Privacy Policy

This Website is operated by Karnak Travel Karnak is a brand of a company organized and existing under the laws of Turkey and registered under Commercial Registry no Istanbul 8711, having its registered office at Ergenekon Mah. Halaskargazi Cad. No: 25/1, Harbiye – Şişli, Istanbul, 34384, TURKEY Your privacy is very important to Karnak Travel. This Privacy Policy describes the principles and practices that apply to Personal Information (defined below) collected from users of our services (“you”) on our Website (defined below), in telephone or email communications.

Simply put:

• We will not collect Personal Information without your knowledge and permission;
• We will not knowingly disclose your Personal Information to third parties, except as provided in this Privacy Policy;
• We will allow you to view, correct or remove your Personal Information; and
• We will take reasonable steps to protect the security of the Personal Information we collect from you.

1. Use of cookies
   A cookie is a small text file that is placed on your computer by websites that you visit, and a pixel tag is a request for an invisible graphic that may cause a cookie to be set. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the website. 
   
   Some web browsers automatically accept all cookies, but allow some control of most cookies through the browser settings. Other web browsers only accept certain types of cookies. You can instruct your browser, by editing its options, to stop accepting cookies or prompt you before accepting a cookie from the websites you visit. If you decide not to accept our cookies or you decide to delete our cookies, you will be able to access certain parts of our Website, but you will not be able to access many of the Products and Services offered through our Website and you will not be able to book Products or Services offered through our Website. 
   
   The remainder of this policy describes our Personal Information handling practices in detail. 
   
   2. Definitions 
   
   In this Privacy Policy, terms that commence with a capital letter are defined in this section or in the preamble, as follows: 
   
   ” Guest” means an individual who can search and Purchase Products or Services on our Website without being a Member. 
   ” Member” means an individual who has registered with our Website. Members choose a Member ID and a password. 
   ” Member ID” means the email address Members use (with your password) to login to our Website. 
   “Karnak Travel ” ” us,” ” our, ” or ” we” means KARNAK DIS TIC. VE TURIZM LTD.ŞTİ. and its subsidiaries and group companies.
   ” Personal Information” means any information, recorded in any form, which identifies an individual either on its own or when combined with other information which we hold on that individual, or which a third party holds on that individual and to which we could obtain access. This includes, for example, name, email and mailing address and telephone number, billing and account information, and other information incidental to providing Products or Services (including information about individuals travelling with you). 
   ” Products or Services” means the airline, travel, hotel accommodation, car rental, ground transportation, tours, attractions, travel insurance and other items available through our Website. 
   ” Purchase” means to book, reserve or purchase. 
   ” Sensitive Personal Information” means Personal Information which relates to an individual’s race, ethnicity, physical or mental health, political opinions, religious beliefs, sexual life, trade union membership, criminal offences or alleged offences. 
   ” Session Data” means usage information, such as the type of Internet browser and operating system an individual uses, the domain name of the site from which the individual came, the date, time and duration of the visit, number of visits, pages viewed and number of cookies accumulated, and in the case of the Karnak Travel mobile site and applications, also means the unique identifier of an individual’s mobile device, the type of mobile device the individual uses and the application version. This information is anonymous and does not identify individual visitors to our Website.
   ” Website” means the www.karnakonline.com site, the www.karnakonline.com mobile site or the Karnak Travel mobile applications, and their respective sub sites, together with the respective content, Products and Services available from these sites and sub sites.
   ” Subscriber” means an individual who elects to receive offers or promotions from Karnak Travel without becoming a Member or a Guest.
   
   3. Consent 
   
   BY SUBMITTING PERSONAL INFORMATION TO US, AND/OR BY USING OUR WEBSITE, YOU AGREE THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW. 
   
   WHERE YOU ARE PROVIDING PERSONAL INFORMATION OF A THIRD PARTY TO US, YOU CONFIRM THAT YOU HAVE OBTAINED CONSENT TO PROVIDE US WITH SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY. 
   
   If you do not agree with these terms, please do not use our Website or provide any Personal Information to us. You may withdraw your consent at any time. If you refuse or withdraw your consent, or if you choose not to provide us with any required Personal Information, we may not be able to provide you with Products or Services that can be offered on our Website only if we have access to certain Personal Information. 
   
   Minors 
   Minors (as defined under the laws of their jurisdiction or residence) are not eligible to register for, use, or Purchase Products or Services on our Website directly. 
   Other Travelers or Contacts 
   If you Purchase Products or Services on behalf of a third party using your Member ID and password, or if you provide us with contact information of a third party at any time, you must make sure that you have the right to do so. By providing the Personal Information of a third party, you represent that you have all necessary authority and/or have obtained all necessary consents from such person to enable us to collect, use and disclose his or her Personal Information as set forth in this Privacy Policy. 
   
   4. What Personal Information we collect 
   
   When you are just visiting 
   You can visit certain areas of our Website without revealing who you are or signing-in. When you visit our Website as a visitor, Guest or Member, we collect Session Data through cookies and pixel tags, as described above. 
   
   When you use the Karnak Travel mobile site or applications, you may search for Products and Services in the area in which you are located. If you choose to do so, depending on the mobile device or application you are using, we may collect your geo-location information to search for the applicable Products and Services or to personalize and improve your individual viewing experiences on our Website and provide information that may be of interest to you. You may at any time disable our collection and use of your location information by turning location services off at the device level.
   
   When you register with us as a Member, we collect Personal Information that is necessary to provide the Products and Services. We require that you provide your name and email address. You also need to choose a password, which will be required to gain access to portions of our Website reserved for Member use. We might also request your home postcode. 
   
   You may elect to indicate your preferences for seat selection or meal requests, or provide details about your participation in loyalty or awards programs and applicable membership numbers, and other ticketing options. You may cancel your registration at any time. 
   
   When you Purchase Products or Services 
   When you Purchase Products or Services, you must provide payment or other necessary information. This includes, for example, name and address, billing information (such as credit card and account information), email address, telephone number, information on travel preferences (for example information on desired flight meals, necessary assistance during boarding), age, information about your membership or customer loyalty discount programs, dates for entry into other countries especially the United States of America (usually flight origin, flight destination, flight time, duration of flight, seat number, travel agency), driver information or similar information, as required by the travel service provider(s). 
   
   If you are using our Website as a Guest, you must also provide an email address, so that we can send you our welcome email and a confirmation of the Purchase. With the confirmation, we will provide you with a temporary password so that you can return to our Website if you wish to review information about your Purchase. 
   
   When you Purchase Products or Services for a third party 
   When you Purchase Products or Services for a third party using your Member ID and password, you must provide that third party’s name and contact information, and other information, as required by the travel service provider(s). 
   
   When you “Subscribe” 
   When you become a Subscriber, we collect your name and email address, so that you may receive offers or promotions from Karnak Travel without becoming a Member or Guest. You can cancel your subscription at any time.
   
   When we advertise on third party websites 
   When you visit a website on which we advertise and click through our advertisement, we may place cookies on your computer or use pixel tags. 
   
   When you call or write to our Customer Service 
   When you call or write to our Customer Service, we collect contact information (name, phone number, mailing address or email address) and information about the relevant Purchase as necessary to assist you. For example, if you call for assistance with a pre-existing Purchase, or to make a Purchase, we may request your contact and billing information. 
   
   When we send emails or e-newsletters 
   When we send emails, e-newsletters or when you forward a promotion or search results to a third party, using the “Send to a Friend” feature, we may insert a pixel tag in the email. If you choose to use our “Send to a Friend” feature, we will send your friend a one-time e-mail about the applicable information. We do not permanently store the e-mail address of such individuals. 
   
   Information you volunteer 
   We may collect Personal Information you provide voluntarily to us in addition to that information we specifically request. By providing Personal Information about yourself that is not requested by us, you are providing your consent to us processing that Personal Information (including any Sensitive Personal Information you may provide) for the purposes of any requests, enquiries, complaints or purchases you may make from us. You can withdraw your consent at any time. 
   
   Sensitive Personal Information 
   We may collect Sensitive Personal Information about you to ensure that any preference(s) or disabilities you have can be properly accommodated, where required, as part of the purchased Products or Services. The Sensitive Personal Information collected can include details about your religious affiliation, food requests based on religious affiliation, health information or special access requirements. We are required to obtain your consent prior to collecting Sensitive Personal Information. Please do not provide any Sensitive Personal Information if you do not consent to us collecting and processing this information. However, bear in mind that your preference(s) or disabilities may not be properly accommodated for if this information is not provided. We will only process Sensitive Personal Information about you for this purpose and as otherwise set out in our Privacy Policy. 
   
   When you write a review or comment 
   If you submit a review or comment on our Website, you should be aware that any Personal Information you submit can be read, collected or used by other users. We are not responsible for the Personal Information you choose to submit in reviews or comments and such disclosure of Personal Information by you is strictly voluntary. If you wish to request the removal of your Personal Information that you submitted in a review or comment, you can do so by contacting us as indicated in Contact Information. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why. 
   
   5. How we use the information we collect 
   
   We use Personal Information in order to provide and enhance the Products or Services offered on our Website: 
   •    To record your travel preferences, to make reservations or acquire travel insurance on your behalf, or to communicate with you about your travel plans; 
   •    To issue invoices, administer accounts, collect and process payments; 
   •    To provide tips or guidance on how to use our Website, inform you of new features on our Website, or provide other information that may be of interest to users; 
   •    To personalize the service we provide to you, tailor your experience of our Website to suit your interests and to allow us to make more appropriate travel recommendations to you; 
   •    To send you emails, e-newsletters, personalized offers via direct messaging or other communications about our services, if you have subscribed to receive this information; 
   •    To manage our Website, diagnose technical problems, improve content, and allocate the resources of our systems so that your experience with our Website is as efficient as possible; 
   •    To process and track your transactions and to send you information about us and our group companies and business partners’ products and services and other information and materials that may be of interest to you but only if you have granted us permission to do so or we are otherwise able to do so under applicable law; 
   •    To send you surveys asking questions about your customer experience – sometimes we use third parties to administer such surveys; 
   •    To validate that we have provided you with the appropriate insurance, as applicable; 
   •    To develop, enhance, market, sell or provide Karnak Travel Products or Services, or those of companies with which we have a commercial relationship, but only if you have granted us permission to do so or we are otherwise able to do so under applicable law;
   •    To investigate, detect and protect Karnak Travel and other third parties against error, negligence, breach of contract, fraud, theft and other illegal activities;
   •    To effect a corporate transaction, in connection with the sale, merger, spin-off, or other corporate reorganization of our corporation, where the information is provided to the new controlling entity in regular course of business; 
   •    To audit compliance with our policies and contractual obligations; 
   •    As permitted by, and to comply with, any legal or regulatory requirements or provisions; and/or 
   •    For any other purpose to which you consent. 

Session Data
We use Session Data, collected through cookies and pixel tags, to better understand how our Website is navigated, how many visitors arrive at specific pages, the length and frequency of stays at our Website, the variety of searches of our Website’s database, the types of browsers and computer operating systems used by our visitors and the Internet Protocol addresses from which visitors connect to our Website. We also use this information to improve our Website content and ease of use, to personalize and improve your individual viewing experiences on our Website, and provide information that may be of interest to you.

Pixel Tags
We use pixel tags to monitor the open rate of our communications. This helps us understand the effectiveness of communications we send. We do not use this information for any other purpose.

Aggregated Information
Aggregated information is information, recorded in any form, about more than one individual, where the identity of the individual is not known, and cannot be inferred from the information. We may use aggregated information to describe our user base to current or potential partners, investors and advertisers; after a survey, to understand and respond to market needs and preferences; or to make recommendations to other users of our Website. For example, if users of our Website who have travelled to a particular destination told us that they had positive experiences at a hotel in that destination, we might recommend that hotel.

What we do NOT do
We do not and will not, at any time, request your credit card information, Member ID, login password, or national identification numbers in a non-secure or unsolicited email or telephone communication.

6. To whom we disclose Personal Information

We will not share your information with third parties except as described in our Privacy Policy. We do not sell your Personal Information to third parties for their promotional purposes.

We may disclose your Personal Information as follows:

•    To those travel service providers with which you make arrangements through our Website, for example, airlines, car rental, hotel, ground transportation or travel insurance. We provide them with the Personal Information needed to make and complete the purchase, booking, or reservation.
•    To other entities within the Karnak Travel which include Karnak Travel in order to make arrangements for your Products or Services on our behalf, or procure that organizations perform services for us or the Karnak Travel. Such other entities may be located in countries outside the European Economic Area (“EEA”). Where transfers to such non-EEA entities occur, a Data Transfer Agreement will have been put into place in accordance with standard contractual clauses adopted by the European Commission on 27 December 2004 (Decision 2004/915/EC).
•    To organizations that perform services for you or on behalf of Karnak Tarvel, for example to provide customer service, deliver tickets, ship items, process credit cards, submit email communications to you on our behalf, for research, marketing, data processing, data storage, to measure the use of our Website or to facilitate usage by a Visitor. We will share with these companies only that Personal Information which they need to work on our behalf. Some of these service providers may be located in countries outside the EEA. Your Personal Information will be provided to these organizations only if they agree to use such information solely for the purpose of providing services to Karnak Travel , and under the instructions of Karnak Travel, and with respect to that information, to act in a manner consistent with the relevant principles articulated in our Privacy Policy. Where transfers to such non-EEA entities occur, an adequate level of data protection will be ensured by either a Data Transfer Agreement in accordance with standard contractual clauses adopted by the European Commission on 5 February 2010 (Decision 2010/87/EC) or another legally acceptable method (Safe Harbor, Binding Corporate Rules).
•    To government or regulatory agencies that may be located outside the EEA, in order to comply with relevant legal or regulatory requirements or provisions, including but not limited to border control agencies.
•    We may collaborate with other companies to offer you additional Products or Services, for example, through promotions. We will share Personal Information with these other companies only if you have expressly permitted us to do so, or if we are permitted by law to do so.

Please note that there are circumstances where the use or disclosure of Personal Information may be justified or permitted, or where Karnak Travel may be obligated to disclose information without consent.

Security
In order to protect national security, and to ensure travel security, the United States Government and other governments may request access to passenger name records, which typically includes name, flight origin, flight destination, flight time, duration of flight, seat location, travel agent, form of payment, credit card numbers, travel itinerary, address, telephone number and meal requests. In response to such request, Karnak Travel and/or its providers will give access to all the information you provide at the time of making your reservation to the applicable government agencies of the countries to or from which you are travelling

7. How we retain and store Personal information

My Stuff
If you are an Karnak Travel  Member, we combine your Personal Information in what we call “My Stuff”, which consists of “My Trips” and “My Account”. You can access My Stuff from the Homepage of our Website, after logging onto our Website as a registered Member. My Trips contains information about your current, cancelled, or past trips. My Account contains your name, email address, password, and departure city from which you usually travel. It may also contain other information so that you do not need to re-enter it each time you Purchase a Product or Service. For example, My Account may contain your billing information unless you tell us not to store it. It may also contain your preferences for seat selection or special meals, details about your participation in loyalty or awards programs and applicable membership numbers, and other travel preferences.

We also keep in My Account all other information that you have elected to provide us, such as gender, favorite activities and lifestyle preferences, and favorite destinations.

My Account also contains a listing of the emails, e-newsletters and other communications we offer to send, and that you have elected to receive or not.

You can access, modify, or delete this Personal Information from time to time, as described below.

Third Parties’ Personal Information
We will retain in your My Stuff folder the Personal Information of individuals for whom you have made reservations. You can access, modify, or delete these third parties’ Personal Information at any time, as described below.

Retention and storage
We will retain your Personal Information in our databases in accordance with our document management, retention and destruction policy and applicable laws. This period may extend beyond the end of your relationship with us, but it will be only as long as it is necessary for us to have sufficient information to respond to any issues that may arise later. For example, we may need or be required to retain information to allow you to obtain credit for a trip you Purchased but had to cancel. We may also need the retain certain information to prevent fraudulent activity; to protect ourselves against liability, permit us to pursue available remedies or limit any damages that we may sustain; or if we believe in good faith that a law, regulation, rule or guideline requires it.

Your Personal Information will be stored in secured locations, and on servers controlled by Karnak Travel, located either at our offices, or at the offices of our service providers, as described below. Such secured locations may be located in countries outside the EEA.

8. How we protect Personal Information

Karnak Travel employs physical, administrative and technical safeguards to help protect the confidentiality and integrity of Personal Information and to reduce the risk of loss, misuse, unauthorized access disclosure or modification of Personal Information. When Personal Information is sent to our service providers, we require, in our contracts with them, that they protect all Personal Information in a manner consistent with the principles articulated in our Privacy Policy.

If you choose to contact Karnak Travel through our Website, you should be aware that any information transmitted electronically via the World Wide Web might not be secure. Karnak Travel assumes no liability for the loss of any information that you transmit to us via the World Wide Web. If you choose to Purchase Products or Services using a credit card, or if you choose to search for Products and Services, through the Karnak Travel mobile applications, that are located near you and we collect your geo-location, we encrypt the transmission of that information using secure socket layer technology (SSL) with 256 bit encryption.

In communicating with you, we may send email as unencrypted plain text because we are aware that most Members, Guests or Subscribers cannot readily process encrypted email. This is done for your convenience, but with the security concern that, if misrouted or intercepted, it could be read more easily than encrypted email.

9. How to access, modify or delete your Personal Information

We endeavor to ensure that Personal Information is as accurate, complete and current, as necessary for the purposes for which we use that information. We encourage you to visit your My Stuff folder to review your Personal Information.

You can access your Personal Information in My Stuff, update it, correct it or modify it, as necessary. For example, you can change at any time your email address, preferred activities or preferred destinations, or your preferences for receiving or not receiving our emails, e-newsletters or instant messaging customized advertisements.If you wish to modify or delete other Personal Information, you can do so by contacting us as indicated below. If you request that we remove all of the Personal Information or travel records stored in My Stuff, we will promptly do so, to the extent possible. Once required Personal Information is removed from My Stuff, however, you will not be able to use many of the services available on our Website to Members, unless you re-register. Please remember that we may not be able to honor your request if we are legally obligated to retain that information, or for other reasons, as described above.

10. Privacy

Opting-Out
As part of the Purchase or Member registration process, we give you the ability to receive via email or direct messaging information about our Products and Services, updates to our Website, customized advertisements and promotions that are targeted to your specific interest, such as flight specials, promotions and other travel opportunities available on our Website and/or sponsored by our travel service providers and advertisers. We send this information directly ourselves or via third party service providers. If you elect to receive these communications about our Website, we will send them to you. At any time, you may change which of the communications you wish to receive or not, by changing your preferences, as described above. In addition, in our emails and other communications, we will include instructions on how to unsubscribe and inform us of preferences if you decide you do not want to receive any future marketing or promotional emails from us. To opt-out of receiving the emails or communications of companies from which you have previously requested products or services, please contact them directly.

Monitoring
Karnak Travel may from time to time monitor and review any information transmitted or received through our Website, or through telephone or email communications, for quality assurance and training purposes. We reserve the right to censor, edit, remove, or prohibit the transmission or receipt of any information that Karnak Travel deems inappropriate, or in violation of our Terms and Conditions. During monitoring, the information may be examined, recorded or copied.

Links
For your convenience, our Website provides links to other websites. When you click on one of these links, you are leaving our Website and entering another website. We are not responsible for such third party websites. You should carefully review the privacy statements of any other websites you visit, because those privacy statements will apply to your visit to such other websites.

Social Plug-Ins
Our Website includes social plug-ins, such as the Facebook or Twitter button, and gives you the option to post information about your activities on our Website to your social media accounts. These features may collect your IP address, which page you are visiting on our Website, and may set a cookie to enable the feature to function properly. Social plug-ins are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing them.

1. Changes to our Privacy Policy
   
   We may change or supplement our Privacy Policy from time to time. We may also undergo a change of ownership. We will post an appropriate notice of changes to our Privacy Policy and changes or ownership on our Website. Privacy Policy changes will apply to the information collected from the date we post the revised Privacy Policy to our Website. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on our Website prior to the change becoming effective. 
   
   12. Contact information 
   
   If you have any questions or concerns about (a) access to Personal Information, (b) the collection, use, management or disclosure of Personal Information, (c) our Privacy Policy or our information handling practices, or (d) with whom your Personal Information is shared, or if you need further assistance with respect to our Privacy Policy, you may contact us as indicated below. We will attempt to respond to your questions or concerns promptly after we receive them. 
   
   Karnak Travel, a brand of KARNAK DIS TIC. VE TURIZM LTD. ŞTİ. a company organized and existing under the laws of Turkey and registered under Commercial Registry no, Istanbul 8711 , having its registered office at Ergenekon Mah. Halaskargazi Cad. No: 25/1, Harbiye Şişli, Istanbul, 34384, TURKEY