Privacy Policy

1. Data Controller

The data controller responsible for the processing of personal data covered by this Privacy Policy is:

2. Scope of This Privacy Policy

This Privacy Policy applies to personal data processed in connection with Hana Travel’s services and online platforms, including:

This Privacy Policy does not apply to websites, applications or services independently operated by third parties, even where they may be accessible through our websites or platforms.

3. Personal Data We Collect

The personal data we process depends on how an individual interacts with Hana Travel and the services being used.

3.1 Customer and Passenger Information

When a transfer is requested or booked, we may process information such as:

Identity card or passport numbers, nationality and date of birth are processed only where the law requires them, such as the passenger declaration made to the U-ETDS system of the Ministry of Transport and Infrastructure for passenger transport, or where the service requires them, such as Fast Track and Meet & Assist at the airport.

3.2 Booking and Service Information

We may process information generated during the organisation and provision of transfer services, including:

3.3 Business Partner Information

Where a company applies to become, or operates as, a Hana Travel business or transport partner, we may process information relating to the company and its representatives, including:

Information relating solely to a legal entity is not necessarily personal data. However, information identifying or relating to an individual representative, contact person or other natural person is treated as personal data where applicable.

3.4 Operational and Location Data

In connection with the operation, coordination and monitoring of active transfer services, Hana Travel may process operational information relating to a transfer or journey, including:

Such information may be processed where necessary to coordinate transfers, monitor active services, support operational teams, provide relevant journey information and ensure the effective delivery of the requested service.

During an active transfer, the guest of that transfer may be shown the assigned driver’s name, the vehicle’s plate and the vehicle’s live location on the My Booking page.

Operational location information is not used for advertising or direct marketing purposes.

3.5 Website and Technical Information

When our websites, online platforms or partner services are used, certain technical information may be generated or processed, including, where applicable:

We may also use cookies, local browser storage and similar technologies where necessary for website functionality, authentication, security and user preferences.

3.6 Photographs and Guest Reviews

Hana Travel staff, such as drivers and airport representatives, may take photographs of guests during our services, for example when guests are welcomed at the airport or next to the vehicle.

These photographs are kept in Hana Travel’s private archive. After internal approval they may be used on Hana Travel’s websites, social media accounts and promotional materials. The guest’s name is not published with them; the hotel or region of the transfer may be.

After a service, guests may be asked to rate it and leave a comment. After review by Hana Travel, ratings and comments may be published on Hana Travel’s websites with the guest’s first name and the initial of their surname, and may be translated into other languages. Guests may also be invited to share their experience on review platforms such as Tripadvisor or Google, which operate under their own privacy practices.

Guests who do not wish to be photographed may tell the staff at the time. Removal of a published photograph or review may be requested at [email protected].

3.7 Communications with Guests

Hana Travel may contact guests by email, WhatsApp, SMS and telephone, including automated calls, about their reservation and service: for example confirmation requests, reminders, driver and vehicle details, flight changes, payment links, the My Booking link and requests for feedback.

Records of these communications are kept, such as delivery status and, for automated calls, the key pressed in reply. They may be used to document the service, including where a guest does not arrive for a transfer.

4. How We Collect Personal Data

Personal data may be collected:

Where a person provides personal data relating to another passenger, that information should only be provided where the person is authorised to provide it for the purpose of arranging the requested service.

Personal data may be processed by automated means or, where it forms part of a data recording system, by non-automated means.

5. Why We Process Personal Data

Hana Travel processes personal data for specified purposes connected with the operation of its services.

Providing and Managing Transfer Services

We may process personal data to:

Performing Our Contractual Obligations

Personal data may be processed where necessary for the establishment or performance of a contract, including arranging and providing a transfer that has been requested or purchased.

Transfer Coordination and Operational Monitoring

Operational and location information may be processed where necessary to:

Meeting Legal and Regulatory Obligations

Certain personal data may be processed or disclosed where necessary for Hana Travel to comply with obligations arising under applicable laws and regulations or lawful requests from competent public authorities.

Managing Business Partners

Information relating to representatives and users of partner companies may be processed for purposes including:

Protecting Our Services

Technical and usage information may be processed where necessary to:

Photographs, Reviews and Promotion

Photographs and guest reviews described in Section 3.6 may be processed to:

6. Legal Grounds for Processing

Depending on the relevant processing activity, Hana Travel may process personal data on one or more legal grounds available under applicable data protection legislation, including where:

Where processing requires explicit consent, such consent will be obtained separately where required by applicable law.

7. Payments and Payment Card Information

Payments for Hana Travel services may be processed through banks, payment service providers or other authorised payment infrastructure.

Where card payment is available, payment card information may be entered directly into systems operated or provided by the relevant bank or payment service provider.

Hana Travel does not store customers’ full credit or debit card details, such as the complete card number or card security code (CVV/CVC), in its own systems.

Hana Travel may receive and retain limited transaction information necessary for reservation, accounting and payment administration, such as:

Payment providers process payment information in accordance with their own legal obligations and privacy practices.

8. Sharing of Personal Data

Hana Travel does not sell personal data.

Personal data may be shared with appropriate recipient groups where necessary to provide the requested services, operate our platforms or fulfil applicable legal obligations.

Photographs and reviews published as described in Section 3.6 are visible to the public, including on social media platforms operated by third parties.

Transfer and Transport Partners

Information necessary to organise and perform a transfer may be provided to the transport company, operational partner or service provider responsible for the relevant service.

Only information reasonably necessary for the organisation and performance of the service should be shared.

Operational Personnel

Relevant passenger and transfer information may be made available to authorised operational personnel where necessary to identify passengers, coordinate pickup arrangements and perform the requested transfer.

Travel Agencies, Hotels and Other Booking Parties

Where a reservation has been arranged through or in cooperation with a travel agency, hotel or another authorised organisation, relevant information may be exchanged where necessary to administer the reservation and provide the requested service.

Banks and Payment Service Providers

Relevant transaction information may be exchanged with banks and payment service providers where necessary to process or administer payments.

Technology and Service Providers

Personal data may be processed by suppliers providing services such as:

Access to personal data should be limited to information necessary for the relevant provider to perform its function and should be subject to appropriate safeguards.

Public Authorities

Personal data may be disclosed to courts, law enforcement authorities, regulators, ministries or other competent public authorities where Hana Travel is required or authorised to do so under applicable law or pursuant to a legally valid request. This includes the passenger declarations Hana Travel is required to make to the U-ETDS system of the Ministry of Transport and Infrastructure, which contain passengers’ names, nationality, identity card or passport number, gender and telephone number.

9. Address and Location Services

Certain Hana Travel online services may use third-party address or location functionality to assist users in searching for, entering or validating address information.

When such functionality is used, text entered into an address search field and related technical information may be transmitted to the relevant third-party service provider for the purpose of returning address suggestions or location results.

Such third-party services process information in accordance with their own privacy practices and applicable legal obligations.

10. International Data Transfers

Some technology, communication, messaging, artificial-intelligence, address, infrastructure or other service providers used in connection with Hana Travel’s operations, such as messaging services for WhatsApp and SMS, may process or store information outside Türkiye.

Where personal data is transferred outside Türkiye, Hana Travel will take the measures required under applicable data protection legislation and use an appropriate lawful transfer mechanism where required.

11. Cookies and Browser Storage

Our websites and online platforms use limited cookies and browser storage technologies where necessary to provide their functionality.

These technologies may be used for purposes such as:

For example, a functional cookie may be used to remember a user’s selected language.

Authentication or other information necessary for the operation of an online platform may also be stored using browser technologies such as local storage.

We do not currently use information collected through these technologies for behavioural advertising or direct marketing.

If additional cookies, analytics technologies or similar services are introduced in the future, this Privacy Policy and any applicable consent mechanism will be updated where required.

12. Marketing Communications

Hana Travel does not currently use customer contact information collected through its standard reservation process for routine promotional email or messaging campaigns.

Communications necessary for:

are service communications and are not treated as direct marketing communications.

Photographs and guest reviews may be used to present and promote Hana Travel’s services as described in Section 3.6.

If Hana Travel introduces direct marketing activities in the future, required notices, permissions and opt-out mechanisms will be implemented in accordance with applicable legislation before personal data is used for those purposes.

13. Data Retention

Hana Travel retains personal data only for as long as necessary for the purpose for which it was collected and for any additional period required by applicable legal, accounting, tax, contractual or regulatory obligations.

Retention periods may vary depending on the type of information and the purpose of processing.

When determining an appropriate retention period, Hana Travel may consider:

When there is no longer a lawful reason to retain personal data, it will be deleted, destroyed or anonymised in accordance with applicable requirements.

14. Data Security

Hana Travel takes appropriate technical and organisational measures designed to protect personal data against risks including:

Access to personal data is limited according to operational requirements and the responsibilities of authorised personnel and service providers.

No internet transmission, software platform or electronic storage system can, however, be guaranteed to be completely secure.

15. Rights of Data Subjects

Individuals whose personal data is processed by Hana Travel may exercise the rights available to them under applicable data protection legislation.

Under Article 11 of the KVKK, these may include the right to:

The availability and scope of individual rights may depend on the applicable legislation and circumstances of the processing.

16. Exercising Your Rights

Requests concerning personal data or this Privacy Policy may be submitted to:

Requests should contain sufficient information to allow Hana Travel to identify the requester, understand the request and, where necessary, verify that the requester is entitled to exercise the relevant rights.

Requests will be evaluated and answered within the periods prescribed by applicable law.

17. Personal Data of Other Passengers

A person making a booking may provide information concerning other passengers travelling under the same reservation.

The person making the reservation should ensure that they are authorised to provide the relevant passenger information to Hana Travel for the purpose of arranging and performing the requested service.

Hana Travel will process such information only for applicable service, operational and legal purposes as described in this Privacy Policy.

18. Children’s Information

Hana Travel’s transfer services may include passengers classified as children or infants.

Information concerning a child or infant may therefore be processed where necessary to arrange and provide a transfer booked by a parent, guardian or another person authorised to make the reservation.

Hana Travel does not knowingly use children’s personal data for behavioural advertising or direct marketing purposes.

Where a photograph described in Section 3.6 shows a child, the parent or guardian may object at the time or ask for its removal at [email protected].

19. Third-Party Websites and Services

Our websites and online platforms may contain links to websites or services independently operated by third parties.

Hana Travel is not responsible for the privacy practices, security or content of independently operated third-party websites or services.

Users are encouraged to review the privacy information provided by the relevant third party before providing personal data to them.

20. Changes to This Privacy Policy

Hana Travel may update this Privacy Policy where necessary to reflect changes in its services, systems, data processing activities or applicable legal requirements.

Where material changes are made, the updated version will be made available through the relevant Hana Travel website or online service.

The date shown at the beginning of this Privacy Policy indicates when it was last updated.

Where a new processing activity requires additional information or consent under applicable law, the appropriate notice or consent mechanism will be provided where required.

21. Contact Us

Questions concerning this Privacy Policy or Hana Travel’s processing of personal data may be directed to: