Clarification Text on the Protection and Processing of Personal Data

As STH TURİZM ORG. VE DAN. LTD. ŞTİ ("Company"), we show maximum sensitivity to the security of your personal data. With this awareness, we attach great importance to the processing and preservation of all personal data belonging to persons associated with the Company, including those who benefit from our products and services, in accordance with the Law on the Protection of Personal Data No. 6698 ("KVKK" or "Law").

1. Data Controller and Representative

In accordance with the Law, your personal data; as the data controller, can be collected and processed by our Company within the scope described below.

2. Purpose of Processing Personal Data

Our Company mainly operates in the fields of Flight Ticketing, Visa Consultancy, and Event Management. Your collected personal data is processed for the following purposes:

  • Flight Ticketing and Travel Management: Issuing domestic and international flight tickets, reservation changes, creating PNR (Passenger Name Record), processing frequent flyer (mile) programs and making necessary information sharing with airline companies.
  • Visa Consultancy Procedures: Preparing visa application files requested by consulates and intermediary institutions, creating appointments, filling out application forms and following up the process.
  • Event and Organization Management: Creating participant registrations (RSVP) in meetings, congresses, launches or corporate events, badge printing, providing event security and keeping visual/auditory records (photos and videos) during the event.
  • Legal and Commercial Security: Fulfilling obligations arising from relevant legislation, especially the Law on the Union of Travel Agencies No. 1618 and the Tax Procedure Law, billing processes and notifying authorized institutions (e.g., General Directorate of Security, TÜRSAB).

3. Categories of Personal Data Processed and Special Quality Data

Our Company processes data in the following categories depending on its fields of activity:

  • Identity Information: Name, surname, T.R. identity number, passport number/photocopy, date of birth.
  • Contact Information: E-mail address, phone number, address, in-house title.
  • Financial Information: Credit card information (for collection purposes), bank account information, payroll, bank statements and asset information required for visa procedures.
  • Customer Transaction Information: Flight details, PNR codes, accommodation preferences, request and complaint information.
  • Visual and Auditory Records: Photos/videos taken at events, biometric photos provided for visa procedures.
  • Special Quality Personal Data:
    • Within the Scope of Visa Consultancy: Health data (travel health insurance, vaccination card, etc.), biometric data (fingerprint, etc.), criminal record records and if any, association/foundation membership information requested by the visa application requirements of the relevant country's consulates.

Important Note: Your special quality personal data is processed only within the conditions specified in Article 6 of the Law and when it is mandatory for the relevant process (visa application), based on your explicit consent.

4. To Whom and For What Purpose the Processed Personal Data Can Be Transferred

Your collected personal data; for the realization of the purposes mentioned above, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law, can be transferred to the following parties:

  • Domestic Transfer: To our business partners, suppliers (hotel, transfer company, event venues), legally authorized public institutions (Police, Tax Offices) and authorized private persons.
  • International Transfer: Due to the nature of Flight Ticketing and Visa Consultancy services, which is our Company's field of activity;
    • To relevant Foreign Airline Companies and Global Distribution Systems (GDS) so that your flight ticket can be issued,
    • To accommodation facilities abroad so that your hotel reservation can be made,
    • To the Consulates, Embassies and authorized visa intermediary institutions of the relevant country so that your visa application can be processed.

5. Method and Legal Reason for Collecting Personal Data

Your personal data is collected by our Company through our website, e-mail, telephone, mobile applications, physical forms (visa application forms, hotel registration forms) and face-to-face interviews.

This data is collected based on the following legal reasons specified in Articles 5 and 6 of KVKK:

  • Performance of the Contract: When data processing is necessary for the establishment and performance of flight ticket, hotel reservation or event participation contract.
  • Legal Obligation: For our Company to fulfill its legal obligations (e.g., billing, Identity Reporting Law).
  • Explicit Consent: In cases of processing special quality personal data (Visa processes) and sending commercial electronic messages.
  • Legitimate Interest: When data processing is mandatory for the legitimate interests of our Company, provided that it does not harm your fundamental rights and freedoms.

6. Rights of the Personal Data Subject (Article 11)

As personal data subjects, you have the following rights under Article 11 of the Law:

  • Learning whether personal data is processed or not,
  • Requesting information if personal data has been processed,
  • Learning the purpose of processing personal data and whether they are used in accordance with their purpose,
  • Knowing the third parties in the country or abroad,
  • Requesting correction if personal data is processed incompletely or incorrectly,
  • Requesting deletion or destruction,
  • Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,
  • Requesting compensation for the damage if personal data is damaged due to illegal processing.

To exercise these rights, you can forward your requests to the address of Balmumcu Mahallesi, Bestekar Şevki Bey Sokak No:13/2 Beşiktaş/İstanbul or to info@sthteam.com.