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1. Who We Are

PAST HAVACILIK VE DANIŞMANLIK TİCARET LİMİTED ŞİRKETİ, operating under the brand Past Aviation (“we”, “us” or “our”), is the data controller for the personal data described in this notice under Turkish Personal Data Protection Law No. 6698 (“KVKK”).

Registered address: Yelken Plaza, Kurtköy Mahallesi, Ankara Caddesi No: 289, Suite: 21, Pendik, İstanbul, Türkiye.

Contact email: commercial@pastaviation.com

1. Scope of This Notice

This notice explains how we process personal data relating to visitors to www.pastaviation.com and individuals who contact us through the email address or telephone number displayed on our website.

Our website does not provide a contact form, user registration or an online checkout.

1. Personal Data We Process

When you contact us, we may process your name, business contact details, company name, position and the information contained in your enquiry and subsequent correspondence.

Please provide only the personal information necessary for your enquiry and avoid sending sensitive personal data unless specifically required through an appropriate channel.

Visiting the website may also involve the processing of technical information, such as IP addresses, browser and device information, access times and security logs, through the website infrastructure. Information about cookies is provided separately in our Cookie Policy.

1. Purposes and Legal Bases

We process personal data only where an applicable legal basis exists under Article 5 of the KVKK.

Depending on the nature of the interaction, this may include:

• Responding to business enquiries and conducting preliminary discussions: our legitimate interests in managing business communications, provided that your fundamental rights and freedoms are not prejudiced.

• Preparing proposals and taking steps directly related to entering into or performing a contract: where processing is necessary and directly related to the establishment or performance of a contract.

• Meeting statutory obligations and responding to lawful requests: where processing is expressly provided for by law or necessary to fulfil our legal obligations.

• Establishing, exercising or protecting legal rights: where processing is necessary for those purposes.

• Maintaining website and information security: our legitimate interests in protecting our systems, subject to the applicable balancing of rights and interests.

Where a processing activity requires your explicit consent, consent will be requested separately. This notice does not itself constitute a request for consent.

1. Disclosure of Personal Data

Where necessary for the purposes described above and subject to applicable legal requirements, personal data may be disclosed to:

• Website hosting, IT support and email service providers, to operate and support our communications and website infrastructure.

• Legal and other professional advisers, where necessary for advice or the protection of legal rights.

• Competent public authorities, where disclosure is legally required.

This notice covers website use and initial communications. Where a subsequent engagement involves additional processing or disclosure, supplementary information will be provided as necessary.

1. International Processing

The use of website, email or other technology providers may involve the processing of personal data outside Türkiye.

Any transfer abroad must satisfy the applicable requirements of Article 9 of the KVKK. Information about the providers, destinations and applicable transfer arrangements will be made available in accordance with those requirements.

1. Retention and Security

We retain personal data for as long as necessary for the relevant purpose, taking account of applicable statutory retention periods and the establishment, exercise or protection of legal rights.

When the grounds for retention cease to apply, personal data is deleted, destroyed or anonymised in accordance with applicable requirements.

We apply appropriate technical and organisational measures to protect personal data against unlawful processing, unlawful access and accidental loss.

1. Your Rights

Subject to Article 11 of the KVKK, you may request to:

• Learn whether your personal data is processed and obtain information about that processing.

• Learn the purposes of processing and whether your data is used in accordance with those purposes.

• Learn the third parties to whom your data has been transferred in Türkiye or abroad.

• Request correction of incomplete or inaccurate data.

• Request deletion or destruction where the statutory conditions are met.

• Request notification of correction, deletion or destruction to relevant recipients.

• Object to an adverse outcome resulting from analysis exclusively through automated systems.

• Seek compensation for damage caused by unlawful processing.

1. Contact and Applications

For privacy enquiries, contact commercial@pastaviation.com.

Applications to exercise your rights may be submitted in writing to our registered address or through other methods permitted under the applicable KVKK application rules. Email applications may be submitted from an email address previously notified to us and registered in our systems, where the applicable requirements are met.

Please describe your request clearly and provide the information required by the applicable rules. Additional information may be requested where necessary to verify your identity.

Applications will be handled as soon as possible and no later than 30 days, subject to applicable legal requirements.

1. External Links and Updates

Our website includes links to external services, such as Google Maps. Their processing of personal data is governed by their own privacy notices.

We may update this notice to reflect changes in our activities or applicable requirements. The current version will be made available on this page.