PROTECTION OF PERSONAL DATA AND PRIVACY POLICY

Website Privacy Agreement
During your visit to this website and your use of the services we provide through this site, the way the information we obtain about you and the services you request will be used and protected is subject to the terms set forth in this “Privacy Policy.” By visiting this website and requesting to benefit from the services we offer through this site, you accept the terms specified in this “Privacy Policy.”

I. Purpose of the Policy on Protection and Processing of Personal Data

Due to the sensitivity of the business activities we have undertaken as BEAUTY FLIGHTS, the data received from our customers or prospective customers has always been kept confidential and has never been shared with third parties. The protection of personal data is a fundamental policy of our company. Even before any legal regulations were in place, our company and its subsidiaries attached great importance to the confidentiality of personal data, adopted this as a working principle, and instructed its employees to comply with this principle. As BEAUTY FLIGHTS, we commit to complying with all responsibilities imposed by the Personal Data Protection Law. The principles of our company regarding the protection of personal data also cover our subsidiaries.

II. Scope and Amendments to the Policy on Protection and Processing of Personal Data

This Policy, prepared by our company, has been drafted in accordance with the Personal Data Protection Law No. 6698 (“KVKK”). The law has come into full effect as of today. The data obtained from you with your consent or in accordance with other legal compliance reasons specified in the Law will be used to improve the quality of the services we provide and to enhance our quality policy. Additionally, some of the data in our possession is depersonalized and anonymized. These data are used for statistical purposes and are not subject to the Law or our Policy.

The BEAUTY FLIGHTS Personal Data Protection and Processing Policy aims to protect the automatically obtained data of our customers, prospective customers, employees, customers and employees of companies working in partnership with us, and other individuals, and includes relevant regulations. Our company reserves the right to amend our policy and regulations in compliance with the Law and for better protection of personal data.

III. Fundamental Principles Regarding the Processing of Personal Data

1. a) Compliance with the Law and the Principle of Good Faith:
   BEAUTY FLIGHTS verifies the source of the data it collects or receives from other companies and ensures that it is obtained in compliance with the law and the principles of good faith. In this context, BEAUTY FLIGHTS issues necessary warnings and notifications to third parties (including agents and other intermediaries) who sell its services to ensure the protection of personal data.
2. b) Accuracy and, When Necessary, Up-to-Date Information:
   BEAUTY FLIGHTS places great importance on ensuring that all data within the organization is accurate, does not contain incorrect information, and is updated whenever changes are communicated.
3. c) Processing for Specific, Explicit, and Legitimate Purposes:
   BEAUTY FLIGHTS processes data only for the purposes for which it has obtained consent from individuals and limits data processing to those specific purposes. It does not process, use, or allow the use of data for purposes beyond those intended.
4. d) Being Relevant, Limited, and Proportionate to the Purpose of Processing:
   BEAUTY FLIGHTS uses personal data strictly within the scope of the intended purpose and only to the extent required by the service provided.
5. e) Retention for the Period Prescribed by Law or Necessary for the Purpose of Processing:
   BEAUTY FLIGHTS retains data derived from contracts for as long as required by law, including dispute resolution periods and obligations under commercial and tax laws. However, once these purposes are no longer applicable, the data is deleted or anonymized.

It is important to note that the above principles apply regardless of whether BEAUTY FLIGHTS has collected or processed the data with consent or in compliance with the law.

According to Article 11 of the Personal Data Protection Law, you have the following rights. To facilitate the exercise of these rights, BEAUTY FLIGHTS has also prepared a dedicated application form for you.

Individuals whose personal data is processed may contact the relevant department announced on our BEAUTY FLIGHTS website to exercise their rights regarding their personal data, including:

1. a) Learning whether their personal data has been processed,
   b) Requesting information if their personal data has been processed,
   c) Learning the purpose of processing personal data and whether they are used in accordance with that purpose,
   d) Knowing the third parties to whom personal data is transferred domestically or internationally,
   e) Requesting the correction of personal data if it has been processed incompletely or inaccurately,
   f) Requesting the deletion or destruction of personal data under the conditions set forth in the law,
   g) Requesting that the actions taken under (e) and (f) be notified to third parties to whom personal data has been transferred,
   h) Objecting to any unfavorable outcome resulting exclusively from the analysis of processed data through automated systems,
   i) Requesting compensation for damages incurred due to the unlawful processing of personal data. As BEAUTY FLIGHTS, we respect these rights.

Maximum Savings Principle/Economy Principle

According to this principle, referred to as the Maximum Savings Principle or Economy Principle, data reaching BEAUTY FLIGHTS is only processed into the system to the extent necessary. Therefore, the data collected is determined based on the purpose. Unnecessary data is not collected. Other data that reaches our company is also transferred to the company’s information systems in the same way. Excessive information is not recorded into the system, but is either deleted or anonymized. These data may be used for statistical purposes. Health data, which is a special category of data, is only collected for the purpose of providing better service to customers and protecting their health, and it is carefully maintained in the system.

Deletion of Personal Data

When the legal retention periods expire, judicial processes are completed, or other requirements are no longer applicable, these personal data are either automatically deleted, destroyed, or anonymized by our company, either on its own or upon the request of the relevant individual.

Accuracy and Data Currency

As a rule, the data within BEAUTY FLIGHTS is processed as declared by the relevant individuals. BEAUTY FLIGHTS is not required to verify the accuracy of the data declared by customers or individuals who contact BEAUTY FLIGHTS, nor is this done due to legal and operational principles. The declared data is accepted as accurate. The principle of accuracy and currency of personal data is also adopted by BEAUTY FLIGHTS. Our company updates the personal data it processes from official documents it receives or upon request from the relevant individual. Necessary precautions are taken for this.

Privacy and Data Security

Personal data is confidential, and BEAUTY FLIGHTS adheres to this confidentiality. Personal data can only be accessed within the company by authorized individuals. Necessary technical and administrative measures are taken to ensure the protection of personal data collected by BEAUTY FLIGHTS and to prevent unauthorized access, ensuring that our customers and prospective customers are not harmed. In this context, software compliance with standards, careful selection of third parties, and adherence to the data protection policy within the company are ensured.

1. Purposes of Data Processing

The collection and processing of personal data by BEAUTY FLIGHTS shall be carried out for the purposes specified in the information notice. The data are collected and processed for the establishment of contracts and to provide better service to customers.

1. Collection and Processing of Customer, Potential Customer, and Business Partner Data for Contractual Relationships

If a contractual relationship has been established with our customers or potential customers, the collected personal data may be used without the customer’s explicit consent. However, such use is limited to purposes directly related to the contract. The data are utilized to improve the execution of the contract and to meet the requirements of the service, and are updated by contacting the customers when necessary.

On the other hand, the data voluntarily provided by potential customers are processed in order to offer them easier and higher-quality service. If no contractual relationship results from these interactions, the data are deleted upon request.

Business Partner Data

BEAUTY FLIGHTS adopts the principle of acting in compliance with the law when sharing data with its business and solution partners. Data are shared with business and solution partners under a confidentiality commitment and only to the extent necessary for the service. These parties are also required to take appropriate measures to ensure data security.

Processing of Data for Advertising Purposes
In accordance with the Law on the Regulation of Electronic Commerce and the Regulation on Commercial Communication and Commercial Electronic Messages, electronic messages for advertising purposes may only be sent to individuals who have given prior consent. The existence of the recipient’s explicit consent is a prerequisite for sending advertisements. BEAUTY FLIGHTS complies with the specific requirements and details regarding “consent” as defined under the relevant legislation.

Data Processing Due to the Company’s Legal Obligations or Explicit Legal Provisions
Personal data may be processed without obtaining additional consent if the processing is explicitly provided for in the relevant legislation or necessary for the fulfillment of a legal obligation stipulated by law. The type and scope of data processing must be necessary for the legally permitted data processing activity and must comply with the applicable legal provisions.

Processing of Data by the Company
Personal data may be processed in line with the services offered by the Company and its legitimate purposes. However, under no circumstances may the data be used for any services that are contrary to the law.

Processing of Special Categories of Personal Data
According to the Law, data relating to an individual’s race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, appearance and dress, membership in associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data, are classified as special categories of personal data.
In the processing of special categories of personal data, BEAUTY FLIGHTS takes additional measures as determined by the relevant Authority. Special categories of personal data are processed by BEAUTY FLIGHTS only for the purposes for which they were collected and only with the individual’s explicit consent, to enable the provision of better services.

Data Processed Through Automated Systems
BEAUTY FLIGHTS processes data through automated systems in compliance with the Law. Information obtained from such data cannot be used against individuals without their explicit consent. However, BEAUTY FLIGHTS may make decisions regarding individuals it will engage in transactions with, based on the data processed within its own systems.

Cookie Policy
Like many websites, BEAUTY FLIGHTS uses cookies and similar technologies to improve users’ browsing experience and enhance the quality of its services. The BEAUTY FLIGHTS Cookie Policy has been prepared to inform website users about cookies and the types of cookies used, and to guide them on how to manage their cookie preferences.

If you do not approve the use of cookies, we kindly ask you not to continue using the website or to change your cookie preferences as outlined in this Policy. Please note that if cookies are not permitted, certain features of the website may lose their functionality.

What is a Cookie?
A cookie is a small text file stored on your computer or mobile device when you visit a website. These files can store data such as your IP address, session information, pages accessed, and similar information. Cookies enable the website to remember your preferences, keep your session active, or offer content relevant to your interests.
For more detailed information about cookies, you may visit www.aboutcookies.org and www.allaboutcookies.org.

Types of Cookies
Cookies are categorized based on criteria such as the duration of their storage on mobile devices and by whom they are placed. Based on these criteria, the main classification is as follows:

Session Cookies:
Session cookies are temporary cookies that are deleted from the device once the browser is closed. The primary function of these cookies is to ensure the proper operation of the website.

Persistent Cookies:
Persistent cookies remain on the device after the browser is closed and are only deleted when manually removed by the user or upon expiration.

First-Party Cookies:
First-party cookies are cookies placed on the device by the operator of the website being visited.

Third-Party Cookies:
Third-party cookies are placed and controlled by parties other than the operator of the website being visited.

In cases where personal data is collected, processed, or used through BEAUTY FLIGHTS’ websites, systems, or applications, individuals are informed through a privacy notice and, where necessary, about the use of cookies. Individuals are also notified regarding the applications on our websites. Personal data shall be processed in accordance with the applicable legal regulations.

When you visit our website, we present the following information regarding the cookies we use or may use.

Cookies Used on the BEAUTY FLIGHTS Website
In accordance with the Privacy Policy, BEAUTY FLIGHTS uses various types of cookies.

Strictly Necessary Cookies:
These are technical cookies that ensure the proper functioning of the website and enable you to use its features. They fall under the category of session cookies. Blocking these cookies may result in the website’s features becoming unavailable. The use of strictly necessary cookies does not require your consent.

Analytical Cookies:
Analytical cookies are used to improve your website experience. These cookies help us understand how you use the website (e.g., which pages you visit, the duration of your visit, etc.). This enables us to enhance the content we provide or modify the website’s design accordingly.

Functionality Cookies:
Functionality cookies allow your preferences, such as language selection or region choice, to be remembered when you revisit the website.

Targeting/Advertising Cookies:
BEAUTY FLIGHTS uses different first-party and third-party cookies for targeting and advertising purposes on its website. You can block these cookies by changing your browser settings or by adjusting your cookie preferences as explained in this Policy.

How to Change Your Cookie Preferences
You can customize or completely block cookies by changing your browser settings. Detailed information on the steps to follow for different browsers can be found at the links provided below:

You can review the help or support page of the relevant browser to manage cookie preferences in other browsers.

Your Rights Regarding Your Personal Data
As a data subject, you can apply to BEAUTY FLIGHTS and:

•  Learn whether your personal data is being processed,
  · Request information if your personal data has been processed,
  · Learn the purpose of processing your personal data and whether it is used in accordance with that purpose,
  · Know the third parties to whom your personal data has been transferred domestically or abroad,
  · Request the correction of your personal data if it has been processed incompletely or inaccurately and request that these corrections be communicated to third parties to whom the personal data has been transferred,
  · Request the deletion or destruction of your personal data if the reasons requiring its processing cease to exist, even though it has been processed in accordance with the provisions of Law No. 6698 and other relevant laws, and request that these actions be notified to third parties to whom the personal data has been transferred,
  · Object to any adverse result arising from the analysis of your processed data exclusively through automated systems,
  · Request compensation if you suffer damage due to the unlawful processing of your personal data.

If you submit your requests regarding the rights listed above to our Company in accordance with the procedures set forth in the Communiqué on the Principles and Procedures for the Request to Data Controller, BEAUTY FLIGHTS will respond to your request as soon as possible and no later than 30 (thirty) days free of charge. However, if the process requires an additional cost, BEAUTY FLIGHTS may charge the fee determined by the Personal Data Protection Board.

Functional and Analytical Cookies
Functional and analytical cookies collect data about your preferences, the efficient use of the website, the optimization of the site to meet user demands, and how visitors use the site. Due to their nature, these types of cookies may contain personal information such as your username.

Third-Party Cookies
BEAUTY FLIGHTS websites and mobile websites collaborate with trusted, well-known third-party advertising providers. These third-party service providers place their own cookies to deliver personalized advertisements. Cookies placed by third parties collect, process, and analyze the browsing data and behavior of visitors on websites.

Commercial Cookies
Commercial cookies are used to offer products or content similar to your interests and preferences and to enhance your user experience by providing a more advanced and personalized advertising portfolio.
The storage duration of the aforementioned session, persistent, functional, analytical, and commercial cookies is approximately 2 (two) months, and users can make the necessary adjustments through their internet browser settings. The removal process of these cookies may vary depending on the browser used.

How Can I Delete Cookies?
Most internet browsers are initially set to automatically accept and use cookies. You can block cookies or set your device to alert you when cookies are sent by using your internet browser’s help or settings menus. To learn more about how to manage cookies and adjust your browser settings, you can refer to your browser’s instruction or help options.

1. Data Related to Our Employees
   Processing Data for Employment Relationships
   The personal data of our employees may be processed without obtaining consent to the extent necessary for the establishment and maintenance of the employment relationship and for health insurance purposes. However, BEAUTY FLIGHTS ensures the confidentiality and protection of employee personal data.

Processing Due to Legal Obligations
BEAUTY FLIGHTS may process the personal data of its employees without obtaining consent if such processing is expressly stipulated in the relevant legislation or is necessary for the fulfillment of a legal obligation. This is strictly limited to obligations arising from the law.

Processing for the Benefit of Employees
BEAUTY FLIGHTS may process personal data without obtaining consent for transactions that benefit its employees, such as private health insurance. BEAUTY FLIGHTS may also process employee data in cases of disputes arising from employment relationships.

Processing of Special Categories of Personal Data
According to the Law, data concerning a person’s race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and attire, membership in associations, foundations, or trade unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data, are considered special categories of personal data.
In processing special categories of personal data, BEAUTY FLIGHTS takes all necessary measures determined by the Board in addition to obtaining the individual’s explicit consent. Such special categories of personal data may only be processed without consent in cases permitted by law and strictly for the relevant purposes. Special category data obtained from employees for the purposes of insurance and healthcare services are used solely for these specific purposes.

Data Processed Through Automated Systems
Data related to employees processed through automated systems may be used in internal promotions and performance evaluations. Employees have the right to object to any outcome that may arise against them and must do so in accordance with internal company procedures. Objections raised by employees are evaluated within the company.

Telecommunications and Internet
Computers, phones, emails, and other applications allocated to employees within the company are provided solely for business purposes. Employees may not use these tools for private purposes or personal communication. The company reserves the right to monitor and audit all data and activities conducted via these tools. Upon commencing employment, the employee undertakes not to store any non-business-related data or information on company-provided computers, phones, or other devices.

VII. Transfer of Personal Data Within and Outside the Country
Personal data may be shared by BEAUTY FLIGHTS with business partners, affiliates, and subsidiaries for the purpose of providing services.

BEAUTY FLIGHTS may transfer personal data to the following persons and institutions for specific purposes:

• To BEAUTY FLIGHTS’ business partners, limited to the fulfillment of the purposes of establishing business partnerships,
• To BEAUTY FLIGHTS’ suppliers, limited to the services procured externally from suppliers to fulfill the company’s commercial activities,
• To BEAUTY FLIGHTS’ solution partners, limited to conducting commercial activities involving affiliates,
• To BEAUTY FLIGHTS’ affiliates.

BEAUTY FLIGHTS is authorized to transfer personal data domestically and internationally in compliance with the conditions determined by the Board and other provisions of the Law, based on the individual’s consent.

VIII. Rights of the Data Subject
BEAUTY FLIGHTS acknowledges that individuals have the right to give consent before their personal data is processed and, after processing, the right to determine the fate of their personal data.

By applying to the contact addresses announced on our website, individuals may exercise the following rights regarding their personal data:

1. To learn whether their personal data is being processed,
2. To request information if their personal data has been processed,
3. To learn the purpose of the processing and whether it is being used in accordance with its purpose,
4. To know the third parties to whom personal data is transferred domestically or abroad,
5. To request correction of personal data if it is incomplete or inaccurate,
6. To request the deletion or destruction of personal data within the framework of the conditions set forth in Article 7 of the Law,
7. To request that the transactions carried out pursuant to subparagraphs (e) and (f) be notified to third parties to whom the personal data has been transferred,
8. To object to a result arising against the individual through the exclusive analysis of processed data via automated systems,
9. To request compensation for damages if personal data is processed unlawfully and the individual suffers harm as a result.

However, individuals have no rights regarding anonymized data. Within the Company, individuals hold no rights over anonymized data. BEAUTY FLIGHTS may share personal data with relevant institutions and organizations for the purpose of fulfilling a judicial duty or enabling the exercise of statutory powers by a state authority, based on its business and contractual relationships.

Personal data owners may submit their requests concerning the aforementioned rights by fully completing the application form available on the Company’s official website at www.beautyflights.com, signing it with a wet signature, and sending it via registered mail along with a photocopy of their identity card (only the front side for identity cards) to the following address:
Nisbetiye Mahallesi Gazi Güçnar Sokak Uygur Business Center Apt. No: 4/2 Office No: 703 Beşiktaş/İstanbul.
Requests will be answered as soon as possible depending on the nature of the request, and no later than 30 days following receipt by the Company.
Applications must be made via registered mail. Furthermore, only requests concerning your own personal data will be answered; applications made on behalf of a spouse, relative, or friend will not be accepted. BEAUTY FLIGHTS reserves the right to request additional relevant information and documentation from the applicant.

1. Principle of Confidentiality
   All data belonging to employees or other individuals within BEAUTY FLIGHTS is considered confidential. No one may use, copy, reproduce, transfer to others, or utilize such data for purposes other than business activities without a contractual obligation or legal compliance.
2. Data Security

All necessary technical and administrative measures are taken by BEAUTY FLIGHTS to protect collected personal data, prevent unauthorized access, and avoid any harm to our customers and potential customers. In this context, it is ensured that software is compliant with standards, third parties are carefully selected, and internal compliance with data protection policies is maintained. Security measures are continuously updated and improved.

1. Audit
   BEAUTY FLIGHTS conducts necessary internal and external audits to ensure the protection of personal data.

XII. Notification of Breaches
BEAUTY FLIGHTS will immediately take action to rectify any breach related to personal data upon being notified of such an incident. The Company will minimize the harm to the affected individual and compensate for any damages. If personal data is accessed by unauthorized individuals, BEAUTY FLIGHTS will promptly notify the Personal Data Protection Authority.

For breach notifications, applications can also be made following the procedures outlined at https://beautyflights.com.

Contact
For any questions or requests regarding the privacy agreement, you can send a registered letter to the address below.

BEAUTY FLIGHTS
Get Well Sağlık Hizmetleri Limited Şirketi
Adres: Nisbetiye Mahallesi Gazi Güçnar Sokak Uygur Business Center Apt. No: 4/2 Office No: 703 Beşiktaş/İstanbul