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UM Passenger Data Protection

SUNEXPRESS CLARIFICATION TEXT ON THE PROTECTION OF PERSONAL DATA RELATED TO THE UNACCOMPANIED MINOR PASSANGER (UM PASSENGER) SERVICE

As Güneş Ekspres Havacılık A.Ş. ("SunExpress”), we attach great importance not only to the safety and comfort of our unaccompanied minor passengers, but also to the protection of their personal data. In this context, we would like to inform you as the data controller in accordance with the Personal Data Protection Law No. 6698 ("PDPL") and the European Union General Data Protection Regulation ("GDPR") regarding the processing of personal data of the Unaccompanied Minor Passengers (“UM Passenger”) and you, as their legal representatives, during travel.

For more detailed information regarding the processing of your personal data, or if you are a passenger subject to the GDPR, you can read the “SunExpress Personal Data Protection Notice”, which includes the necessary information for you, at the following address: https://www.sunexpress.com/tr-tr/verilerin-korunmasi/.

1.  Personal Data Processed

The UM Passenger service is provided in case a child under a certain age is traveling unaccompanied on the flight. The following personal data is processed within the scope of this service:

  • Identity and Contact Information: When creating an account, please provide your personal data such as name, surname, ID number, passport information, etc., as well as e-mail address, telephone number, mobile phone number, address, which you provided when you applied for flight ticket reservations or to benefit from the privileged services offered by SunExpress and its business partners.
  • Your Flight Information: Your reservation and ticket information and other information about your flight,
  • Advanced Passenger Information (“API”): Personal data relating to your name, nationality, date of birth, gender, type and number of travel documents, start and end dates of validity and country of issue,
  • Your assessments and requests: The assessment details we have provided from you about our services,
  • Your payment details: Information on whether the service fee has been paid.
  • Your Membership Program Information: Information about the SunExpress Loyalty program if you are a member,
  • Disease, Allergy, Special Dietary Requirements Information: If requested and approved by you, information on diseases, allergies and special dietary requirements, if any, in order to provide the service the UM Passenger needs during the trip,

 

2.  Purposes of Processing of Personal Data

The personal data collected are processed for the following purposes:

  • Ensuring the safety of unaccompanied minor passengers before, during and after the flight within the scope of UM Passenger service,
  • Planning, coordinating and executing UM service,
  • Sharing the necessary information with the relevant airport ground handling and cabin crews,
  • Fulfilling the legal liabilities.

 

3.  Legal Basis

Personal data is processed within the scope of being directly related to the establishment or performance of a contract (Article 5/2-c of the Turkish Personal Data Protection Law – PDPL), the data controller’s obligation to fulfill a legal requirement (Article 5/2-ç of PDPL), and legitimate interest (Article 5/2-f of PDPL). In cases where explicit consent is required, your consent is also obtained.

4.  Personal Data Transfer

In some cases, your personal data processed by SunExpress may be transferred to third parties at home or abroad in accordance with the provisions of national and international legislation, especially Articles 8 and 9 of the Law.

The personal data of an unaccompanied minor passenger may be shared with the following parties:

  • SunExpress ground handling and cabin crews,
  • Airport operators and security services,
  • Customs and border security officials,
  • SunExpress' domestic or international business partners (e.g. ground handling service providers, connecting airlines used on your flight)
  • Our suppliers (e.g. companies providing transportation services)
  • SunExpress' domestic or international IT service providers (limited only to necessary system access)

Data transfer is carried out in accordance with applicable national and international data protection legislation. Necessary security measures shall be taken for transfers outside the European Economic Area.

5.   Method of Collecting Personal Data

Your personal data is obtained through printed documents and/or our electronic systems when you purchase tickets or make bookings through our ticket sales offices, airport check-in counters or agencies or when performing similar transactions in the aforementioned channels and during the filling of the UM service form and information provided through customer service.

6.   Your Rights as a Data Subject

Pursuant to Article 11 of PDPL, you are entitled for;

  • Learning whether or not your personal data has been processed,
  • If processed, requesting information as to processing,
  • Learning whether it is used for its intended purpose,
  • Being provided with details of third parties to which your personal data has been transferred,
  • Requesting correction if incomplete or incorrectly processed,
  • Asking for it to be deleted or destroyed,
  • Requesting notification to third parties to whom it is transferred,
  • Raising objection against any result to the detriment of yourself by analyzing the processed data exclusively through automatic systems,
  • Claiming compensation if you suffer damage.

To exercise your rights listed above, you can send an e-mail to sxs.dpo@sunexpress.com or you may apply to our Company in writing.

  • Güneş Ekspres Havacılık A.Ş.

Address: Yenigöl Mah. Nergiz Sok. No: 84 / 07230 Muratpaşa-Antalya/Türkiye
Telephone: +90 (0)242 310 26 26 (pbx)
Website: https://www.SunExpress.com