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1. Definition
As a result of your use of the website flymedi.com (hereinafter referred to as the "Website"), we may require you to provide us with your personal data, so that you have the possibility to use the services provided through the Website. The word "personal data" means any data that enables a person to be identified, which includes your family name, first name, email address, telephone numbers, sensitive personal data, health data and data relating to your transactions on the Website, detail of your orders and subscriptions, all information about you that you choose to provide us with.

2. Purpose
The purpose of this privacy policy is to inform you of the means that we use to collect and process your personal data, with the strictest respect for your rights. In this regard, we inform you that we collect and process your personal data in compliance with the Turkish Data Protection Law (hereinafter referred to as the "Law"), as well as the regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 as from its entry into force, namely 25th May, 2018 (hereinafter referred to as the "GDPR").

3. Identity of the entity responsible for collecting data
The entity responsible for collecting and processing your personal data is the company Flymedi, a Dutch Simplified Joint Stock company registered with the Registry of Trade and Companies of Amsterdam under the number …. , whose head office is located at … (hereinafter referred to as "us" or "we").

4. Collecting personal data
The legal basis of our processing of your personal data is the following: The legitimate interest resulting from your voluntary provision of your personal data when visiting the Website and/or requiring information on our services, as these data are aimed at enabling us to better answer to your information requests about our Services; Your consent to our use of social network cookies, advertising cookies and Google Analytics cookies, as set forth in article "Cookies"; Processing is necessary for the performance of the contract to which you are party for purposes of using our services on our Website. Your personal data is processed to meet one or several of the following requirements:

  • To manage your access to the Services provided through the Website and their use;
  • To carry out operations necessary for the management of customers with regard to the contracts, orders, deliveries, invoices, fidelity programs, follow-up of the customer relations;
  • To constitute a file of registered members, users, customers and prospects;
  • To send newsletters, entreaties and promotional advertisements. In case you do not wish so, you have the possibility to opt-out of receiving such communications when your data are collected;
  • To provide commercial and service use statistics;
  • To manage customer’s opinions on products, services or contents;
  • To manage unpaid invoices and possible disputes about the use of our products and services;
  • To customize our answers to your information requests;
  • To respect our legal and regulatory requirements.
We inform you, when collecting your personal data, whether some of these data are mandatory or optional. Mandatory data are necessary for the provision of the Services. You are free to provide or not optional data. We will also inform you of the possible consequences of failure to reply.

5. Recipients of the collected data
The only persons who have the right to access to your personal data are our personnel, the services in charge of control (including external auditor) and our subcontractors. We may also give access to your personal data to government agencies, for the sole purposes of meeting legal requirements, or to representatives of the law, ministerial officers and organizations responsible for the collection of debts.

6. Transfer of personal data
Your personal data will not be exchanged with, transferred or rented to any third party. Besides, we also inform you that we may share with or disclosed to third-parties your data in an anonymized form so that you may not be identified, for statistical purposes.

7. Personal data storage period
Data concerning current and potential customer management: Your personal data shall be stored no longer than the time strictly necessary for the management of our commercial relations with you. However, any data providing the proof of a right or a contract and that must be stored in compliance with a legal obligation shall be so for the period stated by the legislation currently in force. With regard to possible promotion operations towards customers, their data may be stored for a period of 10 (ten) years from the end of the commercial relations with them. Personal data relating to potential customers may be stored for a period of 10 (ten) years from their collection or the last contact from the potential customer. Beyond that ten-year period, we may contact you again to find out if you still wish to receive commercial solicitations. Management of opt-out systems: All information taking into account your right to object shall be stored for at least 10 (ten) years from the exercise of this right. Cookies: The term of storage of the cookies set forth in article "Cookies" is 12 (twelve) months.

8. Safety
We inform you that we take all necessary precautions, as well as all appropriate organizational and technical measures, to maintain the security, the integrity and the confidentiality of your personal data, including to prevent that they be distorted or damaged and that any unauthorized third-party access to them.

9. Cookies
Cookies are often encrypted small lines of text that are stored in your web browser. They are created when a user’s browser is loading one website: this website sends information to the browser which creates a text file. Each time the user is visiting this website, the browser retrieves this file and sends it to the website’s server. There are various types of cookies which do not have the same purposes: Technical cookies are used throughout your browsing, in order to facilitate it and to carry out some of the functions. A technical cookie may be used, for instance, to memorize the answers you provided in a sign-up form or preferences relating to the language or the presentation of an internet site when such options are available. We use technical cookies. Social network cookies may be created by social platforms for purposes of enabling web designers to share their website content on said platforms. These cookies may be used by social platforms for purposes of tracking net surfers’ visit on the relevant website, whether they use or not these cookies. We hereby inform you that we do not use social network cookies. However, should we decide to use them in the future, we will inform you in advance, so that you may have the possibility to consent or not to their placement. Advertising cookies can be created not only by the website users are visiting, but also by other websites which provide advertisements, announcements, widgets or any other element on the displayed page. In particular, these cookies enable the use of the retargeting technique which is a marketing model whose purpose is to propose advertisements to the internet user that are adapted specifically for them. We hereby inform you that we do not use advertising cookies. However, should we decide to use them in the future, we will inform you in advance, so that you may have the possibility to consent or not to their placement. We use Google Analytics, an audience analysis statistics tool that generates a cookie that enables us to measure the number of visits to our Website, the number of page views and visitors' activity on the Website. Your IP address is also collected to determine the city you are connecting from. This cookie is placed only with your consent. You have the possibility to accept them or to refuse them. To all intents and purposes, you can refuse the installation of cookies in your browser settings. However, this refusal could prevent you from using the services offered on the Website.

10. Access to your personal data
In compliance with the Law and the GDPR, you have the right to access, rectify and delete any information concerning you. You can exercise this right and have the information concerning you by contacting us at the: Postal Address: … Persons the data of which are processed on the basis of our legitimate interest, as specified in article "Collecting personal data", are reminded that they have the possibility to object to the processing of their personal data at any time. We may however carry on with this processing if there are legitimate reasons for it that should prevail over your rights and freedoms or if it is required in order to establish, exercise or defend our rights before courts.

11. Portability of your personal data
You have a right to portability of the personal data you have entrusted to us, understood as the data you have actively and deliberately declared when accessing to and using our Services. You are reminded that portability right does not apply on data that were processed on another basis than consent or the execution of a contract between us. This right may be exercised free of charge, at any time, including when closing your account on the Website, so that you may recover and store your personal data. In this context, we shall provide your personal data, by any appropriate means, in an open standard, currently used and machine-readable format, in compliance with the state of art.

12. Submission of a complaint before a supervisory authority
You are informed that you have a right to submit a complaint before a supervisory authority which is competent in the member State in which your ordinary residence, your place of work or the place in which the infringement of your rights was committed, if you consider that the personal data processing under this Privacy policy is a violation of the applicable regulations. This complaint submission may be exercised without prejudice of other legal action before any administrative or judicial court. In fact, you have also a right to effective administrative and judicial redress if you consider that the personal data processing under this Privacy policy is a violation of the applicable regulations.

13. Restriction of processing
You have the right to obtain restriction of your personal data’s processing where one of the following applies: - Within the period of verification that we carry out, if you contest the accuracy of your personal data; - When the processing of these data is unlawful et you request the restriction of this processing, instead of erasing your data; - When we no longer need your personal data, but you require their maintenance for the exercise of legal claims; - Within the period of verification of the legitimate interests, if you have objected to the processing of your personal data.

16. Modifications
We reserve the right, at our sole discretion, to modify this Privacy policy, in whole or in part. Any changes will be effective from the time of publication of the new Privacy policy. Your use of the Website after the changes have been implemented implicitly expresses your acknowledgement and acceptance of the new Privacy policy. Otherwise, and if the new Privacy policy does not suit you, you must no longer use the Services.

17. Entry into force
This Privacy policy came into force on … 2019