Please read this policy carefully. Here you will find important information about the processing of your personal data and your rights under the relevant legislation.
We reserve the right to update our privacy policy at any time due to operational decisions, as well as to comply with any legislative or jurisprudential changes. If you have any questions or need any clarification regarding our Privacy Policy or your rights, you can contact us through the channels indicated below.
In the event of providing personal data of third parties, we undertake to obtain the prior consent of those concerned and to inform them of the content of this policy.
The fields of our forms that are marked as compulsory must be filled in to process your request.
1. Who is responsible for the processing of your data?
Unless specifically indicated otherwise, HoliBuddy Inc. ( Holibuddy Turizm A.Ş.) is responsible for the processing of your personal data (hereinafter referred to as HoliBuddy) with registered address at Karliktepe Region Camlik St. 1C/262 Kartal Istanbul TR; Email: info@holibuddy.com
2. What will we process your data for and on what legal basis?
Management of bookings and provision of requested services. The data provided in your reservation or service requests will be processed for the management of such reservations and the provision of the services requested. The categories of data we process for these purposes are as follows:
• Identification data (name, surname) and contact details (address, email and telephone) of the holder of the reservation or contract;
• Data on personal characteristics (nationality and age)
• Details of the booking itself (dates of the booking, type of vehicle booked, flight number in case of airport pick-up, and ancillary services included in the booking).
• Financial and transactional data.
These processing operations are necessary for the performance of the contract or for the implementation of pre-contractual measures at the request of the data subjects.
Economic data and data on transactions of goods and services will be processed for accounting and administrative management purposes and the fulfilment of our legal obligations in accounting and taxation matters.
Response to queries and complaints
The data provided in your enquiries or complaints will be processed in order to deal with your requests and handle any complaints you may have.
These processing operations are necessary for the performance of the contract, the implementation of pre-contractual measures at the request of the data subjects or the defense of customer claims.
The processing of any health data you have provided in your complaint is covered by Art. 9.2. f) of the GDPR, where such processing is necessary for the formulation, exercise or defense of claims.
Statistical and quality management purposes:
In order to evaluate and manage the quality of our services and products, we process identifying data and contact details provided by our customers to send them rating requests or feedback about their experience with us. We also perform statistics based on aggregated data obtained from transaction data and web browsing data, e.g. IP address, weblogs, pages visited or actions performed on the website (+ info in our cookies policy).
These processing operations are based on our legitimate interest to evaluate and manage the quality of our services and products. In weighing this interest against their rights and freedoms, it was determined that the processing had a limited impact on the privacy of data subjects, as it corresponded to their reasonable expectations and did not pose significant threats as it was carried out on aggregated data and with the consent of the data subjects themselves with respect to the metrics conducted with the use of cookies.
Sending of commercial communications and management of distribution lists
We process the identification and contact data provided by our customers and those who sign up to our distribution lists in order to send them communications about our activities, products and services.
These processing operations are based on the consent that you are asked to give. Failure to give or withdrawal of consent does not condition the execution of the order or the provision of the contracted services.
You may at any time request to unsubscribe from the processing for commercial purposes by activating the mechanism provided for this purpose in our communications or by sending an email to: info@holibuddy.com
To whom may we disclose your data?
Your data will only be disclosed to third parties if legally obliged to do so, with your consent, to other entities that are part of HoliBuddy for administrative purposes or when it is necessary for the correct processing of the reservation or the provision of the requested services. Specifically:
For the correct processing of the reservation, the data provided will necessarily be communicated to the rental company providing the selected vehicle (more information in the reservation conditions stipulated on the page from which the reservation is requested or formalised) or to the companies whose services are included in the contracted service, for example: intermediary and insurance company in the case of contracting a "Vehicle rental excess insurance" (more information in the conditions and policy document accessible from the page from which the reservation is requested or formalised).
Furthermore, where necessary for their resolution, we will pass on your complaints to the service providers affected by them. Likewise, depending on the nature of your claim, the recipients of the data included in the same may be, among others, insurance entities, public administrations or entities, official bodies, solicitors, judges and courts. These communications are necessary either for the provision of the contracted services or for the application of pre-contractual measures at your request, or for the formulation, exercise or defense of claims.
These communications may involve the transfer of your data to third countries when the aforementioned companies are located outside the European Economic Area.
3. How long do we keep your data for?
In general, we will retain your data for the duration of your relationship with us and in any case for as long as required by applicable legal provisions, e.g. for accounting and tax purposes, and for as long as necessary to meet any liabilities arising from the processing. We will delete your data when they are no longer necessary or relevant for the purposes for which they were collected. The information related to navigation will be cancelled once the web connection has ended and the statistics have been carried out.
Data processed for marketing purposes, including marketing profiles, will be retained for as long as no request for deletion has been made.
4. What are your rights?
You have the right to obtain confirmation as to whether or not we are processing your personal data and, if so, to access it. You can also ask for your data to be corrected if they are inaccurate or for incomplete data to be completed, as well as request their deletion if, among other reasons, the data are no longer necessary for the purposes for which they were collected.
In certain circumstances, you may request that we restrict the processing of your data. In this case, we will only process the data concerned for the formulation, exercise or defense of claims or for the protection of the rights of other persons. Under certain conditions and for reasons relating to your particular situation, you may also object to the processing of your data. In this case, we will stop processing the data except for compelling legitimate reasons that override your interests or rights and freedoms, or for the formulation, exercise or defence of claims. You may also, under certain conditions, request the portability of your data to be transferred to another data controller.
You may withdraw your consent for certain purposes, without affecting the lawfulness of the processing based on your consent prior to its withdrawal, and lodge a complaint with the Turkish Data Protection Agency.
You also have the right to lodge a complaint with a data protection authority. A list and contact details of the European data protection agencies can be found on the European Commission's website at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
You may at any time request to unsubscribe from the processing for commercial purposes by activating the mechanism provided for this purpose in our communications or by sending an email to: info@holibuddy.com
To exercise your rights, you must send us a request by post or e-mail to the addresses indicated in the section Who is responsible for the processing of your data?
You can obtain more information about your rights and how to exercise them on the website of the Turkish Data Protection Agency at https://kvkk.gov.tr/ or on the website of the data protection authority in your country.