PRIVACY POLICY


PRIVACY POLICY

Last update: 23 March 2022


This privacy policy explains in detail how we collect, use, and disclose your personal data. It also informs you about the choices that you have with respect to your personal data. Please read this privacy policy carefully before submitting your personal data to us.



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. GENERAL INFORMATION

In this section, we provide you with general information about us, TurkeyVisas, and this Privacy Policy.


1.1 About the Privacy Policy. This privacy policy (the “Privacy Policy”) governs the processing of personal data collected from individual users (“you” and “your”) through the website https://turkeyvisas.com, the related domain names, software and services (collectively, “TurkeyVisas”).

1.2 Third-party websites. The Privacy Policy does not cover any third-party websites, applications or software that integrate with TurkeyVisas or any other third-party products and services. We are not responsible for the privacy policies of websites to which TurkeyVisa links. If you provide any information to such third parties different rules regarding the collection and use of your personal data may apply. You should contact these entities directly if you have any questions about their use of the data that they collect.

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.

1.6 Term and termination. This Privacy Policy enters into force on the effective date indicated at the top of the Privacy Policy and remains valid until terminated or updated by us.

1.7 Amendments. This Privacy Policy can be changed or updated occasionally to meet the requirements and standards. Therefore, you are encouraged to frequently visit this page to be updated about the changes on TurkeyVisas. Modifications will be effective on the day they are posted. The amended version of the Privacy Policy will be posted on this page and, if we have your email address, we will send you a notice about all the changes implemented by us. For significant material changes in the Privacy Policy or, where required by the applicable law, we may seek your consent.


2. WHAT DATA DO WE COLLECT?

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:

2.2 Collection of personal data. We comply with data minimisation principles. This means that we collect only a minimal amount of personal data that is necessary for your use of TurkeyVisas. We use your personal data for limited, specified and legitimate purposes explicitly mentioned in this Privacy Policy. For example, we use it only for the purposes of providing you with access to TurkeyVisas, processing your applications, maintaining and improving TurkeyVisas, replying to your enquiries, and pursuing our legitimate interests. We do not repurpose your personal data. This means that we do not use it for any purposes that are different from the purposes for which your personal data was provided. Below, you can find an overview of the types of personal data that we collect, the purposes for which we use it, and the legal bases on which we rely when processing it.

2.3 Cookies and other tracking technologies. When you browse TurkeyVisas, we collect your cookie-related data and use other tracking technologies. We use such information to analyze the technical aspects of your use of TurkeyVisas, conduct our marketing campaigns, prevent fraud and abuse, and ensure the security of TurkeyVisas. For more information on our use of cookies and other tracking technologies, please refer to our Cookie Policy. The legal bases on which we rely are ‘pursuing our legitimate interests’ (i.e., analyze our content and protect TurkeyVisas) and ‘your consent’. We will store this data as long as analytics records are necessary for our activities or you withdraw your consent.

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:

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.


3.1 Storage of personal data. We and our data processors store your personal data only for as long as such personal data is required for the purposes described in this Privacy Policy or until you request us to update or delete your personal data, whichever comes first. For more details about the period for which each type of personal data is stored, please refer to section 2.2. After your personal data is no longer necessary for its purposes and there is no other legal basis for storing it, we will immediately securely delete your personal data from our systems. We do not store any personal data longer than strictly necessary.

3.2 Storage of non-personal data. We retain non-personal data pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include storing non-personal data for the period of time needed for us to examine our activities, fulfil our contractual obligations, pursue our legitimate interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

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:

4.2 List of data processors. We choose our data processors carefully and make sure that they ensure an adequate level of protection of personal data that is consistent with this Privacy Policy and the applicable data protection laws. The data processors that will have access to your personal data are:

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:

6.2 How to exercise your rights? If you would like to exercise any of your legitimate rights, please contact us by using our contact details available at the end of the Privacy Policy and explain in detail your request. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information, so that we can identify you in our system. We will answer your request within a reasonable time frame but no later than 30 days.

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.


7. CONTACT

If you have any questions about this Privacy Policy, your rights, or our data protection practices, please contact us by using the following contact details:

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.



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