Privacy Notice (KVKK)

Private Luxury Limousine / ROYELAY SEYAHAT TURİZM ACENTELİĞİ TİC. A.Ş.

Last Updated: 2026-09-24

As ROYELAY SEYAHAT TURİZM ACENTELİĞİ TİC. A.Ş. (the “Company”), we attach great importance to the protection of your personal data in connection with the Private Luxury Limousine brand and the privateluxurylimousine.com website.

This Privacy Notice has been prepared pursuant to Turkish Personal Data Protection Law No. 6698 (“KVKK”) in order to inform individuals who visit our website, use our contact and reservation/quotation forms, or contact us regarding our services about the processing of their personal data.

1. Data Controller

Within the scope of Law No. 6698 on the Protection of Personal Data (KVKK), the data controller is ROYELAY SEYAHAT TURİZM ACENTELİĞİ TİC. A.Ş.

Address: Merkez Mahallesi, Seçkin Sokak, Z Ofis No: 2-4/A, Kat: 2, No: 206, Kağıthane / İstanbul, Türkiye
TÜRSAB: Group A Travel Agency – Operating License No: 12705
Email: info@privateluxurylimousine.com
Telephone: +90 530 761 94 82

2. Personal Data Processed

Depending on the transactions carried out through the Private Luxury Limousine website and our communication channels, the following categories of personal data may be processed:

• Identity Information: First name and surname.
• Contact Information: Telephone number, WhatsApp number and email address.
• Reservation and Service Information: Requested service, vehicle preference, reservation date and time, number of passengers, pick-up and destination locations, travel/transfer information and any special requests submitted by you.
• Customer Transaction Information: Quotation, reservation, service and customer communication records.
• Transaction Security and Internet Usage Information: IP address, device/browser information, website usage and traffic information, and technical data obtained through cookies and similar technologies.
• Marketing and Analytics Data: Advertising source, campaign information, advertisement and website interactions, and conversion information.

Whether payment and credit card information is processed directly by the Company will be clarified once the payment infrastructure used by the Company has been confirmed, and this section will be updated accordingly.

3. Purposes of Processing Personal Data

Your personal data may be processed for the following purposes:

• Receiving and responding to your communication, quotation and reservation requests;
• Planning and providing chauffeur-driven vehicle, transfer and related services;
• Managing vehicle availability and operational processes;
• Managing customer relations and post-service processes;
• Fulfilling contractual and financial processes;
• Managing requests, complaints and customer support processes;
• Ensuring the security and functionality of the website;
• Analyzing service and website performance;
• Fulfilling legal obligations; and
• Providing information to authorized public institutions and authorities where required by law.

Advertising, analytics and conversion measurement activities carried out through Google Ads and similar advertising/measurement technologies will be further specified once the cookies used and the relevant Google configurations have been confirmed.

4. Methods of Collecting Personal Data

Your personal data may be collected electronically or, where necessary, through physical means via contact and reservation/quotation forms available on the website, telephone, email, WhatsApp, the website itself, cookies and similar technologies, as well as information provided by you during the service and reservation process.

5. Legal Grounds for Processing Personal Data

Depending on the relevant processing activity, your personal data may be processed based on the legal grounds set out in Article 5 of the KVKK, including:

• Processing being directly related to the establishment or performance of a contract;
• Processing being necessary for the data controller to fulfil its legal obligations;
• Processing being necessary for the establishment, exercise or protection of a right; and
• Processing being necessary for the legitimate interests of the data controller, provided that such processing does not violate the fundamental rights and freedoms of the data subject.

Where certain personal data processing activities require explicit consent, such activities will be separately assessed and the necessary explicit consent mechanisms will be implemented.

6. Transfer of Personal Data

To the extent necessary depending on the nature and requirements of the relevant transaction, your personal data may be transferred to:

• Authorized employees and service providers involved in the provision of services;
• Business partners necessary for carrying out operational processes;
• Information technology, hosting and technical infrastructure service providers;
• Support service providers such as accounting and legal service providers;
• Communication, reservation and payment service providers used by the Company; and
• Legally authorized public institutions and organizations, judicial authorities and administrative authorities.

Such transfers will be carried out in accordance with the applicable legislation and the conditions stipulated under the KVKK.

Any international transfer of personal data that may arise due to the use of Google, WhatsApp/Meta, hosting providers, reservation systems or other foreign service providers will be separately assessed and confirmed, after which this section will be finalized accordingly.

7. Google Ads and Cookies

Private Luxury Limousine may use Google Ads services for the purpose of measuring the performance of advertising campaigns and analyzing conversions occurring through the website.

Within this scope, technical information relating to advertisement clicks, website interactions, and conversion events such as form submissions or communications may be processed through cookies or similar technologies.

Once it has been confirmed which technologies, including Google Analytics, Google Tag Manager, Enhanced Conversions, Consent Mode and/or remarketing technologies, are used in addition to Google Ads, this section and the separate Cookie Policy will be prepared and updated accordingly.

8. Retention of Personal Data

Your personal data will be retained for the period required for the relevant processing purpose and in consideration of the statutory retention periods applicable to the Company.

When the purpose of processing and the relevant legal grounds cease to exist, personal data will be deleted, destroyed or anonymized in accordance with applicable legislation.

9. Your Rights under the KVKK

Pursuant to Article 11 of the KVKK, you may apply to the Company to exercise your rights, including:

• Learning whether your personal data is being processed;
• Requesting information regarding the processing of your personal data if it has been processed;
• Learning the purpose of processing your personal data and whether it is being used in accordance with such purpose;
• Knowing the third parties to whom your personal data has been transferred within Türkiye or abroad;
• Requesting correction of your personal data if it has been processed incompletely or inaccurately;
• Requesting the deletion or destruction of your personal data under the conditions stipulated by law; and
• Exercising your other rights provided under the applicable personal data protection legislation.

10. Applications and Contact

You may submit your requests regarding your rights under the KVKK to the Company through the following channels:

ROYELAY SEYAHAT TURİZM ACENTELİĞİ TİC. A.Ş.
Address: Merkez Mahallesi, Seçkin Sokak, Z Ofis No: 2-4/A, Kat: 2, No: 206, Kağıthane / İstanbul, Türkiye
Email: info@privateluxurylimousine.com

Applications will be evaluated and processed in accordance with the applicable personal data protection legislation.

Important Notice: This document has been prepared as a working draft based on the currently available information. The sections shown in square brackets and the information relating to payment systems, reservation systems, analytics tools, cookies, hosting services and other third-party services must be confirmed before this document is considered the final version for publication.