Privacy Notice

This privacy notice is provided by the data controller, Sanalogi Bilişim Sanayi ve Ticaret A.Ş. ("Sanalogi"), under Article 10 of Turkish Personal Data Protection Law No. 6698 ("KVKK") and the Communiqué on the Procedures and Principles for Fulfilling the Obligation to Inform. Turasistan is the software brand developed by Sanalogi.

Company name: Sanalogi Bilişim Sanayi ve Ticaret Anonim Şirketi
Address: YTÜ İkitelli Teknopark No:1 Kat:2 Ofis No:16, 34220 Başakşehir / Istanbul / Türkiye
MERSİS No: 0743043185200018
Tax office and number: İkitelli Tax Office, 7430431852
Phone: +90 850 557 76 54
Email: [email protected]

2. Which data are we the controller for?

Sanalogi is the data controller for the data of visitors to our website, people who contact us or request a demo or trial, our customers' representatives and Turasistan users (agency staff), employees of our business partners and suppliers, and job applicants.

For the traveler, customer and staff data that agencies process through Turasistan App, Turasistan Reader, Trobot and Turizm Web, the agency concerned is the data controller. Sanalogi is a data processor that processes this data only on the agency's instructions and to provide the service; informing these people is the agency's obligation. If you are a traveler or customer of an agency, please contact that agency first with any request.

3. Personal data we process

Identity: First name, last name, job title and, where necessary, Turkish ID number
Contact: Email address, phone number, address and company details
Customer transactions: Account and subscription records, requests, support records and usage records
Transaction security: IP address, log records, device and browser information, session information, password and verification records
Financial: Invoice details, payment status, bank and IBAN details. Card details are not stored by Sanalogi; they are processed by the payment institution.
Marketing: Newsletter subscription and commercial electronic message permissions
Visual and audio records: Phone call recordings, if any
Professional experience: CV information shared in job applications

Sanalogi does not aim to process special category personal data for its own activities. The data agencies process in Turasistan, however, may include special category data: data relating to Hajj and Umrah may indirectly reveal a person's religious beliefs; documents uploaded by the agency, such as vaccination cards or health reports, are health data; and the facial image read from the passport chip may be biometric data. As data controller, the agency is responsible for processing this data in line with Article 6 of KVKK and for informing the people concerned. For this data, Sanalogi applies technical and administrative measures taking into account the adequate measures set by the Personal Data Protection Board.

4. Purposes and legal grounds

Purpose	Legal ground (Article 5 of KVKK)
Opening accounts, managing the free trial and subscription, providing the service	Entering into and performing a contract (5(2)(c))
Handling demo, trial and information requests, technical support	Entering into and performing a contract (5(2)(c)), legitimate interest (5(2)(f))
Invoicing, collections, accounting and keeping statutory records	Legal obligation (5(2)(ç))
Ensuring information security, keeping logs, preventing unauthorized access	Legal obligation (5(2)(ç)), legitimate interest (5(2)(f))
Measuring service quality, product development and statistics	Legitimate interest (5(2)(f))
Responding to requests from competent authorities	Legal obligation (5(2)(ç))
Sending campaign, newsletter and announcement messages	Explicit consent (5(1))
Protecting our rights in legal disputes	Establishing, exercising or defending a right (5(2)(e))
Assessing job applications	Entering into a contract (5(2)(c)), legitimate interest (5(2)(f))

The purposes and legal grounds for data processed through cookies are explained in our Cookie Policy.

5. How we collect data

Your personal data is collected electronically, by automated or partly automated means, through the contact, demo, registration and newsletter forms on our website, Turasistan applications, email, phone and support channels, email and job platforms such as LinkedIn and Kariyer.net for job applications, and cookies.

6. Transfers of personal data

Your personal data may be transferred, only for the purposes above and in line with Articles 8 and 9 of KVKK, to the following groups of recipients:

Providers of hosting, server and infrastructure services (to provide the service)
Email and SMS service providers (for communication and notifications)
Banks and payment institutions (to collect payments)
Accounting, e-invoicing, legal, audit and consulting service providers (to meet legal obligations and protect our rights)
Competent public authorities and judicial bodies (where required by law)

Transfers that agencies make through Turasistan to third-party systems such as Diyanet, Nusuk and Saudi visa systems are made on the agency's instructions and under its responsibility; these systems are not owned by Sanalogi.

Some of our service providers, such as server and email providers, are located outside Türkiye. Transfers to these providers rely on one of the transfer mechanisms under Article 9 of KVKK (for example, a standard contract notified to the Personal Data Protection Authority).

7. Retention periods

Personal data is kept for as long as the purpose of processing requires and for the periods set by legislation such as the Turkish Commercial Code, the Tax Procedure Law and Law No. 5651. Data our customers enter into Turasistan is kept for no more than 1 year after the Membership and SaaS Service Agreement ends. Unsuccessful job applications are kept for no more than 1 year after the recruitment process ends. At the end of the retention period, the data is deleted, destroyed or anonymized.

8. Data security

To protect personal data, we apply technical and administrative measures such as permission-based access, encrypted connections, firewalls, access logs, regular backups and penetration testing. Our staff who have access to the data are bound by confidentiality obligations. Details are set out in our Information Security Policy.

9. Your rights under Article 11 of KVKK

Find out whether your personal data is processed
Request information if it has been processed
Find out the purpose of processing and whether it is used for that purpose
Know the third parties in Türkiye or abroad to whom it is transferred
Ask for it to be corrected if it is incomplete or inaccurate
Ask for it to be deleted or destroyed under the conditions in Article 7 of KVKK
Ask for corrections and deletions to be notified to the third parties to whom it was transferred
Object to a result against you that arises solely from analysis by automated systems
Claim compensation if you suffer loss because your data was processed unlawfully

10. How to apply

You can send your application in the following ways:

Hand deliver your written application with your wet-ink signature and information identifying you to our address, or send it by registered mail with return receipt or through a notary public
Send your application signed with a secure electronic signature or mobile signature to [email protected]
Write to [email protected] from the email address you have previously given us and that is registered in our system

The application methods and the information required are set out on our Data Subject Application Form page. Your application will be concluded free of charge as soon as possible and within 30 days at the latest, depending on its nature. If the action involves an additional cost, the fee in the tariff set by the Personal Data Protection Board may be charged. If your application is rejected, you find the response insufficient or no response is given in time, you may complain to the Personal Data Protection Board within 30 days of learning of the response and, in any case, within 60 days of the application date.

11. Related texts

General information on how data is used is set out in our Privacy Policy, cookies in our Cookie Policy, and the mobile passport reader app in the Turasistan Reader Privacy Policy.

12. Changes

When we update this notice, we publish the new text on this page and change the "Last updated" date.