1. Data Controller
This AI Chatbot Privacy Notice explains how your personal data is processed when you use our chatbot and webchat support services.
The data controller is:
Turistik Hava Taşımacılık A.Ş. Güzeloluk Mah. 1879. Sok. No: 148, Muratpaşa / Antalya / Türkiye
2. Scope of this Notice
This notice applies to personal data processed when you access and use our chatbot or webchat support channel available on our website or related digital platforms.
This notice applies specifically to the chatbot process and should be read together with our general Privacy Notice, Cookie Policy, and any other privacy information made available to you through our website or customer interfaces.
3. Categories of Personal Data Processed
When you use the chatbot service, we may process the following categories of personal data:
- identity and contact data, such as your name, surname, email address, and telephone number
- communication data, such as the content of your messages, questions, replies, attachments, and interaction history within the chat
- customer support and case management data, such as chat transcripts, request history, ticket details, resolution notes, and related customer service records
- technical and usage data, such as date and time of the interaction, session information, device/browser information, IP-related logs where applicable, and system event records
- internal record data, such as customer or contact card information created and maintained in our communication management systems
Where relevant, some of the above data may be associated with your existing customer profile or prior interactions with us.
4. How the Chatbot Service Operates
When you initiate a chat, certain personal data including your name, surname, email address and telephone number may be collected in order to create and manage your contact or customer record within our communication infrastructure.
The content of your chat messages is processed in order to respond to your questions, assist with your requests, maintain communication continuity, and where necessary escalate the matter to human support teams.
The chatbot service is supported through third-party service providers.In particular:
- Our communication infrastructure provider may process your identity, contact, and chat data for the operation of the chat service and the creation and maintenance of contact records
- AI-supported response generation may be carried out through third-party AI technologies used to analyze your message content and generate or support responses
- Your personal data may therefore be processed both in third-party systems used for the operation of the chatbot and in our own internal systems and databases.
5. Purposes of Processing
We process your personal data for the following purposes:
- to provide the chatbot and webchat service
- to identify you and create or maintain your contact or customer record
- to receive, manage, and respond to your requests, questions, complaints, or support needs
- to ensure service continuity and allow follow-up by our customer service teams where required
- to document customer communications and maintain service records
- to improve the quality, consistency, and efficiency of our customer communication processes
- to maintain the security, integrity, and proper functioning of our systems
- to detect misuse, fraud, unauthorized access, or other harmful activity
- to establish, exercise, or defend legal claims where necessary
- to comply with legal and regulatory obligations
6. Legal Bases for Processing
Depending on the context of the interaction, your personal data may be processed on one or more of the following legal bases:
- where processing is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract
- where processing is necessary for our legitimate interests, including the operation of customer communication channels, service continuity, quality assurance, fraud prevention, system security, and the efficient handling of customer requests, provided that such interests do not override your fundamental rights and freedoms
- where processing is necessary for compliance with legal obligations applicable to us
- where required by applicable law, on the basis of your explicit consent If explicit consent is used for any specific processing activity, this will be presented to you separately where required.
7. Use of AI-Supported Technologies
As part of the chatbot service, we may use AI-supported tools to analyze chat content and generate or support responses to your requests.
Such tools are used to improve response speed, consistency, and service efficiency. However, the chatbot may not always provide complete, accurate, or appropriate responses in all circumstances. Where necessary, requests may be escalated to human personnel for further review and handling.
We recommend that you do not share unnecessary sensitive personal data in the chat unless this is strictly necessary for your request.
Where technically and operationally possible, we seek to limit the personal data shared with AI-supported systems to what is necessary for the relevant processing purpose.
8. Recipients and Service Providers
Your personal data may be shared with or made accessible to:
- our customer communication infrastructure providers, including providers supporting chat operations and customer record creation
- AI technology providers supporting chatbot response generation or related processing activities
- our internal customer support, operations, IT, legal, compliance, and authorized management teams on a need-to-know basis
- other group companies or affiliated entities where relevant and lawful
- public authorities, regulators, courts, law enforcement bodies, or other third parties where disclosure is required by law or necessary for the establishment, exercise, or defense of legal claims
All such access or sharing is limited to what is necessary for the relevant purpose and subject to appropriate contractual, technical, and organizational safeguards where required.
9. International Data Transfers
Because some of our technology providers or their sub-processors may operate internationally, your personal data may be transferred to and processed in countries outside your country of residence or outside the jurisdiction from which the data originates.
Where such international transfers take place, we implement the transfer mechanism required under applicable data protection law, including where relevant adequacy decisions, standard contractual clauses, or other legally recognized safeguards.
You may contact us for more information regarding the safeguards applied to international transfers where applicable.
10. Retention Periods
Your personal data will be retained only for as long as necessary for the purposes described in this notice, including the handling of your request, the maintenance of service records, the management of customer communications, legal compliance, dispute resolution, and the protection of our rights and interests.
Specific retention periods may vary depending on the nature of the interaction, the applicable legal obligations, and the operational requirements of the service.
11. Source of Personal Data
In most cases, personal data processed through the chatbot is collected directly from you when you enter your information and communicate through the chat.
Where relevant, we may also link or supplement this information with data already held in our systems in connection with your existing customer relationship, previous requests, bookings, transactions, or support history.
12. Whether the Provision of Data is Mandatory
Certain personal data may be necessary for the operation of the chat service or for the handling of your request. If you do not provide the required information, we may be unable to initiate or maintain the chat session, verify your request, or provide effective support.
13. Automated Processing
The chatbot may use automated processing to interpret your messages and generate or support responses. However, unless explicitly stated otherwise, the chatbot is not intended to make solely automated decisions producing legal effects or similarly significant effects on you.
If your request requires human assessment, intervention, or decision-making, it may be escalated accordingly.
14. Your Rights
Subject to the requirements and limitations under applicable law, you may have the right to:
- request access to your personal data
- request correction of inaccurate or incomplete personal data
- request deletion of your personal data
- request restriction of processing
- object to certain processing activities
- request data portability where applicable
- withdraw your consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal
- lodge a complaint with the competent data protection authority
To exercise your rights, please contact us at:
15. Security Measures
We implement appropriate technical and organizational measures designed to protect personal data against unauthorized access, alteration, disclosure, loss, or misuse.
These measures include access controls, role-based restrictions, contractual safeguards with service providers, logging and monitoring where appropriate, and other reasonable security practices proportionate to the nature of the processing.
16. Updates to this Notice
We may update this AI Chatbot Privacy Notice from time to time in order to reflect changes in legal requirements, technical infrastructure, service providers, or processing practices. The updated version will be made available through the relevant website or digital interface.