Important Definitions

Personal Data: Any information relating to an identified or identifiable natural person.

Data Subject: The natural person who is the owner of the processed data (the person to whom the personal data refers).

Personal Data Protection Law (KVKK): Refers to the Law No. 6698 on the Protection of Personal Data.

ER-AH or Data Controller: The legal entity that determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system.

Explicit Consent: Consent that is related to a specific subject, based on information, and declared with free will.

Anonymization: The process of altering personal data in such a way that it loses its personal data characteristics and cannot be reversed.

Application Form: The form used by the personal data subject to exercise their rights under this Policy and the Law No. 6698 on the Protection of Personal Data.

Job Applicant: Natural persons who have applied to ER-AH for a job or internship through any means or who have made their CVs and related information available for review.

Employees, Shareholders, and Authorized Representatives of Institutions We Cooperate With: All natural persons who, in any way, have a relationship with or work for the institutions ER-AH cooperates with, including shareholders and authorized representatives of such institutions.

Special Categories of Personal Data: Data relating to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothing, membership in associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data.

Processing of Personal Data: Any operation performed on personal data, whether fully or partially automated, or by non-automated means provided that it is part of a data recording system, such as obtaining, recording, storing, retaining, modifying, reorganizing, disclosing, transferring, taking over, making available, classifying, or preventing its use.

Personal data specified within different data categories such as identity, contact, location, personnel records, legal transactions, physical space security, visual and audio recordings, risk management, professional experience, transaction security, body measurements, health information, criminal convictions and security measures, emergency contact information, work data, signature, website usage data, insurance information, etc., may be processed for the purposes listed below:

Ensuring that trainings are carried out in compliance with the legislation, performing assessments and certification processes, submitting documentation to relevant authorities when required, ensuring training quality, ensuring physical security and workplace safety, reporting incidents such as accidents, and fulfilling requirements of aviation training.

Improving the services and activities offered to you, customizing them according to your needs, preferences, and usage habits, providing necessary enhancements, or ensuring technical support and quality.

Fulfilling our obligations arising from laws, regulations, and contracts.

Informing you about our new activities, providing appropriate products and services, and enabling smooth social media interaction and sharing.

Processing special categories of personal data such as health, clothing, criminal convictions only for reasons arising from legal obligations, institutional requirements, operational necessities, or for safety and security purposes.

For security of premises, we maintain video surveillance systems. During the time spent in our facilities, indoor and outdoor areas may be recorded and monitored by authorized personnel.

Notifications required by the educational system, online courses, and other educational activities such as course notes, flight and lesson planning information may be communicated to you (our students) electronically through your contact information.

Areas where video recording takes place have been marked, and warning/information signs have been appropriately placed.

We also use electronic card entry systems, time-tracking systems, GPS location tracking in some vehicles, and video recording systems.

Additionally, in accordance with ER-AH Aviation Trade Ltd. Co. Personal Data Retention and Destruction Policy, and under Articles 5 and 6 of the Law:

• When explicitly stipulated in the applicable laws,

• When necessary for the establishment or performance of a contract,

• When required for ER-AH to fulfill its legal obligations,

• When explicit consent has been provided by the data subject (where required), or when the data has been made public by the data subject,

• When required for ER-AH’s legitimate interests, provided that it does not harm the fundamental rights and freedoms of the data subject,

personal data is processed and stored lawfully.

Collected and processed personal data is stored with great care by implementing all required administrative and technical measures, for the periods specified in the ER-AH Aviation Trade Ltd. Co. Personal Data Retention and Destruction Policy.

When your relationship with ER-AH ends, your data is deleted, destroyed, or anonymized at the end of the legal retention period.

Personal data may be shared within the scope described below.

Collected and processed personal data may be shared:

With natural persons or private legal entities, shareholders, business partners, suppliers, authorized public institutions and organizations, and board members for the above-listed purposes.

During online classes, audio and video recordings are made, and these recordings are shared with relevant authorities as required by the legislation governing the Directorate General of Civil Aviation and the Ministry of National Education.

Your personal data may be transferred to:

• Business partners, suppliers, group companies, and shareholders for the provision and promotion of our services and activities,

• Group companies for the determination and implementation of ER-AH’s commercial and business strategies, and for the execution of human resources policies,

• Lawyers, auditors, tax consultants, and other third parties from whom we receive consultancy services, for the proper and lawful conduct of business processes and to enable our right to defense in potential legal proceedings,

• Your authorized representatives, to the extent of the authority you have granted,

• Regulatory and supervisory authorities, courts, enforcement offices, and other official institutions legally authorized to request your personal data.

Your personal data may be transferred in accordance with Articles 8 and 9 of the KVKK.

Regarding your personal data, you have the right to:

• Learn whether your personal data is processed and request information if it has been processed,

• Learn the purpose of processing and whether it is used in accordance with that purpose,

• Know the third parties to whom your personal data is transferred domestically or abroad,

• Request correction if your personal data is incomplete or incorrectly processed,

• Withdraw your consent or explicit consent where processing is based on such consent, and request the deletion or destruction of your personal data,

• Request deletion or destruction of your data under the conditions described in Article 7 of the Law,

• Request notification to third parties to whom your data has been transferred regarding correction or deletion requests,

• Object to a decision made solely through automated processing that produces results against you,

• Request compensation if you suffer damage due to unlawful processing of your personal data.

You may submit your requests under Article 11 of the Law (“rights of the data subject”) by completing the Application Form in accordance with the ER-AH Aviation Trade Ltd. Co. Personal Data Retention and Destruction Policy or by contacting bilgi@erah.aero.

Your request will be finalized as soon as possible and within thirty days at the latest. Requests are processed free of charge unless the response requires an additional cost, in which case a fee determined by the Personal Data Protection Board may be charged.

You may access the ER-AH Personal Data Retention and Destruction Policy and the Application Form at:

 https://erah.aero/

Revision Date: 14.02.2022