SECTION 1

We Care About Your Privacy!

As CABA Travel, we want you to be confident that the privacy of your personal data is really important to us. We are always committed to protect your personal information.

This Privacy Policy applies to personal information/data about you that we collect, use and otherwise process regarding your relationship with us as a customer (or a potential customer), including when you travel with us, or use our other services and websites, contact our service agents, or call centers and book to use our services through third parties (such as other travel agents).

By making a booking/purchase, or by submitting your personal data via our website or call centers, you agree for us to store and process your data as set out under this Privacy Policy.

 

SECTION 2

Data Control

Any personal information processed by us regarding this Privacy Policy is controlled by Caboğlu Turizm ve Sigortacılık Ltd., which is considered to be a “data controller” of your personal data under KITSAB data protection law.

Any provider of services, such as a hotel or a car rental company, will simultaneously be a “data controller”. You can access the Privacy Policies of those providers from them directly.

What Do We Mean By “Personal Data”?

For us, personal data (or personal information) is defined by all the details which identify you as an individual, or could be used to identify you. Please view the personal data we may collect from you below:

- Personal details - house address, e-mail address, phone number, and date of birth

- Account login details - username and password

- Travel and social preferences, interests and activities

- Passenger information - passport details, other ID document details

- Insurance details

- Payment information - credit or other payment information

- Relevant medical data and any special dietary, religious, or disability-related, requests

- Information about your browsing behavior on our website, when you click on one of our adverts, including those shown on other organizations’ websites

- Information about the way you access our digital services, including operating system, IP address, online identifiers and browser details

- Information about your purchases, including what you bought, when and where you bought it, how you paid for it and credit or other payment information

- Personal data you provide when you connect with us (including by e-mail, post, and phone, or through social media), such as your name, username and contact details

- Details of e-mails and other digital communications we send to you that you open, including any links in them that you click on

- Your feedback and contributions to customer surveys and questionnaires

- Personal data from other sources, such as specialist companies that supply information, retail partners, and public registers

- Personal data about other individuals provided by you, such as other people on your booking; you should ensure that third parties or other individuals on your booking consent for their personal data to be provided to us by you and that they understand how their personal data may be used by us

 

SECTION 3

What Do We Use Your “Personal Data” For?

The main purposes for which we use your personal information are:

1. To fulfill your travel arrangements and deliver the services you have asked for, as well as to contact you directly

I. We need to process your personal data so that we can manage your account or booking, provide you with the products and services you want to buy, and help you with any orders and refunds you may ask for.

II. We need to share personal data with suppliers for your travel arrangements, including airlines, hotels and transport companies, regulatory authorities and credit reference/fraud prevention agencies, police, law enforcement agencies, law firms and law courts, to enforce or apply any contract with you when appropriate.

III. We also work with carefully selected suppliers that carry out certain functions on our behalf such as suppliers of IT services, storing and combining data, marketing, campaign advertising, market research, processing payments and delivering products and services.

IV. We do not sell personal data.

2. To provide services tailored to your requirements, and to treat you in a more personal way

I. Your browsing behavior, purchases, your responses to marketing communications relating to products and services we offer, give us the opportunity to offer you products and services that are perfectly suitable for your needs, hence allowing us to provide you with personalized offers and services, planning of activities and excursions.

II. If you do not wish to receive a personalized service from us, you can change your preferences online, over the phone, or by writing (e.g. e-mail or post) to us at any time. Once your message is received, we shall amend our records accordingly.

3. To keep you informed about our products, services, and other offers

I. We may send you relevant offers and news about our products and services in a number of ways, including by e-mail. We will only do this if you previously agreed to receive these marketing communications.

II. You can change your marketing preferences online, over the phone or by writing (e.g. email or post) to us at any time and we shall amend our records accordingly.

III. If you ask us to stop sending marketing communications, please note that we will still retain your personal information for service-related communications (e.g. confirming bookings you make with us, providing important information about the use of our products or services).

4. To carry out research for improving our websites, products and services

I. We use personal data to carry out market research and internal research and development, and to improve our product range, services, shops, IT systems, security, personal data protection, prevention of fraud/ crimes, and know-how, as well as the way we communicate with you.

II. We use CCTV images to help maintain the safety of anyone working in or visiting our premises and other buildings, and for the prevention, detection and prosecution of criminal offences.

III. We may rely on the CCTV images and any recorded communications we have to establish, exercise or defend our legal rights.

5. We can collect and use your personal information where you have given your specific consent to us

I. You can withdraw your consent to your personal data being processed at any time - on our website for online profiles, or by writing to us via e-mail to our address mentioned below.

II. Please be informed that if you withdraw this consent, it may mean we will not be able to provide all, or parts of, services you have requested from us, and you will not be able to cancel your booking or obtain a refund of any charges you have paid, as we will not be able to fulfill any of our contractual duties to you within the absence of such information.

 

SECTION 4

Protecting Your Personal Data

We take appropriate security measures to help protect your personal data from accidental loss and from unauthorized access, use, alteration and disclosure. Sensitive personal data, such as medical information you may provide, as well as children’s data, is stored additionally with adequate protection.

The security of your data also depends on you - please, do not share your passwords, bookings or flight details with other parties, and always be aware of internet fraud.

The processes mentioned may involve sending your data to countries where, under their local laws, you may have fewer legal rights. We will take appropriate security measures to ensure that your personal data is safe and secure, if that is the case.

Data Retention

We will retain your information for as long as necessary to fulfill the purpose for which it is being processed. We will keep the information for a period which will enable us to handle or respond to any complaints, queries or concerns relating to your booking. The information may also be kept for us to continue improving your experience with us, and to ensure that you receive any loyalty rewards which are due to you.

Your information will actively be reviewed and deleted when there is no longer a legal, business or customer need for it to be retained. However, if the data is required after this period for analytical, historical or other legitimate business purposes, we will take appropriate measures to make this data anonymous.

Links to Other Websites

Our website may have links to other organizations’ websites that have their own privacy notices. Please be reminded that we do not accept any responsibility or liability for websites of other organizations, and you should read their own Privacy Policy.

Social Media Features on Our Website

Our website’s social media features, such as Facebook, Instagram and YouTube, have their own privacy notices. Please make sure you read their Terms and Conditions and Privacy Policies carefully, as we do not accept any responsibility or liability for these features.

 

SECTION 5

Managing Your Personal Information

You have online access to your own personal data associated with your account on our website. You may request a copy of any personal data held by us and there is no fee for this request.

All personal data related enquiries and requests must be in writing and must contain the following information:

- Your name and postal address

- Your full request in paragraph form

- Any details which may help us locate the information which is the subject of your request (e.g. booking reference number)

- A photocopy of your passport or driver’s license, for identity verification purposes

- Your signature and the date of your request

- If you are applying on behalf of another person, then signed authority from the individual is required

Please send your request to:

Data Protection,

Customer Services,

CABA Travel

Uğur Mumcu Caddesi, Alkın İş Merkezi, No:4 - Girne, KKTC

You may ask for your personal data to be rectified or erased, to object to the processing of your personal data and, where technically feasible, to ask for personal data you provided to be transmitted to another organization. We will update or erase your data, unless we have to keep it for legitimate business or legal purposes.

Please be informed that if you withdraw your consent for us to process your personal data, it may mean we will not be able to provide all, or parts of, services you have requested from us, and you will not be able to cancel your booking or obtain a refund of any charges you have paid, as we will not be able to fulfill any of our contractual duties to you within the absence of such information.

Legal Basis for Using Your Personal Information

Under current data protection laws in TRNC (Turkish Republic of Northern Cyprus), the legal basis in almost all cases will be:

1. Your information is needed to process your booking, to complete your travel arrangements, and to otherwise perform the contract we have with you.
2. It is in our legitimate interest to use your personal information to operate and improve our business as a travel provider.
3. Your personal information is necessary to comply with local legal obligations.
4. To protect your, and/or other individuals’, vital interests.
5. To respond to and to manage security operations, accidents or other similar incidents, including for medical and insurance purposes.
6. It is by your consent that we can use your information for any particular purpose.

 

SECTION 6

Notice Updates

This notice replaces all previous versions and may change at any time, so please check it regularly on our website for any updates.