Privacy Policy and Personal Data Protection Notice
At a Glance
Turasistan is the data controller for the data of its own customers and website visitors, and a data processor for passenger data that agencies upload to the platform. Below you can see what data is processed, why, and what rights you have.
Two different roles
We act as data controller for our own customer data and as data processor for agencies' passenger data.
Protected data
We apply measures such as access authorisation, encryption, backups and regular penetration testing.
Your rights
Requests under KVKK Art. 11 are answered within 30 days at the latest.
Contents
This notice is provided under Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK") and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform. It explains for what purposes Sanalogi Bilişim Sanayi ve Ticaret Anonim Şirketi ("Turasistan") processes your personal data, with whom it is shared, and what rights you have.
Data Controller
- Company name: Sanalogi Bilişim Sanayi ve Ticaret Anonim Şirketi
- Tax office / No: İkitelli Tax Office / 7430431852
- Address: Yıldız Teknopark – İOSB Mah. Teknopark Cad. No:1 Floor:2-16, Başakşehir / Istanbul, Türkiye
- Phone: +90 850 557 76 54
- Support: [email protected]
- Email: [email protected]
- Website: www.turasistan.com
Turasistan's Role: Data Controller and Data Processor
Turasistan is a software platform for travel agencies and tour operators (Turasistan App / CRM, Turizm Web, Mobile Passport Reader, T-Robot and related services).
- As data controller: for the personal data of website visitors, people who contact us, those who request a demo or trial, our customers (agency representatives and users) and our business partners.
- As data processor: for passenger, customer and booking data that agencies upload to and manage on the platform. The agency is the controller of this data; Turasistan processes it only on the agency's instructions and under the Service Agreement. If you are a passenger, please send requests about your data first to the agency you are travelling with.
Personal Data We Process
| Data Category | Examples |
|---|---|
| Identity | Name, surname, Turkish ID number, job title |
| Contact | Email, phone, address, company details |
| Customer transaction | Account/subscription records, orders, support requests, usage records |
| Transaction security | IP address, log records, device and browser information, session data, password/verification records |
| Financial | Invoice details, payment status, bank/IBAN details (card details are not stored by Turasistan; they are processed by the payment institution / virtual POS) |
| Marketing | Cookie and preference data, newsletter subscription, communication permissions |
| Visual / audio | Photographs in documents uploaded to the platform, call recordings (if any) |
Passenger data uploaded by agencies (processed as a data processor) may include passport/ID details, MRZ and NFC chip data, date of birth, nationality, visa application details, and room and flight information. For services such as Hajj and Umrah, this data may indirectly reveal religious belief. The legal responsibility for such special categories of personal data, including explicit consent, rests with the agency as data controller under Article 6 of the KVKK.
Purposes of Processing
- Providing the website and platform services; opening and managing accounts
- Responding to demo, trial and information requests; providing technical support
- Concluding and performing the contract; invoicing and collection
- Running information security processes; preventing unauthorised access and misuse
- Measuring service quality, product development, statistics and analysis
- Fulfilling legal obligations and responding to requests from competent authorities
- Product, campaign and information communications, with your explicit consent or under legal exceptions
- Establishing, exercising and protecting rights and claims
Legal Grounds (KVKK Art. 5)
- Processing is directly related to the conclusion or performance of a contract (Art. 5/2-c)
- Processing is necessary for the controller to comply with a legal obligation (Art. 5/2-ç)
- Processing is necessary for the establishment, exercise or protection of a right (Art. 5/2-e)
- Processing is necessary for our legitimate interests, provided it does not harm your fundamental rights and freedoms (Art. 5/2-f)
- Explicit consent (Art. 5/1), in particular for marketing communications and non-essential cookies
How Personal Data Is Collected
Your data is collected through website forms (contact, demo, registration, newsletter), the panel and applications, email, phone and support channels, cookies and similar technologies, by automatic or partly automatic means.
Transfer of Personal Data
For the purposes above, and in line with Articles 8 and 9 of the KVKK, your personal data may be transferred to the following groups of recipients:
- Cloud, hosting and infrastructure providers
- Payment institutions, banks and virtual POS providers
- SMS, email and communication service providers
- Accounting, e-invoicing, legal, audit and consulting providers
- Public institutions and third-party systems integrated on an agency's instructions (e.g. visa, Diyanet and Ministry of Foreign Affairs integrations)
- Competent public authorities and judicial bodies
Transfers abroad: Some of our infrastructure and service providers may host servers abroad. In that case, transfers are made under Article 9 of the KVKK, on the basis of an adequacy decision, standard contractual clauses, binding corporate rules or other appropriate safeguards provided by the Law.
Retention Period
Personal data is kept for as long as the purpose of processing requires and for the periods set by the relevant legislation (Turkish Commercial Code, Tax Procedure Law, Law No. 5651, etc.). After that period it is deleted, destroyed or anonymised. When a contract ends, agency data is handled under the return and deletion provisions of the Service Agreement.
Data Security
Turasistan applies appropriate technical and organisational measures such as access authorisation, encryption, firewalls, logging, regular backups and penetration testing, and holds its staff to confidentiality obligations. See our Information Security page for details. Transmission over the internet cannot be guaranteed to be completely risk-free.
Cookies
Our site may use cookies that are strictly necessary for it to work, as well as analytics, performance and functionality cookies. Non-essential cookies are used only with your explicit consent. You can delete or block cookies in your browser settings; some parts of the site may then not work properly.
Third-Party Links
Our site may link to third-party websites. Turasistan is not responsible for the privacy practices of those sites.
Your Rights under KVKK Article 11
By applying to the data controller, you may request to:
- Learn whether your personal data is processed and, if so, request information about it
- Learn the purpose of processing and whether it is used in line with that purpose
- Know the third parties, in Türkiye or abroad, to whom your data is transferred
- Request correction if the data is incomplete or inaccurate
- Request deletion or destruction under Article 7 of the KVKK
- Request that corrections, deletions and destruction be notified to the third parties to whom data was transferred
- Object to a result against you arising from the analysis of your data exclusively by automated systems
- Claim compensation if you suffer damage because of unlawful processing
How to Apply
You can send your requests, together with information that identifies you, in writing to the address above by hand or through a notary, or by email from the address registered with us to [email protected]. Applications are concluded free of charge within 30 days at the latest, depending on the nature of the request; if the process requires extra cost, the fee in the tariff set by the Board may be charged. If you find the reply insufficient, you may complain to the Personal Data Protection Board within 30 days of receiving the reply and in any case within 60 days of your application.
Changes
This notice may be updated to reflect changes in legislation or in our services. The current version is published on this page.
Contact
Sanalogi Bilişim Sanayi ve Ticaret Anonim Şirketi
Yıldız Teknopark – İOSB Mah. Teknopark Cad. No:1 Floor:2-16, Başakşehir / Istanbul
Tel: +90 850 557 76 54
Email: [email protected]
Questions about your data?
Send us your KVKK requests and questions. We reply to your requests within 30 days at the latest.
Sanalogi Bilişim Inc.
Yıldız Teknopark – İOSB Mah. Teknopark Cad. No:1 Floor:2-16, Başakşehir / Istanbul
+90 850 557 76 54
Turasistan • Legal • Tourism Technology