings.
  • Financial data: Payment method, payment details, (where applicable) masked card information, POS slip information, bank information for refunds, billing information, and financial records.
  • Customer transaction and reservation/order data: Reservation/order code, contract number, details of purchased product/service, transaction history; accommodation/transportation/activity purchase information related to your current or past reservations, package tour preferences and travel information; support records.
  • Request/complaint data: Written/oral requests and complaints, as well as your special requests.
  • Insurance data: Travel insurance policy information and details.
  • Occupational and demographic data: Professional information; (if you give your consent for marketing) marital status, date of marriage, information about children, etc.
  • Location data (depending on the nature of the service): Real-time/static location information (if address/location-based services are required).
  • Special categories of personal data: Personal health information, which is considered special categories of personal data, is processed to the extent necessary for organizing your or your family members' special needs during your travel/accommodation (e.g., health condition, allergies, mobility), or if you request a change or cancellation of your reservation due to illness. If health issues arise concerning your family members during your trip, you are responsible for obtaining their explicit consent to share their health information.
  • Other information: Documents explaining the reason why you were unable to attend the accommodation service or tour you purchased.
As a rule, we do not request/process your special categories of personal data. However, in cases where it is necessary for the performance of the service and you have shared it with us, we may process it based on your explicit consent in accordance with Article 6 of the KVKK (Personal Data Protection Law) and only within the limits of the purpose.
6. For what purposes and on what legal grounds do we process your personal data?
We may process your personal data in accordance with Article 5 and, where applicable, Article 6 of the KVKK (Law on Protection of Personal Data) for the following purposes:
6.1. Establishment and Performance of the Contract (KVKK Article 5/2-(c))
  • Providing products and services such as tour/hotel/transportation/activity/event tickets/insurance/visa consultancy, etc.,
  • Booking/order creation and management, operational updates (flight time changes, etc.),
  • Managing membership processes,
  • Managing return/cancellation/change processes,
  • Transactions requiring identity verification depending on the nature of the service (ticketing/reservations, etc.).
For example, we can make accommodation reservations to enable you to take your preferred package tour, manage the reservation/sales processes for activities if you purchase accommodation and activities, obtain airline tickets on your behalf, inform third parties organizing transfer/meeting processes, and provide you with necessary information regarding your trip (including operational notifications). If the processing of your sensitive personal data is necessary during the reservation process, we will process this data with your explicit consent. We may also process your data for the purpose of providing visa consultancy services upon your request.
6.2. Fulfillment of Legal Obligations and Explicit Provision in the Law (KVKK Article 5/2-(ç) and Article 5/2-(a))
  • Invoicing, maintaining accounting records, tax legislation obligations,
  • Tourism/insurance/other applicable legal obligations,
  • Responding to lawful requests from authorized public institutions / judicial authorities / law enforcement agencies / regulatory and supervisory authorities.
6.3. Legitimate Interest (KVKK Article 5/2-(f))
  • Improving product and service quality, measuring customer satisfaction, business development activities and analyses,
  • Evaluating and resolving requests and complaints; addressing problems and taking measures to prevent their recurrence.,
  • Proof in case of dispute and protection of the Company's rights,
  • Prevention of fraud/irregularities, ensuring company security and economic/legal security,
  • Execution of internal company processes (IT infrastructure management, internal audit, etc. – to the extent necessary and proportionate).
Furthermore, in cases where there is a violation of the rules or legal obligations stipulated for the services offered by our company, or when an investigation into a suspected violation is necessary, we may process your personal data in compliance with legal retention periods for the purposes of preventing fraud and protecting our rights.
6.4. Public Disclosure (KVKK Article 5/2-(d)) – To the Extent Where Appropriate
Personal data contained in feedback you publicly share on platforms such as social media may be evaluated (to the extent applicable) for the purpose of improving service quality and measuring customer satisfaction.
6.5. Special Categories of Data (KVKK Article 6) – Explicit Consent
When necessary for organizing special needs (e.g., special menu/allergy needs at the hotel, wheelchair for the flight, cancellation/change due to health reasons); based on your explicit consent and limited solely to the fulfillment of the relevant request.
7. Marketing Communications and Personalized Offers
The following activities require your explicit consent:
  • Sending commercial electronic messages: With your explicit consent, your name, surname, telephone number, and email address may be processed for campaign/promotion/marketing messages (KVKK Article 5/1).
  • Segmentation and profiling: With your explicit consent, we may process the following types of data for the purpose of planning marketing activities, conducting segmentation and profiling analyses, and providing you with personalized content/offers (KVKK Article 5/1).
For example; name and surname, gender, date of birth, marital status, phone number, email address, travel information (preferred holiday destination, amount spent, frequency of spending, number of holidays per year, preferred hotel category, information of the person making the reservation), date of marriage, information about children, occupation information.
You can withdraw your consent at any time by contacting us.
8. For what purposes and with whom may we share/transfer your personal data?
Your personal data may be shared/transferred with the following recipient groups in accordance with Articles 8 and 9 of the KVKK (Law on Protection of Personal Data) and in a limited/proportionate manner, depending on the nature of the service. We would like to emphasize that we will never share or make your personal data accessible to unauthorized third parties for our own benefit.
8.1. Business Partners / Suppliers
Accommodation and tourism service providers: Hotels, tour operators, guides, event companies, activity providers, ticket sales platforms, etc.
  • Transportation service providers: Airlines, bus companies, etc.
  • Insurance companies: Travel insurance procedures.
  • Visa processes: Relevant country diplomatic missions, authorized visa application centers, and required insurance companies.
  • Service providers for distance/online orders: Third-party suppliers who actually deliver the requested product or service (limited to identity/contact/location data depending on the nature of the service).
For international packages, our business partners to whom we transfer data for the performance of the service may be located abroad. Furthermore, in many cases, third parties to whom we transfer your personal data may process your personal data as data controllers within their own processes.
The details of the main supplier who will actually provide your service (e.g., your hotel/airline) may be included in your sales contract/attachments; you can also obtain this information by contacting our sales consultant or call center.
8.2. IT/Communications Suppliers and Operational Support
Suppliers of website management, application hosting/server services, CRM/call-center infrastructure, messaging services, fraud prevention services, etc.
8.3. Financial Institutions
Banks, payment institutions, and e-money institutions facilitate payment transactions.
8.4. Consultants and Business Partners
Lawyers for legal processes, financial advisors/auditors for financial processes (under confidentiality obligations and limited to the purpose).
8.5. Authorized Public Institutions and Organizations / Private Individuals
In case of a legal obligation or a lawful official request (court, prosecutor's office, law enforcement, tax audit, etc.).
9. Transfers within the Scope of Marketing Activities
For the purpose of sending commercial electronic communications, we may share your name, phone number, and email address with the providers from whom we receive communication services.
  • In accordance with the Regulation on Commercial Communication and Commercial Electronic Messages, we may transfer your consent information and contact data to the Message Management System (İYS) as part of our legal obligations regarding commercial message consent records.
  • Data processed for segmentation/profiling purposes may be shared with domestic/international suppliers from whom we receive application hosting and server services.
10. International Transfer and WhatsApp (Meta) Information
Due to travel packages that include international travel or the infrastructure/communication channels used, your personal data may be transferred to recipients located abroad and/or stored on servers located abroad.
Particularly in communications conducted via WhatsApp, the relevant data and service provider Meta Platforms Inc. (WhatsApp) may be processed/stored on servers located abroad. Transfers abroad are carried out in accordance with the conditions stipulated in Article 9 of the Turkish Personal Data Protection Law (KVKK).
11. Your Rights Regarding Your Personal Data and Application Procedure
According to Article 11 of the KVKK (Law on Protection of Personal Data), as a data subject you have the following rights:
  • To find out whether your personal data is being processed,
  • If it has been processed, request information about it.,
  • To learn the purpose of the processing and whether it is being used for its intended purpose.,
  • Knowing the third parties to whom it is transferred, domestically or internationally.,
  • The right to request corrections if the data is incomplete or incorrect, and to request that the corrections be notified to the third parties to whom the data was transferred.,
  • The right to request the deletion/deletion of the data if the reasons for processing no longer exist, and to request that the data be notified to the third parties to whom the data was transferred.,
  • Objecting to an unfavorable outcome resulting from analysis by automated systems.,
  • The right to claim compensation for damages incurred as a result of an unlawful act.
You can access the Jolly Tur Data Subject Application Form to submit your requests regarding your rights at the following address:
Your applications will be processed as soon as possible, and no later than 30 days, depending on their nature. Applications are generally free of charge; however, if additional costs arise, a fee may be charged according to the tariff determined by the Board.
Our Contact Information
Trade Name
Club Jolly Tourism and Trade Inc.
Address
Hikaye Street No:11 34394 Esentepe, Şişli / Istanbul
Telephone
444 0 644 or +90 212 296 50 40
Fax
+90 212 296 06 51
Registered Electronic Mail Address
clubjollyturizm@hs03.kep.tr