Personal Data Policy



The Policy of Lunarya İletişim Limited Şirketi on Protection and Processing of Personal Data


General information on Law on Protection of Personal Data

Law on Protection of Personal Data numbered 6698 (referred to under this information sheet as “KVKK”) is adopted on 24 March 2016 and published on the issue of Turkish Official Gazette numbered 29744 and dated 7 April 2016. Some of the provisions of KVKK entered into force on the date of publication and some of them entered into force on 7 October 2016.


Information of the data controller

As per KVKK numbered 6698 and in the capacity of Data Controller, your personal data will be – within the framework explained under this information sheet – recorded, stored, updated and disclosed or transferred to third persons within the limits allowed by the legislation, classified and processed with the methods mentioned under KVKK.

Processed Personal Data

Identitiy Data: Your name, surname, date and place of birth, gender, marital status, nationality,

Contact Data: Your e-mail address, address, mobile phone number, telephone number, fax number, residence address or other address information provided to us in order to perform our services,

Financial Information/Card information: Your credit card, debit card and/or bank transfer/eft information regarding services. (if needed)

Special Categories of Personal Data: Your fingerprints, information about political party, association, foundation, union membership, religious or philosophical opinion, ethnic origin and race, if you include in our forms or surveys, or in any document or form in the written or electronic environment that you send to our company. or information that may form an opinion on that subject, and information about your health, or your special categories of personal data recorded in the automatic voice recording system during all your telephone conversations with our call center with our employees. (In any case, we process your special categories of personal data in accordance with the KVKK and special regulations in the legislation, especially article 6 of the KVKK. By approving this clarification text, you expressly consent to the processing of your Special Categories Personal Data).

Survey Questions: Although it varies according to the research and survey content; the city you are traveling to, whether it is your first trip, travel dates, your travel budget, your food, shopping and travel preferences, the purpose of your trip, the items you take with you during your trip.


Processing of your personal data

As per the KVKK numbered 6698, your personal data you shared with our company, will be processed by our company partially or as a whole – automatically or not automatically as a result of your data being part of a recording system – by means of obtaining, recording, storing, altering, reorganizing, briefly by being subject to all kinds of processes performed on the data. Within the scope of KVKK, any action/process performed on the data is accepted as “processing of personal data”.


Purposes of processing your data and legal reasons

Personal data shared by you, will be processed in accordance with KVKK numbered 6698 and relevant secondary legislation,

  • in order to render us able to carry out the requirements of the services we provide to our customers in accordance with requirements of the distance sales agreement (the “Agreement”) and Terms of Use, executed between us and our customer and the service we provide (the “Service”) (in other words, in order to establish and fulfill the Agreement; in order to be able to improve our products and services we provide and in order to render us able to present the product and Services subject to the Agreement by means of preparing them personally for you;  


  • by means of transferring such data to third persons who will provide Services that you desired within the framework of the Agreement, in order to render such third persons able to communicate with you and present to you such Services you desired or other services;


  • in order to record identification information, address and other necessary information with the purpose of detecting the information of the person who participates in the transaction within the scope of Law on the Regulation of Electronic Commerce numbered 6563, Law on Protection of Consumer numbered 6502, Regulation Regarding Service Providers and Intermediary Service Providers in Electronic Commerce published in the issue of Official Gazette dated 26.08.2015 and numbered 29457, Regulation on Distance Sales Agreements published in the issue of Official Gazette dated 27.11.2014 and numbered 29188, which regulations were prepared basing on these two abovementioned laws, and the relevant legislation;


  • in order to prepare all records and documents, relating to mandatory payment systems in the Banking and Electronic Payment field, in order to prepare such electronic or printed records and documents that will constitute the basis of the transaction; in order to comply with the obligations to store, report and notification of information, which obligations are foreseen by legislation and authorities;


  • in order to inform prosecution offices, courts and relevant public authorities in cases of subjects regarding public safety, legal conflicts and also upon request.



Information on third persons or institutions/bodies, to whom your personal data may be transferred

With the purposes specified above, the persons and institutions/bodies to whom your personal data, which you shared with our company, can be transferred is: suppliers, including firstly Stripe, Inc., who is the provider our company’s payment system, persons and institutions, our business partner, and who are related to the services being provided, such as courier companies, solution partners, with whom we collaborate to carry out our operations, or who provide us services as Data processors, domestic/foreign persons/institutions and other third persons.


Further, before the Agreement is executed, in order to render us able to contact you and compose the travel advices that are right for you, your personal data will be transferred to our employees and also our business partners / suppliers, who provide us with the software and services that present the most suitable travel advices for our customers to us by collecting our customers’ data.


In this context, your personal data will be transferred to service and/or product providers whose information will be given to you within the travel guide / booklet that we will prepare personally for you in accordance with the Agreement, to other service and/or product providers, that are recommended by us to provide services to you during your travel period upon your request; and additionally, in the event you require us to do any reservation or purchasing/booking transaction, to such third persons relevant to your request on reservation or purchasing/booking.


Collection method of your personal data

Your personal data / personal data can be processed or collected

  • via our firm’s web site and mobile application and forms therein, with respect to data such as name, surname, ID number, address, telephone number, business or private e-mail address, choices on the web pages entered by using username and password, IP records of activities, cookies’ data collected from browser and data containing information on internet browsing time and details, and location data;


  • in verbal, written or electronic form via our sales and marketing staff, affiliates, suppliers, other sale channels, forms on the paper, business cards, other channels such as digital marketing and call center;


  • via business cards, resumés, which are shared – verbally or in written or electronic form – by persons for purposes such as establishing a commercial relationship with our company, applying for a job or making offers, or for other purposes, in physical or virtual platform, or person-to-person interactions or distance interactions; and additionally


  • via data obtained from different channels indirectly, and from websites, blogs, competitions, surveys, games, campaigns and other (micro) websites and social media having similar purposes, from data received from reading and clicking movements on e-bulletins and public databases and via profiles which are publicly accessible in social media platforms.

Your personal data obtained before KVKK entered into force on 7 April 2016, and your data obtained before such date such as membership information, electronic message permissions, purchasing of products and services and other information obtained in accordance with laws are processed and stored as per terms and conditions stipulated under this document.


Transfer of your personal data abroad

Your personal data that is collected with any methods above, which is processed in Turkey or which is collected with the purpose of processing and storing outside of Turkey, can be transferred to service mediators/providers located outside of Turkey (to countries accredited by the Personal Data Board and where there is sufficient protection for the protection of personal data), provided that such transfer is in accordance with the KVKK and made to fulfill the purposes of the Agreement.


Storing and protection of personal data

Your personal data will be stored in our firm’s data base and systems as a confidential data in accordance with the Article 12 of KVKK, and your personal data will not be shared with any third persons except in compliance with legal obligations or rules/provisions specified under this document. Our firm is – as per Article 12 of KVKK – obliged to (i) prevent the unlawful processing of personal data in our systems, (ii) prevent the access of unauthorized persons to such data, and (iii) take software measures such as access management as well as physical security measures. In the event that it is learned that personal data is obtained by third persons by unlawful means, this circumstance will be notified in written to the Personal Data Protection Board immediately and in accordance with legal regulations.


Preservation of the personal data in a correct and up-to-date fashion

As per Article 4 of KVKK, our firm is under the obligation to hold your personal data correctly and on and up-to-date fashion. In this framework and for this purpose, our customers have to share their correct and up-to-date data or update such data through or web site / mobile application.


Rights of personal data owner in accordance with KVKK numbered 6698

Article 11 of KVKK entered into force on 7 November 2016, and pursuant to relevant article, rights of Personal Data Owner are as follows:


Personal Data owner has the right of apply to our firm (data controller) and with respect to himself/herself;

  1.   learn whether his/her personal data are processed or not,
  2.    if his/her personal data are processed, request information on such processing,
  3.   learn the purpose of the processing of his/her personal data and whether this data is used for rightful purposes,
  4.   know the third parties to whom his/her personal data are transferred in Turkey or abroad,
  5.   request the rectification of data processed incompletely or inaccurately, if any,
  6.   request the erasure or destruction of his/her personal data under the conditions laid down in Article 7 of KVKK,
  7.  in case of rectification, deleting or destruction of personal data, request that such operations are notified to third persons to whom personal data are transferred,
  8.  object to the negative outcomes, in case there is a negative outcome if processed data is exclusively analyzed by automatic means,
  9.  in case such data subject incurs damages as a result of unlawful processing of personal data, to request compensation for such damages.


Lunarya İletişim Limited Şirketi, registered with Istanbul Trade Registry under registration number 924490 and Mersis number [0609050342600016], having its headquarters located at İÇERENKÖY MH. TOPÇU İBRAHİM SK. QUICK TOWER NO:8 10D ATAŞEHİR /ISTANBUL Turkey is within the scope of KVKK the Data Controller.


The Data Subjects may direct their questions, opinions or requests to communication channels below:


E-mail:[email protected]