Last update: 09 December 2022
1. GENERAL INFORMATION 1
2. WHAT DATA DO WE COLLECT? 2
3. HOW LONG DO WE STORE YOUR DATA? 4
4. HOW DO WE DISCLOSE YOUR DATA? 5
5. HOW DO WE PROTECT YOUR DATA? 6
6. HOW CAN YOU MANAGE YOUR PERSONAL DATA? 6
7. CONTACT 7
1.3 Owner of TurkeyVisas (data controller). TurkeyVisas is owned and operated by YOYO TRAVELS having a registered place of business at Office 601, Floor 6, Al Habtoor Business Tower, P.O.Box 212089, Dubai, The United Arab Emirates, and the license no. 916968 (“we,” “us,” and “our”).
1.4 About TurkeyVisas. TurkeyVisas provides information about obtaining visas in Turkey and facilitates the online visa application process. If the functionality of TurkeyVisas permits, TurkeyVisas may also offer hotel booking, airline ticketing, and holiday packages for travellers to Turkey.
1.5 Children. TurkeyVisas is not intended for use by persons under the age of 18. We do not knowingly collect personal data belonging to persons younger than 18 through TurkeyVisas. If you become aware that such a person has provided us with his or her personal data and you are a parent or a legal guardian of that person, please contact us immediately and we will remove the child’s personal data from our systems. Parents or legal guardians of minors may use TurkeyVisas for obtaining visas for minors. However, we do not conclude any service contracts with minors.
In this section, we explain in detail what personal data we collect from you, for what purposes we use it, what technical data is collected automatically when you use TurkeyVisas, and how we communicate with you.
2.1 Sources of personal data. We obtain your personal data from the following categories of sources:
Directly from you. For example, if you submit your personal data when you complete our online application form or contact us;
Directly or indirectly through your activity on TurkeyVisas. When you use TurkeyVisas, we automatically collect technical information about your use of TurkeyVisas by means of cookies and analytics services; and
From third parties. We may receive information about you from third parties to whom you have previously provided your personal data, if those third parties have a legal basis for disclosing your personal data to us (for example, for payment processing purposes).
Online Application Form. When you complete our registration form, we collect your country, type of travel document, arrival date, information about your trip, information about supporting documents (visas and residence permits), passport details (number, expiry date, issue date), full name, date of birth, place of birth, email address, phone number, and address. We use the said information to process your visa application, enable you to access and use TurkeyVisas, provide you with the requested services, contact you, if necessary, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you’ and ’pursuing our legitimate interests’ (i.e., operate, analyze, grow, protect, and administer TurkeyVisas). We will store this data until your application is processed, unless we are required by law to keep some records longer.
Orders and Payments. When you place an order on TurkeyVisas and make a payment, we collect your personal data, such as your full name, billing address, payment details (e.g., credit card number, CVV code, expiration month and year, or PayPal details), and other data that is relevant to your order (for example, the dates of your trip and the city where you stay). Your payment data is used to process payments and maintain our accounting records. Your order data is used to process your orders. The legal bases on which we rely are ‘performing our contractual obligations’ and ‘pursuing our legitimate interests’ (i.e., to administer and protect our business). We keep a part of your payment data that is provided to us by our payment processor for the time period prescribed by law (in Turkey, accounting records must be kept for 10 years).
Your credit/debit cards’ details and personal data will NOT be stored, sold, shared, rented or leased to any third parties. We will not pass your debit/credit card details to third parties.
Enquiries. When you contact us by email or by using the contact form available on TurkeyVisas, we collect your first name, last name, email address, phone number, and any information that you decide to include in your message. We use such data to respond to your enquiries and provide you with the requested information. The legal bases on which we rely are ‘pursuing our legitimate interests’ (i.e., to grow and promote TurkeyVisas) and ‘your consent’ (for optional personal data). We will store this data until you stop communicating with us.
2.4 Sensitive data. We do not collect or have access to any special categories of personal data (“sensitive data”) from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data refers to your health, religious and political beliefs, racial origins, membership of a professional or trade association, or sexual orientation.
2.5 Refusal to provide personal data. If you refuse to provide us with your personal data when we ask for it, we may not be able to perform the requested operation and you may not be able to use our services, receive the requested information, or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.
2.6 Collection of analytics data. When you browse TurkeyVisas, we collect certain technical analytics data collected from you. Such data includes the following information:
URL addresses from which you access TurkeyVisas;
Your device type;
Your operating system;
Your browser name and version;
Geolocation data; and
Your other online behavior.
2.7 Purposes of analytics data. We use your analytics data to analyze what kind of users access and use TurkeyVisas, measure your engagement with TurkeyVisas, see which parts of TurkeyVisas are interesting to you, what products you buy, improve our content, develop new products and services, and investigate and prevent security issues and abuse. In most cases, such analytics data is non-personal and it does not allow us to identify you as a natural person. However, some of such data like your IP address may be considered personal data and we will make sure that we have the necessary legal basis for processing such data. When we process your analytics data that is personal data, we rely on the ‘legitimate interest’ (i.e., to analyze, improve, and protect TurkeyVisas) and ‘your consent’ bases.
2.8 Your feedback. If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and the response. Where possible, we will de-identify your personal data (i.e., we will remove all personal data that is not necessary for keeping such records).
2.9 Aggregate and de-identified data. In case your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will handle such aggregate data as personal data. If your personal data is aggregated or de-identified in a way that it can no longer be associated with an identified or identifiable natural person, it will not be considered personal data and we may use it for any legitimate purpose.
2.10 Newsletters. If you opt-in for our newsletter, subscribe to our newsletter, or conclude a service contract with us, we will inform you about our new services, features of TurkeyVisas, and special offers. The legal bases on which we rely is ‘your consent’ (if you opt-in) and ‘pursuing our legitimate business interests’ (i.e., promoting TurkeyVisas). You can opt-out from receiving our commercial communication at any time free of charge by clicking on the “unsubscribe” link included in our newsletters or by contacting us directly.
2.11 Transactional notices. If we have your email address and it is necessary to do so, we may send you important informational messages, such as order confirmations and updates, requests for more information, payment receipts, invoices, and other technical or administrative emails. Please note that such messages are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior consent. You cannot opt-out from service-related notices.
3. HOW LONG DO WE STORE YOUR DATA?
In this section, we explain for how long we keep your data in our systems and how we delete it.
3.3 Storage as required by law. When we are obliged by law to store your personal data for a certain period of time (e.g., for keeping accounting records), we will store your personal data for the time period stipulated by the applicable law and delete the personal data as soon as the required retention period expires.
4. HOW DO WE DISCLOSE YOUR DATA?
In this section, you can find information about third parties that may have access to your personal data.
4.1 Disclosure to data processors. We keep your personal data in strict confidentiality. However, if necessary for the intended purpose of your personal data, we will disclose your personal data to entities that provide services on our behalf (our data processors). Your personal data may be shared with entities that provide technical support services to us, such as hosting, payment processing, and email distribution services. We do not sell your personal data to third parties and do not intend to do so in the future. The disclosure of your personal data is limited to the situations when it is required for the following purposes:
Ensuring the proper operation of TurkeyVisas;
Delivering you the requested services;
Processing your payments;
Responding to your enquiries;
Pursuing our legitimate interests;
Enforcing our rights, preventing fraud, and security purposes;
Carrying out our contractual obligations;
Law enforcement purposes; or
If you provide your prior consent to such a disclosure.
The Turkey governmental authorities that issue visas;
Our payment service provider Stripe located in the USA;
Our analytics and marketing service providers Google, Facebook, Snapchat, Instagram, and Twitter located in the United States; and
Our independent contractors and consultants.
4.3 International transfers. Some of our data processors may be based outside the country where you reside.For example, if you reside in the UK or a country belonging to the European Economic Area (EEA), we may need to transfer your personal data outside the UK or the EEA. In case it is necessary to make such a transfer, we will make sure that the country in which our data processor is located guarantees an adequate level of protection for your personal data or we conclude an agreement with it that ensures such protection (e.g., a data processing agreement based pre-approved Standard Contractual Clauses).
4.4 Disclosure of non-personal data. Your non-personal data may be disclosed to third parties for any purpose as it does not identify you as a natural person. For example, we may share it with prospects or partners for business or research purposes, for improving TurkeyVisas, responding to lawful requests from public authorities or developing new products and services.
4.5 Legal requests. If requested by a public authority, we will disclose information about the users of TurkeyVisas to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.
5. HOW DO WE PROTECT YOUR DATA?
Here you can find information on how we protect your data against breaches.
5.1 Security measures. We implement technical and organizational information security measures that protect your personal data from loss, misuse, unauthorized access and disclosure. We take appropriate steps to ensure data privacy and security including through various hardware and software methodologies. However, TurkeyVisas cannot guarantee the security of any information that is disclosed online. The security measures taken by us include proper authentication, secured networks, strong passwords, limited access to your personal data by our staff, anonymisation of personal data (when possible), limitation of login attempts, and carefully selected data processors.
5.2 Security breaches. Although we put our best efforts to protect your personal data, given the nature of communication and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law.
6. HOW CAN YOU MANAGE YOUR PERSONAL DATA?
Here you can find detailed information about the rights that you have with regard to your personal data and how to exercise those rights.
6.1 The list of your rights. You have the right to control how we process your personal data.Subject to any exemptions provided by law, you have the following rights:
Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed;
Right to rectification: you can rectify inaccurate personal data that we hold about you;
Right to erasure (‘right to be forgotten’): you can ask us to erase your personal data from our systems;
Right to restriction: you can ask us to restrict the processing of your personal data;
Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal data to another processor;
Right to object: you can ask us to stop processing your personal data;
Right to withdraw consent: you have the right to withdraw your consent, if you have provided one; or
Right to complaint: you can submit your complaint regarding our processing of your personal data.
6.3 Complaints. If you would like to launch a complaint about the way in which we handle your personal data, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible (no later than 30 days). If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
Email: [email protected]
Phone number: +971 52 335 5222
Postal address: YOYO TRAVELS, Office 601, Floor 6, Al Habtoor Business Tower, P.O.Box 212089, Dubai, The United Arab Emirates.