Passenger Rights
INFORMATION CENTER
Data Protection and Disclosure Statement
Tailwind Havayolları A.Ş. (“Tailwind”) places great importance on your privacy and data security. Pursuant to the Law no 6698 on Protection of Personal Data published in the Official Gazette no 29677 dated 07/04/2016 (the "Law") and relevant regulations, this text has been written and submitted for your review to inform and clarify as to how your personal data may be processed by Tailwind and with whom such personal data is shared.
We recommend you to view Privacy Rules when you have visit Tailwind Airlines Website. Because by using Tailwind Website, other Tailwind Communication Channels or by using or buying products or services provided by Tailwind through business partners or any other sales channel, you have accepted the conditions and terms of updated version of Tailwind Protection of Personal Data and Privacy Rules and given permission to Tailwind. Tailwind may contact directly with the passenger whom you act on behalf of about the passenger's flight and may process personal data shared about you and about the minors whom you act on behalf of when you make deals for another passenger or service user.
The Law aims to regulate the rules for processing personal data and protecting fundamental rights and freedoms of people including right to privacy and responsibilities and obligations of and other rules and principles for real and legal persons who process personal data. This statement is provided to fulfil the obligation to disclose pursuant to the Law and the "Disclosure Statement” is made available for visitors, passenger, and employees to read and review.
Processing of your personal data refers to performing all kinds of actions on or related to personal data including obtaining, recording, storing, maintaining, changing, reorganizing, disclosing, transferring, taking over, making available, classifying or preventing the use of data through wholly or partly by automated or non-automated means provided that this forms part of a data recording system.
Tailwind is the "data controller" pursuant to the Law and other regulations. Your personal data are stored, processed, updated, saved, shared with local and international third parties and processed using other means as mentioned in the Law by Tailwind Airlines in accordance with the terms mentioned herein.
Your personal data may need to be retained for the retention period as might be stipulated by law and additionally our company determines whether there are any set retention periods for your personal data and pursuant to the article 138 and articles 4 and 7 of the Turkish Criminal Code, ensures that processed personal data is retained for the retention period specified in the law if there is such a retention period or retained for a period required for the intention of processing if no retention period is specified in the law.
Your personal data is processed for purposes including but not limited to providing products and services of our company to you; performing necessary operational activities; conducting work together with relevant business units and business partners in order to suggest and provide better products and services to you; ensuring the rights of real persons; making necessary preparations to take, implement decisions; ensuring legal security of real persons with whom the company has business relations and of such business relations and similar purposes pursuant to the articles no 5 and 6 of the Law.
Your personal data may be processed by Tailwind as the Data Controller in any of the following situations without soliciting your explicit consent:
- When explicitly stipulated in law;
- Data processing must be done to protect the life or bodily integrity of someone who cannot give his/her consent due to a physical impossibility or whose content is not considered legally valid or to protect the life or bodily integrity of somebody else;
- Data processing is required provided that this is directly related with the establishment or execution of the agreement;
- Data processing must be done in order for us as the data controller to fulfil our legal obligations;
- Data has been made anonymous by the Data Owner;
- Data processing must be done in order to establish, exercise or protect a right,
- Data processing must be done for the legitimate interests of the Data Controller provided that no harm is inflicted on the basic rights and freedom of the Data Owner.
Your personal data may be processed for the following purposes;
- To contact you and others;
- To send important information on the changes in our service conditions, changes in our electronic services and other administrative information;
- To improve quality, training and security (for example related with phone calls made to our contact numbers, recorded and tracked);
- To solve complaints and to process data access and correction requests;
- To prevent detect, prevent and investigate criminal acts including fraud and money laundering and to analyse and manage other commercial risks;
- To comply with laws and regulatory obligations in force including anti-money laundering and counter terrorism laws (including those outside your country of residence) and to respond to requests from officials and governmental offices (including those outside your country of residence).
- To manage our infrastructure and commercial operations and to comply with internal policies and procedures including those that are about inspections, finance and accounting; invoicing and collections; IT systems; data and website hosting; business continuity and records; document and press management.
- To identify and defend legal rights; to protect our activities and our business partners' activities, our rights, our confidentiality, security or our property and/or to protect yours and other parties' activities, rights, confidentiality or property and to exercise available remedies or limit our loss;
- To conduct market research and analysis including satisfaction surveys.
Personal data may also be used to ensure flight safety and security pursuant to the Law no 2920 Turkish Civil Aviation Law; to protect the life and property of Tailwind personnel, vendors of Tailwind and their personnel and Tailwind's guests or to facilitate the travel of air passengers including compliance with rules mentioned in this article or to make safety and risk assessments, to comply with legal requirements or requests of the Directorate General of Civil Aviation and other authorities.
Your personal data may be shared with our business partners to ensure legal and commercial security of Tailwind and third parties which have business relations with Tailwind; to perform activities necessary to provide you the products and services of our company; to customize and offer our company's products and services according to your preferences, habits and needs; with local and international aviation authorities in accordance with air transport rules, with administrative authorities in order to fulfil our obligations as set forth in legal regulations and to ensure public and flight safety and with other legal or real persons in compliance with legal requirements and with our suppliers, shareholders and authorized government department and agencies in compliance with the personal data processing rules and purposes as stipulated in the article 8 and 9 of the Law.
Personal Data Collection Means, Cause of Action and Protection
Your personal data is collected by Tailwind Airlines through various channels and based on different legal reasons in order to conduct our commercial operations. Your personal data collected may be processed and shared for the purposes mentioned in this statement in accordance with the personal data processing provisions set forth in the article 5 and 6 of the Law.
Technical security measures have been taken to protect personal data and sufficient protection level has been achieved against potential risks. Main technical measures are listed below.
- Entry to buildings and structures where our company keeps/stores personal data are kept under surveillance and monitored on a 24/ basis.
- Our company performs regular access and authorization checks on the systems that allow access to personal data.
- Technical measures taken are also checked under risk management, internal control and internal audit processes.
- Personnel with sufficient expertise are employed.
If you send your request to exercise your rights using the below mentioned methods to our company as the owner of personal data, your request will be processed free of charge within the shortest time possible, in any case no later than thirty days. However if the Personal Data Protection Board determines a fee, our company will apply that fee. In this process, personal data owners;
Learn whether personal data has been processed; and if processed, request information about it; learn the purpose of processing their personal data and whether it is used for the intended purpose,
Have information about third parties in the country and abroad with whom their personal data has been shared,
Request correction/amendment if their personal data is processed incorrectly or incompletely and that such correction/amendment is informed to the third parties with whom their personal data has been shared,
Request that their personal data is deleted or removed despite being processed in accordance with the Law and other applicable regulations if the reasons for their data to be processed no longer exist and that these actions are informed to the third parties with whom their personal data has been shared,
Object to any unfavourable outcome for them due to the reason that their processed data is analysed solely by automated systems,
Claim damages in the event that they incur losses due to the reason that their personal data is processed illegally.
Pursuant to the paragraph 1 of the article 13 of the Law, you can send your request to exercise your above mentioned rights to our company in writing or using other means as specified by the Personal Data Protection Board. The Personal Data Protection Board has not yet determined a means therefore you need to send your application in writing to our company pursuant to the Law. The channels through which you can send your written application pursuant to the article 11 of the Personal Data Protection Law and the procedure for this are explained below.
You have the right to apply to our company to : (a) Learn whether your personal data has been processed, (b) If yes, request information about how your personal data is processed, (c) Learn the purpose of processing your personal data and whether it is used for the intended purpose, (d) Learn local and international third parties with which your personal data is shared and learn the technique and administrative measures to share with international third parties, (e) Request for correction if your personal data is incomplete or incorrectly processed, (f) Request deletion or anonymization of personal data provided that reasons to process personal data are no longer applicable, request that the operations mentioned in the paragraphs (g) (e) and (f) are informed to the third parties with whom your personal data is shared, (h) Object to any result disadvantageous for you when your personal data is analyzed by automated systems. You can send your written and signed requests on this matter to the Personal Data Protection Manager at the Headquarters at Yeşilköy Mah. Atatürk Cad. DTM Sitesi A2 Blok Apt. No: 10/395 34149 Bakırköy Istanbul/Turkey or using the "contact us" field on our website tailwind.com.tr or via other contact channels mentioned here.
You can request to exercise your rights specified in the article 11 of the Personal Data Protection Law together with your identity information by filling out the form at www.tailwind.com.tr explaining the rights for which you are making the request, sending a signed copy of the form to Yeşilköy Mah. Atatürk Cad. DTM Sitesi A2 Blok Apt. No: 10/395 34149 Bakırköy Istanbul or send through a notary or by using other means specified in the Law or emailing electronically signed form to tailwindhavayollari@hs01.kep.tr.
Data Controller: Tailwind Havayolları A.Ş.
Address : Yeşilköy Mah. Atatürk Cad. DTM Sitesi A2 Blok Apt. No: 10/395 34149
Bakırköy Istanbul
CONSENT
You can withdraw your consent about processing your personal data anytime. Withdrawal of consent is effective for future processing and does not invalidate the legal basis for past processing of data.