This Privacy & Personal Data Policy is meant to provide information on the personal data collected,retained,processed,shared and transferred by Magical Steps Tourism Ltd.Any person who visits www.magical-steps.com  website,or uses any service provided by Magical Steps Tourism Ltd.(e.g.makes a payment with his/her credit card to a merchant that receives payments via Magical-Steps.com)is covered by this Privacy &Personal Data Policy.When the term "Magical-Steps Travel" is used,it covers both Magical Steps Tourism Ltd as they share the same privacy principles and policy.Magical-Steps.com might be referred to as "we","us" or "our" in this policy.Legal titles and contact information of Magical-Steps.com companies can be found at the end of this document.

The terms "personal data","personal information" and "your information" are used interchangeably and they mean any information than can be associated to an identified or identifiable natural person(e.g.name,e-mail adress,birth date,national ID number).We are aware that personal data is important for our clients as well as end users and we endeavor within Magical-Steps Travel and that your personal data is kept safe.Purpose of this Privacy & Personal Data Policy is ;

To explain,in the most transparent and readable way possible,our ways and proposes of using the data we collect about you;                                                                                                              

To clarify the types of information we collect upon your permission and the purposes and methods for processing of them;

To inform you on the third parties we transfer this information to as well as our purpose and method in doing so;

To let you know your choices and legal rights with respect to your personal data;

To describe the extent of our responsibility for protection of your rights and privacy.

This Policy applies to products and services of Magical Steps Travel and Touristicom.com only.On websites and mediums that do not belong to Magical Steps Travel,the policies and rules of the respective person or organization.

The type of personal data processed by Magical Steps Travel depends on which services you benefit(some of them may be available according to your region and legal status) and how you benefit from them.

2.Personal Data Collected by Magical Steps Travel;

We collect different types of personal data about you when you visit our website or use our services.

When you visit our website,send a payment via Magical Steps Travel,we will collect information necessary to offer and fulfill your request in an efficient and secure way.This information may include:

Your contact details (e.g.your name,adress,e-mail adress,ID number)

Payment details (e.g. your credit card number,expiry date,instalment choice)

When someone sends funds to,or enters into any transaction that requires them to provide personal information about third persons,we collect personal data about those third persons.

İf you are a seller utilizing a platform (e.g. a marketplace) which uses our services,the platform may transfer your personal data such as contact details and bank account number.

Additional details you provide to us when you make use of services provided Magical Steps Travel or when you contact Magical Steps Travel (e.g. via the contact us form located on our website or e-mail).

3.Use of Personal Data by Magical Steps Travel and Legal Basis for Processing;

We use your personal data for various purposes permitted under data protection laws in Turkey,USA,European Union.Our purposes in using your personal data are explained with some examples below and are justified by lawfulness criteria stipulated in data protection regulations of USA,European Union and Turkey,such as performance of contractual obligations,our legimate interests,and legal obligations.

To operate our sites and provide our services,we need to use your information to initiate payments

To improve our services and manage our business needs,we monitor usage of our sites and services by you and analyze usage data to enhance our performance.

To mitigate and manage risk and protect our platform and customers from harm,we detect and prevent fraud by identifying customers and measuring their risk level.These decisions may be made by automatic algorithms as well human effort under set rules.İf you learn that a transaction you want to make has been rejected as result of those procedures,you may contact us at the contact information provided at the end of this document.

To contact you when needed,we may contact you regarding the status of your transaction.Also,when there is an issue related to your account or a payment you make,we may use your personal information to reach out to you so that we can resolve the issue.You may be contacted by Magical Steps Travel employees,or by employees of our business partners,in which case we need to share your personal data with those business partners.

To meet our legal obligations or resolve disputes,some regulations in the jurisdictions require us to use and retain your information in certain ways.As a travel services provider,we are obliged to keep and inspect records of all transactions we facilitate for various reasons including data retention,anti-moneylaundering and taxation.

When there is a legal dispute between Magical Steps Travel and you,or between parties of a transaction facilitated by Magical Steps Travel,your information may be used to resolve the dispute and presented to courts and other authorized dispute resolution authorities.We may also use your information in additional ways that you have consented to.For instance,we may seek your consent for sending you marketing material,receiving your feedback or other processing activities.İn those cases,you can always withdraw your consent by contacting us at the addresses provided at the end oh this Policy.You should include information that enable us to recognizeyou in that notification.Your notification of withdrawal of your consent will be effective in the future and therfore will not make our prior processing unlawful but it will make us cease to process that information from the receipt of your notification onwards.

4.Retainment and Erasure of Personal Data;

Magical Steps Travelretains your personal data in an identifiable format for the shotest period of time necessary to fulfil our legal obligations and for our business needs.When the period during which we retain your personal data ends,we will erase or anonymize your personal data so that they can o longer be associated with you,in line with our internal procedures that aim to ensure safety of your personal data.When you cancel your reservations or request erasure of your personal data,we will erase or anonymize parts of it that we are not legally obliged to reject your erasure request or to keep even if your reservation is canselled.

5.Transfer of Personal Data to Third Parties;

While providing our services,we sometimes share your personal information with third persons for purposes explained in this section.We share your personal data within Magical Steps Ltd-Touristicom.com group companies-cooperate partners (e.g.airlines,hotels,transportation companies,insurance companies etc.)in order to manage our operations and provide our services in a safe and consistent manner.The transfer between Magical Steps Travel and partners takes place with adequate safeguards in place,and your personal data does not fall outside the scope of this privacy policy because of this transfer.We utilize services of other companies as necessary and we may need to share your personal data with some of them.For example,when we receive your payment details we need to transfer them to respective financial institutions to initiate the payment.Or when the transaction you have made requires some additional steps to be taken (e.g.if it is an international purchase and customs procedures are to be completed) we may share your personal data with relevant service providers (e.g. customs brokers).We may also transfer personal data to third persons (e.g.anti-fraud processing companies)in order to ensure safety and convenience of our users and business.When you use our services,we notify the other parties to the transaction you have made,such as other users and merchants and other authorities may request information from us.We will share your information only when there is a legal obligation to do so;or when it is deemed necessary to prevent and/or prosecute a crime.We may also need to share personal data with third parties for other business purposes (e.g.for audits,corporate governance,or executing our legal rights).We will always comply with the law when doing so.

6.Choices Available to You;

You have choices available with respect to our privacy practices.You may always decline to provide personal data requested by Magical Steps Travel.However,if the information you have declined to provide is mandatory for provision of our services,you may not use our services.For instance,if you decline to enter your credit card number on the checkout form,we cannot initiate the payment.From time to time,we communicate with you.These communications may be for marketing purposes or notifications related to a transaction you have been a party to.You can opt-out of all marketing related communications by following the instructions at the end of messages we send.However,you cannot opt-out of transactional messages.

7.Your Rights;

We want you to know that you have following rights with respect to your personal data,as per the regulations governing use of personal data within EEA or Turkey;

a) To learn if we process your personal data,the types of data we process,souces we get your personal data from,third parties we transfer your personal data to within the country or internationally,the period for which we keep the personal data or how  we determine that period,

b) To access your personal data and to request the data provided by you to be given to you or another data controller in a structured,commonly used and machine readable format.

c) To learn the purposes for which your personal data is processed and to query if they are used in a compatible manner with those purposes,

d) To object to and request restriction of processing of your personal data,

e) To request rectification of innacurate and incomplete personal data about you.

f) To request erasure of your personal data when there is no legal basis for further processing,

g) To request notofication of procedures such as erasure and rectification to other third parties to whom your personal data has been transferred,

h) To object to any negative consequences arising from automatic analysis of your personal data,

i) To request indemnification for any damages arising from unlawful processing of your personal data.

You can exercise these rights by contacting us at the addresses provided at the end of this Policy.Your application should include the information you have given to us while registering or making use of our services as well as a photo ID,so that we may identify you.

8. Protection of Personal Data;

All personal data collected by Magical Steps Travel is transmitted and stored in compliance with reasonable security standards as adopted by the industry.The security of payment data is ensured with our PCI DSS Level 1 Comliant infractructure and all connections where personal data is transmitted are protected with encrytion.Even though we take all reasonable measures to protect your information,you are responsable for securing and maintaining your account information.

9. Miscellaneous;

Our services and websites are not directed to children,i.e. people who are not legal adults.We do not collect personal data from children or other individuals who are not legally able to use our services.İf we find out that we have collected Personal Data from a child,we will promptly delete it,unless we are legally obligated to retain such data.İf you believe that we have mistakenly or unintentionally collected information from a child,please contact us immediately at the addresses below.

We may make changes to this privacy policy in the future.Changes to the privacy will become effective on the date it is published to be effective.Magical Steps Travel obliged to follow any possible updates and inform their customers (or other users they make transactions with) on fintech company's data-processing activities (as well this privacy policy) before they transfer other persons' information to fintech company.

10. Contact information;

For Magical Steps Travel

Company Title Magical Steps Tourism Ltd.

Mersis (Central Registration System) 0381041631200010

Address Cumhuriyet Mh.Muammer Ulgen Sk. 12 /304 Kusadası / Aydın

E-Mail magical-steps.com">infomagical-steps.com

Tlf 0 256 613 32 33- 0 532 491 44 52