Information Notice on the Protection of Personal Data (Turkish Law No. 6698)

This notice is provided by GOODLIFE ELITE CLUB LTD (“GOODLIFE”) as data controller under Article 10 of Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”). Because we serve members resident in Turkey, we process your personal data in line with both the KVKK and UK data protection law (UK GDPR).

1. Data controller

GOODLIFE ELITE CLUB LTD, registered in England and Wales under number 15345620. Address: Chiswick Business Park, Building 3, 566 Chiswick High Road, London W4 5YA, United Kingdom. Contact: admin@goodlifeeliteclub.com.

2. Personal data we process

• Identity: name, date of birth, sex, nationality, passport details and photo, Turkish ID number for Turkish citizens
• Contact: email, mobile number, address
• Customer transactions: membership level, bookings, past journeys, requests (including the tour, number of travellers, room preference and note you give in the price and information request form on our website), who introduced you, group details
• Financial: Travel Balance movements, payments, refunds and instalments (card details are handled by Stripe, not stored by us)
• Travel preferences: seat, room and meal preferences, travel companion, visa status, Miles&Smiles details, special notes
• Marketing: your consent or refusal to receive commercial electronic messages
• Security: sign-in records, trusted devices, consent records (date, IP address, browser)
• Mobile app usage: if you add the GOODLIFE app to your phone’s home screen, an anonymous device identifier, device type (iPhone / Android), first and last opening dates and number of openings; when you sign in, these are linked to your membership. If you allow notifications in the app, your phone’s notification address is stored so that we can send you push notifications; you can withdraw this permission at any time in your phone’s settings
• Special category data: meal preferences that may reveal health or belief (e.g. gluten-free, diabetic, allergy), only as you provide them and with your explicit consent

3. How we collect it

Through the member area, the price and information request form on our website, booking and traveller forms, email, phone and WhatsApp. The WhatsApp button on our website opens your own WhatsApp app; messages you send us travel over WhatsApp (Meta) infrastructure and are therefore also subject to Meta’s privacy terms. If someone booked for you, they provided your traveller details. If you travelled with us before, your contact details and travel history were transferred from our company records to the member area. Payment results come from our payment provider.

4. Purposes and legal grounds

• Performance of the tour contract (KVKK Art. 5/2-c): answering your price and information request and contacting you about it; bookings, tickets, hotels, transfers, visas and guiding; member area and Travel Balance; booking and payment notifications
• Legal obligations (Art. 5/2-ç): accounting and tax records, package travel rules, protection of customer money, requests from authorities
• Establishing, exercising or defending a right (Art. 5/2-e): disputes, refunds and complaints
• Legitimate interests (Art. 5/2-f): membership levels, travel history and referrals, moving former customers to the member area and inviting them, measuring app usage, account security
• Explicit consent (Art. 5/1 and Art. 6): commercial electronic messages; meal preferences that may reveal health or belief

Consent-based processing is optional; refusing it does not affect your membership or bookings.

5. Turkish ID number

We process your Turkish ID number (T.C. Kimlik) only when your journey requires it, for these purposes:

• Visa: Many visa application forms (e.g. Schengen countries, USA, UK, Japan) ask for a national ID number. We fill it in when preparing your application or booking your appointment.
• Flights: Airlines, especially Turkish carriers, may issue domestic and connecting tickets with the Turkish ID number. Some countries require passenger data to be sent to border authorities before the flight.
• Hotels: In some countries hotels must record guests' identity details and report them to the authorities. Passport details are usually enough; your Turkish ID number is shared only when the hotel or local law requires it.
• Tour: Travel health insurance in Turkey is issued with the Turkish ID number. During the tour it may be used to verify your identity with Turkish consulates and medical providers in an emergency.

We do not use your Turkish ID number for any other purpose or for marketing, and we share it only with the relevant supplier or authority, as far as needed.

6. Recipients

Airlines, hotels, local tour and transfer companies, guides, insurers, consulates and visa agencies; our service providers Supabase (database and storage, London), Vercel (member area servers, London), Stripe (payments), Resend (email), 360dialog GmbH and Meta (WhatsApp) and Wix (website); our accountant, legal advisers and the insurer protecting customer money; and public authorities where required by law.

7. Transfers abroad

GOODLIFE is established in the United Kingdom; your data is collected directly by us and stored in the UK. Some providers process data in the EU and the USA, and your journey requires sharing data with suppliers and authorities in your destination countries. These transfers are made under Article 9 of the KVKK: on the basis of an adequacy decision where one exists, otherwise standard contracts or other appropriate safeguards, and for occasional transfers on grounds such as necessity for the performance of the contract and, where needed, your explicit consent.

8. Retention

We keep personal data only as long as the purpose and the law require.

• Traveller details: identity, passport, Turkish ID, contact, meal and other preference details entered for each traveller, and passport photos, are permanently deleted within a reasonable period after at least 30 days have passed since the tour ended. Passport, Turkish ID and meal details saved in your profile for future bookings may be deleted at the same time.
• Accounting and payment records: kept for 6 years from the end of the financial year.
• Price and information requests: requests that do not lead to a booking are deleted within 1 year of the request date at the latest.
• Mobile app usage: deleted within 2 years of the app’s last opening at the latest.
• Consent and deletion records: records of your confirmations and of the deletion of your data are kept for 6 years as evidence in case of a claim or audit. Deletion records do not contain the deleted information, only whose data was deleted and when.

After that, data is deleted, destroyed or anonymised.

9. Your rights (KVKK Article 11)

You may ask whether your data is processed and request information about it; learn the purpose and whether it is used accordingly; know the recipients in Turkey or abroad; ask for correction or erasure and for recipients to be notified; object to a result against you arising solely from automated analysis; and claim compensation for damage caused by unlawful processing.

10. How to apply

Send your request in writing to the address above, or from the email address registered with us to admin@goodlifeeliteclub.com. We respond free of charge within 30 days at the latest; if the action involves an extra cost, the fee set by the Turkish Data Protection Board may be charged.

For processing under UK law and your UK rights, see our Privacy Notice.