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Protection of Personal Data and Privacy Policy

Website Confidentiality Agreement
How to use and protect the information we obtain about you and the services you request while you visit this website and benefit from the services we provide through this site are subject to the conditions set forth in this "Privacy Policy". By visiting this website and requesting to benefit from the services we offer through this website, you accept the terms set forth in this "Privacy Policy".

I. Purpose of personal data protection and processing policy
Troy-Kale Turizm Insaat Taah. Tic LTD, the data received from our customers or prospective customers have been kept confidential and never shared with third parties due to the sensitivity of the work we have been dealing with. Protection of personal data is the basic policy of our company. Even before there was any legal regulation, our companies and affiliates attached great importance to the privacy of personal data and adopted this as a working principle and gave their employees working instructions in line with this principle. As "Northwest Tour", we undertake to comply with all responsibilities brought by the Law on the Protection of Personal Data. The principles of our companies regarding the protection of personal data also cover our subsidiaries.

II. Scope and modification of the personal data protection and processing policy
This Policy, prepared by our company, has been prepared in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”). The law has entered into force with all its provisions as of today. The data obtained from you with your consent or in accordance with other laws listed in the Law will be used to improve the quality of the services we provide, to improve the services offered to you and our quality policy. Again, some of the data we have is depersonalized and anonymized. These data are data used for statistical purposes and are not subject to Law enforcement and our Policy. “Northwest Tour Personal Data Protection and Processing Policy” aims to protect the automatically obtained data of our customers, prospective customers, employees, customers and employees of companies working in solution partnership with us, or other persons, and includes regulations regarding these. Our company has the right to change our policy and our Regulations, provided that they comply with the law and that personal data is better protected.

III. Basic rules regarding the processing of personal data
a) Compliance with the law and the rules of honesty: “Northwest Tour” questions the source of the data it collects or receives from other companies and attaches importance to obtaining them in accordance with the law and within the framework of honesty rules. In this context, it makes necessary warnings and notifications to third parties (agencies and other intermediary institutions) that sell the services offered by "Northwest Tour" in order to protect personal data.
b) Being accurate and up-to-date when necessary: ​​“ Northwest Tour” attaches importance to the fact that all data within the institution are correct, not contain false information, and finally, if there is a change in personal data, they are updated if they are communicated to it.
c) Processing for specific, clear and legitimate purposes: “Northwest Tour” processes data only for the purposes it offers and for which it receives approval from individuals during the service. It does not process, use and make use of data other than for business purposes.
d) Being connected, limited and measured for the purpose for which they are processed: “Northwest Tour” only uses the data for the purpose for which they are processed and to the extent required by the service.
e) Retention for the period stipulated in the relevant legislation or required for the purpose for which they are processed: “Northwest Tour” preserves the contractual data within its body as long as the conflict periods of the Law and the requirements of commercial and tax law. However, when these purposes disappear, it deletes or anonymizes the data.

It should be emphasized that, whether "Northwest Tour" has collected or processed the data with consent or in accordance with the law, these principles listed above still apply.

Maximum Savings Policy/Stinginess Policy
According to this policy, which is called the principle of maximum savings or the principle of stinginess, the data reaching "Northwest Tour" is processed into the system only as necessary. Therefore, which data we collect is determined by the purpose. Unnecessary data is not collected. Other data transmitted to our company are transferred to company information systems in the same way. Redundant information is not recorded in the system, deleted or anonymized. These data can be used for statistical purposes. Health data, which is one of the special quality data, is taken only in order to provide better service to customers and protect their health and is kept in the system with care.

Deletion of personal data
Personal data is deleted, destroyed or anonymized by our company, automatically or upon the request of the person concerned, when the periods required to be kept by law, the completion of the judicial processes or other requirements are eliminated.

Accuracy and data timeliness
As a rule, the data within the body of "Northwest Tour" are processed as declared by the relevant persons. "Northwest Tour" is not obliged to investigate the accuracy of the data declared by customers or people who contacted "Northwest Tour", and this is not done legally and due to our working principles. The declared data is considered correct. The principle of accuracy and timeliness of personal data has also been adopted by "Northwest Tour". It updates the personal data that our company has processed from the official documents it receives or upon the request of the person concerned. It takes the necessary measures for this.

Privacy and data security
Personal data is confidential and “Northwest Tour” also abides by this confidentiality. Only authorized persons can access personal data within the company. All necessary technical and administrative measures are taken to protect the personal data collected by "Northwest Tour", to prevent it from falling into the hands of unauthorized persons and to prevent our customers and prospective customers from becoming victims. In this framework, it is ensured that the software complies with the standards, that the third parties are carefully selected and that the data protection policy is complied with within the company.

IV. Data processing purposes
The collection and processing of personal data by "Northwest Tour" will be carried out in line with the purposes specified in the clarification text. Data is collected and processed for the purpose of establishing the contract and providing better service to customers.

V. Customer, prospective customer and business and solution partners data
As "Northwest Tour", we process your personal data as a data controller within the scope of the Law on Protection of Personal Data No. 6698 and other relevant legislation. The categories and explanations of personal data to be processed in this context are as follows:

- Identity Information: Name-surname, name-surname of accompanying guest/guests, nationality, place and date of birth; TR ID, driver's license and passport numbers (including the date and place of issue).
- Contact Information: Address, phone number, e-mail address.
- Financial Information: Mobile billing information, bank account information, payment card number and other payment information, Loyalty Program memberships, information about purchased products or services.

Collection and processing of data for contractual relationship
If a contractual relationship is established with our customers and prospective customers, the collected personal data can be used without the customer's consent. However, this use takes place in line with the purpose of the contract. The data is used to the extent of better execution of the contract and the requirements of the service and updated when necessary by contacting the customers. On the other hand, the data left to us by our prospective customers (prospective customers) are processed in order to provide them with an easier and higher quality service afterwards. If this data has not turned into a contractual relationship upon request, it will be deleted.

Business and Business Partners Data
“Northwest Tour” adopts the principle of acting in accordance with the law when sharing data with both business and solution partners. Data is shared with business and solution partners with the commitment of data confidentiality and only as much as the service requires, and these parties are compelled to take measures to ensure data security.

E-invoice & E-Archive Invoice
Within the scope of this program; The customer is automatically registered in the system and an invoice is sent via e-mail to the facility. It is the customer's responsibility to ensure that the e-mail address given at the entrance to the facility or updated by applying afterwards is correct and is the preferred e-mail address for this communication. If a reservation is made for another family member or persons using this e-mail address, the e-invoice of the relevant invoice will be sent to the e-mail owner's address.

E-Archive Invoice is an application that allows the invoice, which has to be prepared, preserved and submitted in paper form in accordance with the Tax Procedure Law, to be prepared electronically in accordance with the conditions in the General Communiqué of the Tax Procedure Law no. All invoices in the e-Archive Invoice, except the invoices created for the taxpayers registered in the e-Invoice Application, are called e-Archive Invoice.

Advertising data processing
About Regulation of E-Commerce. About Commercial Communication and Commercial Electronic Messages by Law. In accordance with the regulation, e-mails for advertising purposes can only be sent to people with prior approval. The explicit consent of the person to whom the advertisement is sent is required. Again, "Northwest Tour" complies with the details of the "approval" determined in accordance with the same legislation. The approval to be obtained should cover all commercial electronic messages sent to the electronic communication addresses of the recipients in order to promote your company's goods and services, market it, promote its business or increase its recognition with content such as congratulations and wishes. This approval can be obtained in writing, in the physical environment or by any electronic means of communication. The important thing is that the buyer has a positive declaration of will that he accepts the sending of commercial electronic messages, his name and surname and his electronic communication address.

Data transactions made due to the legal obligation of the company or expressly stipulated in the law
Personal data may be processed without obtaining separate approval for the purpose of expressly stating the processing in the relevant legislation or fulfilling a legal obligation determined by the legislation. The type and scope of data processing must be necessary for the legally permitted data processing and must comply with the relevant legal provisions.

Company data processing
Personal data may be processed in line with the service offered by the company and its legitimate purposes. However, the data cannot be used for illegal services in any way.

Processing of special data
According to the Law, data related to the race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and dress, membership to associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data is personal data of special nature. “Northwest Tour” also takes adequate measures determined by the Board in the processing of special quality personal data.
"Northwest Tour" can only process sensitive data for the purpose for which they were collected, with the consent of the individuals, in order to provide better services.

Data processed by automated systems
"Northwest Tour" acts in accordance with the Law regarding the data processed through automatic systems. The information obtained from these data cannot be used against the person without the explicit consent of the people. However, "Northwest Tour" can make decisions about the people it will process using the data in its own system.

User information and internet
In case of collection, processing and use of personal data on the websites and other systems or applications of "Northwest Tour", the relevant persons are informed about the privacy statement and, if necessary, about the cookies. People are informed about our practices on web pages. Personal data will be processed in accordance with the law.

When you visit our website, we present the following information to your attention regarding the cookies we use/will use on our page.

Data processed by automated systems
Data processed by automated systems regarding employees can be used in internal promotions and performance evaluations. Our employees have the right to object to the result against them, and they do so by following internal procedures. The objections of the employees are also evaluated within the company.

Google(analytics, doubleclick)
Cookies Purpose: Measurement Advertising In-site improvement
Cookie Type: Functional and analytical cookies Commercial cookies

Facebook
Purpose of Use of Cookies: Advertising
Cookie Type: Commercial cookies

Insider
Cookies Purpose: Measurement Advertising In-site improvement
Cookie Type: Functional and analytical cookies Commercial cookies

Hotjar
Purpose of Use of Cookies: Measurement Intra-site improvement
Cookie Type: Functional and analytical cookies Commercial cookies

3rd party companies (criteo, rtbhouse)
Purpose of Use of Cookies: Advertising
Cookie Type: Functional and analytical cookies Commercial cookies

Functional and Analytical
Cookies contain data about remembering your preferences, using the website effectively, optimizing the site to respond to user requests, and how visitors use the site. Due to their nature, these types of cookies do not contain usernames, etc. may contain your personal information.

Third Party Cookies
TROY-KALE TURİZM İNŞAAT TAAHHÜT TİCARET LTD.ŞTİ (www.cappadocia.cn) websites/mobile applications/mobile websites work with third-party reliable and well-known advertising providers. Third party service providers place their own cookies in order to serve you specific advertisements. Cookies placed by third parties collect and process the browsing information of visitors on websites and analyze how they are used.

Commercial cookies
In line with your interests and choices, it serves to increase your usage experience by presenting products/content that are similar to the product/content you are targeting and by offering a more advanced, personalized advertising portfolio. The above-mentioned session, permanent, functional and analytical and commercial cookies are kept in the background for approximately 2 (two) months, and the necessary adjustments can be made in the personal internet browser settings. The removal process from these settings may vary based on the internet browser.

How can I delete cookies?
Many internet browsers are set to automatically accept and use cookies from the time they are first installed on your computer. By using the help or settings menus of your internet browser, you can prevent cookies or give a warning when cookies are sent to your device. You can use your browser's instruction or help options screen to learn about the different ways to manage cookies and to get detailed information on how to adjust the settings of the browser you are using.

VI. Data of our employees

Processing of data for business relationship
Personal data of our employees can be processed without consent to the extent necessary in terms of business relations and health insurance. However, "Northwest Tour" ensures the confidentiality and protection of the data of its employees.

Data is obtained from the Kariyer.net system for job applications and candidate recruitment, as well as for the management of human resources, and the data is recorded in the system within the scope of the candidate evaluation process.

Processing by Legal Obligations
“Northwest Tour” may process the personal data of its employees without obtaining separate approval for the purpose of expressly stating the processing in the relevant legislation or fulfilling a legal obligation determined by the legislation. This issue is limited to the obligations arising from the law.

Processing for the Benefit of Employees
“Northwest Tour” may process personal data without obtaining approval for transactions that benefit company employees, such as private health insurance. "Northwest Tour" may also process employee data for disputes arising from business relations.

Processing of special data
According to the Law, data related to the race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and dress, membership to associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data is personal data of special nature. “Northwest Tour” also takes adequate measures determined by the Board, in addition to the approval of the person concerned, in the processing of personal data of special nature. Special categories of personal data can only be processed without the consent of the person, only in relation to the cases permitted by the Law and in a limited manner. In order for our employees to benefit from insurance and health services, the qualified data obtained from them is used only for the purpose.

Telecommunications and internet
Computers, telephones, e-mails and other applications allocated to employees within the company are allocated to employees for business purposes only. The employee cannot use any of these means allocated to him by the company for his private purposes and communication. The company can control and audit all data on these vehicles. The employee undertakes that he/she will not keep any other data or information other than work on the computer, phones or other tools allocated to him from the moment he/she starts the job.

VII. Transfer of personal data in and out of the country
“Northwest Tour” will be able to transfer personal data to the following individuals and institutions for certain purposes;
» Limited to the business partners of “Northwest Tour” in order to ensure the fulfillment of the purposes of the establishment of the business partnership,
» To the suppliers of “Northwest Tour”, limited to the purpose of providing our Company with the services that are outsourced by our company from the supplier and necessary to carry out the commercial activities of our Company,
» Solution partners of “Northwest Tour” limited to ensuring the execution of commercial activities of our company that require the participation of affiliates,

“Northwest Tour” has the authority to transfer personal data within the scope of the conditions determined by the Board in the law, in accordance with the other conditions in the Law and subject to the consent of the person, within the country and abroad.

VIII. Rights of the person concerned
“Northwest Tour” accepts that the data subject has the right to obtain consent before the data is processed, and that it has the right to determine the fate of the data after the data is processed.

Regarding personal data, by applying to our related person announced on our website by "Northwest Tour";
a) Learning whether their personal data is processed or not,
b) If personal data has been processed, requesting information about it,
c) Learning the purpose of processing personal data and whether they are used in accordance with its purpose,
ç) To know the third parties to whom personal data is transferred in the country or abroad,
d) Requesting correction of personal data in case of incomplete or incorrect processing,
e) Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7,
f) Requesting notification of the transactions made pursuant to subparagraphs (d) and (e) to third parties to whom personal data has been transferred,
g) Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,
ğ) In case of loss due to unlawful processing of personal data, it has the right to demand the compensation of the damage.

However, individuals do not have a right to anonymized data within the Company. “Northwest Tour” may share personal data with relevant institutions and organizations for the purpose of exercising the legal powers of a judicial duty or state authority in accordance with the business and contractual relationship.

Personal data owners can submit their requests regarding the above-mentioned rights by filling in the application form on the official website of the Company https://cappadocia.cn/en/contact completely and signing it with a wet signature, to the contact address stated below, by registered letter with return receipt and photocopies of identity card. They will be able to forward it by sending only a copy of the front side. Your applications will be answered as soon as possible depending on the content of your application or within 30 days at the latest after it reaches our company. You must submit your applications by registered letter with return receipt requested. In addition, only the part of your application about you will be answered, and an application about your spouse, relative or friend will not be accepted. “Northwest Tour” may request other relevant information and documents from the applicants.

IX. Privacy Policy
The data of employees or other persons in "Northwest Tour" is confidential. No one can use, copy, reproduce, transfer to others, use this data for any other purpose without compliance with the contract or the law.

X. Transaction security
All necessary technical and administrative measures are taken to protect the personal data collected by "Northwest Tour", to prevent it from falling into the hands of unauthorized persons and to prevent our customers and prospective customers from becoming victims. In this framework, it is ensured that the software complies with the standards, that the third parties are carefully selected and that the data protection policy is complied with within the company. Safety measures are constantly being renewed and improved.

XI. Audit
“Northwest Tour” carries out the necessary internal and external audits on the protection of personal data.

XII. Notice of Violations
When "Northwest Tour" is notified of any violation of personal data, it immediately takes action to remedy the violation. It minimizes the harm of the person concerned and compensates the damage. When personal data is obtained by unauthorized persons, it immediately notifies the Personal Data Protection Board.

Regarding the requests made in accordance with the Law on Protection of Personal Data
As announced on https://cappadocia.cn/en/personal-data-protection-law-p150 pages, all applications will be processed if the form on the page is filled in and a copy of the ID is attached to it, and sent to the address on the form by registered mail with return receipt requested.

Rights regarding personal data can only be exercised about personal data. Requests regarding the data of people other than the person who filled out the form and whose ID photocopy is attached will not be considered. Forms without an ID photocopy will not be considered. Even when data deletion requests are fulfilled, we inform you that we are obliged to share the data with the official authorities if requested by the official authorities.

Changes to be made in the Protection of Personal Data and Privacy Policy:
"Northwest Tour" reserves the right to make changes on the statements here. If a significant change is made to the statement, a link to the current statement is added to the home page of the website. Guests who register for any of our products or services can be informed about this issue through the communication channel given to the facilities. The last time the declaration was updated and the update number are indicated at the end of this text.

Every change made in the statement becomes effective with the publication of the amended statement on the site. Using the site or any of our products and services following such changes indicates your acceptance of the then-current amended statement.

Communication
For questions about the confidentiality agreement, you can contact us using our contact information.

Pursuant to paragraph 1 of Article 13 of the KVKK, you may submit your request regarding the exercise of your above-mentioned rights to our Company in writing or by other methods determined by the Personal Data Protection Board. Since the Personal Data Protection Board has not determined any method at this stage, you must submit your application in writing to https://www.cappadocia.cn in accordance with KVKK. In this context, your request containing the necessary information to identify you in order to use your rights mentioned above and your explanations regarding your right that you request to exercise from the rights specified in Article 11 of the KVKK; Fill out the form at northwesttour.com and send a signed copy of the form to Teomanpaşa Mah. 2205 St. You can personally send the documents identifying your identity to the https://www.cappadocia.cn/ management office at 36/3 Center/ CANAKKALE, via a notary public or by other methods specified in the KVKK. Depending on the nature of your request, your applications will be finalized as soon as possible and within thirty days at the latest, free of charge. However, in case of additional costs, our company reserves the right to charge you a fee according to the tariff to be determined by the Personal Data Protection Board.

This Clarification Statement was prepared on 22.03.2022. In case of any change in the text of the declaration, the effective date and content of this Clarification Statement will be updated.