Legal Information

As NOVAY Havacılık Sağlık Turizm ve Ambulans Hizmetleri A.Ş. (“NOVAY Air”, “NOVAY” or the “Company”), we care about the privacy and security of your personal data.

This Privacy Policy explains how your personal data is processed when you visit www.novayair.com, request a flight or service, use our contact forms, or contact us by e-mail, telephone, WhatsApp or other communication channels.

Personal data is processed in accordance with applicable legislation, in particular the Turkish Personal Data Protection Law No. 6698 (“KVKK”).

1. Data Controller

Data controller:

NOVAY Havacılık Sağlık Turizm ve Ambulans Hizmetleri A.Ş.

Address: Ataköy 7-8-9-10. Kısım Mahallesi, Çobançeşme E-5 Yan Yol Caddesi, B Blok No: 12/2, İç Kapı No: 59, Bakırköy / Istanbul, Türkiye

KVKK: kvkk@novayair.com

Privacy: privacy@novayair.com

Web: www.novayair.com

2. Personal Data That May Be Processed

Depending on your relationship with NOVAY Air and the nature of the service you request, the following personal data may be processed:

Identity data: Name, surname and, where the service requires it, ID/passport details.

Contact data: Telephone number, e-mail address, address and company details.

Flight and travel data: Departure and arrival points, flight dates, flight type, number of passengers, route, flight preferences and other operational information.

Customer transaction data: Quotes, requests, booking and operation records, and information relating to contract and payment processes.

Communication records: Correspondence and requests made by e-mail, telephone, contact form and WhatsApp.

Technical data: IP address, device and browser information, session information, site usage information, and technical data obtained through cookies and similar technologies.

Health data: Health information that may be processed where necessary to assess and carry out an air ambulance or medical escort service, in line with the KVKK provisions on special categories of personal data.

3. Purposes of Processing

Your personal data may be processed for the purposes of:

• receiving and assessing private jet, air ambulance and medical escort service requests,
• flight and operations planning,
• preparing quotes,
• communicating with customers,
• coordinating aircraft, crew, airport, handling and ground operations,
• carrying out the health and transfer coordination required in air ambulance and medical operations,
• fulfilling contractual and legal obligations,
• managing customer relations,
• ensuring information and system security,
• assessing requests, applications and complaints,
• ensuring the security and functionality of the website,
• subject to the user’s preference, analysing website performance and measuring marketing activities,
• fulfilling legal obligations towards competent public authorities.

4. Legal Grounds for Processing

Depending on the nature of the specific processing activity, your personal data may be processed on the following legal grounds:

• processing is directly related to the conclusion or performance of a contract,
• processing is necessary for the Company to fulfil its legal obligations,
• processing is necessary for the establishment, exercise or protection of a right,
• processing is necessary for the Company’s legitimate interests, provided that it does not harm your fundamental rights and freedoms,
• processing is expressly provided for by law,
• processing is necessary to protect life or physical integrity,
• and, where required, your explicit consent.

Special categories of personal data are processed only where one of the applicable processing conditions set out in Article 6 of the KVKK is met and the necessary technical and administrative measures are in place.

5. Health Data

In air ambulance and medical escort services, certain health information may need to be processed in order to assess whether the patient can be transported safely.

Health data is processed only to the extent required by the operation and the healthcare service, and access is limited to authorised personnel who need it.

NOVAY Air does not aim to collect unnecessary or detailed health data through public web forms.

Where detailed medical reports, test results, diagnoses, prescriptions or similar documents need to be shared, the appropriate and secure communication method specified by NOVAY Air should be used.

6. Transfer of Personal Data

Depending on the nature of the service and provided the relevant legal conditions are met, your personal data may be shared, only to the extent necessary, with:

• air carriers,
• airports and handling companies,
• healthcare institutions,
• doctors, nurses and other healthcare professionals,
• ground ambulance and patient transfer service providers,
• flight, operations and travel service providers,
• competent public authorities,
• information technology and infrastructure service providers,
• legal, accounting and other professional advisers.

7. International Data Transfers

Due to the nature of NOVAY Air’s international flight operations, certain personal data may need to be shared with aviation operators, airports, handling companies, healthcare institutions or other service providers located abroad.

In addition, the infrastructure of some digital services used on the website may be located abroad.

International transfers of personal data are carried out on the basis of whichever is applicable of the adequacy decision, appropriate safeguards, standard contracts or other legal transfer mechanisms provided for in Article 9 of the KVKK.

8. Third-Party Services Used on the Website

The following third-party technologies may be used on the NOVAY Air website:

Google Analytics: May be used to analyse website usage and performance.

Meta Pixel: Where the user gives their preference, may be used to measure advertising and campaign performance and to analyse marketing activities.

Google reCAPTCHA (v3): Used to protect the contact and flight request forms against automated submissions (bots/spam) and misuse. reCAPTCHA is only loaded once you start filling in a form and runs in the background without showing you a puzzle.

In doing so, technical data such as your IP address, browser and device information, interactions on the page and Google cookies are sent to Google LLC (USA). Google uses this data to produce a risk score, which is used to assess whether a form submission is genuine; the score is not stored with the content of your form.

reCAPTCHA is treated as a strictly necessary technology for form security and works independently of your cookie preferences. The legal basis is our legitimate interest in keeping the website and its forms secure. The Google Privacy Policy (policies.google.com/privacy) and Google Terms of Service (policies.google.com/terms) also apply to the use of reCAPTCHA.

WhatsApp: May be used to enable users to contact NOVAY Air quickly.

When these services are used, technical data such as IP address, device and browser information, cookie identifiers, page views and interaction data may be transferred to the relevant service providers.

Non-essential analytics or marketing technologies are not activated without the user’s relevant preference.

9. Cookies

Strictly necessary, security/functional, analytics and marketing cookies may be used on www.novayair.com.

Non-essential cookies are activated, to the extent required, based on the user’s active preference and explicit consent.

Detailed information about cookies is available in the Cookie Policy and the Cookie Preferences panel.

10. Retention Periods

Personal data is retained for as long as necessary for the purpose for which it is processed and for the statutory retention periods set out in applicable legislation.

Once the reason for processing no longer exists and there is no legal retention obligation, personal data is deleted, destroyed or anonymised in accordance with the legislation.

11. Data Security

NOVAY Air implements technical and administrative measures appropriate to the nature of the data processed in order to prevent unlawful processing of and access to personal data and to ensure that the data is kept securely.

Enhanced security measures are also applied to special categories of personal data.

12. Your Rights

Under Article 11 of the KVKK, you have the right to:

• learn whether your personal data is processed,
• request information if it has been processed,
• learn the purpose of processing and whether it is used in line with that purpose,
• know the third parties to whom your personal data is transferred,
• request the correction of incomplete or inaccurate personal data,
• request the deletion or destruction of personal data where the legal conditions are met,
• request that corrections or deletions be notified to third parties to whom the data has been transferred,
• object to a result against you arising exclusively from analysis by automated systems,
• claim compensation for damage arising from the unlawful processing of personal data.

13. Applications and Contact

For questions about privacy and the protection of personal data:

privacy@novayair.com

For applications under the KVKK:

kvkk@novayair.com

Formal applications under the KVKK must be made in accordance with the application methods set out in the legislation.

14. Changes

NOVAY Air may update this Privacy Policy in line with changes to legislation, its services or its personal data processing activities.

The current version is published on www.novayair.com.

Information Notice on the Processing of Personal Data

Under the Turkish Personal Data Protection Law No. 6698 (“KVKK”), we process your personal data as data controller:

NOVAY Havacılık Sağlık Turizm ve Ambulans Hizmetleri A.Ş.

Address: Ataköy 7-8-9-10. Kısım Mahallesi, Çobançeşme E-5 Yan Yol Caddesi, B Blok No: 12/2, İç Kapı No: 59, Bakırköy / Istanbul, Türkiye

E-mail: kvkk@novayair.com

Privacy: privacy@novayair.com

within the scope described below.

Personal Data Processed

Through the website, contact and flight request forms, your name, surname, telephone, e-mail, company details, flight route, flight date, number of passengers, type of service and other information you provide may be processed.

Where necessary for air ambulance or medical escort services, health data may additionally be processed in accordance with the KVKK provisions on special categories of personal data.

Purposes of Processing

Your personal data is processed to assess your service request, communicate with you, prepare quotes, plan flights and operations, coordinate aviation and healthcare services, manage contract processes, ensure information security and fulfil legal obligations.

Method of Collection and Legal Grounds

Personal data may be collected by automated or non-automated means through the website, electronic forms, e-mail, telephone, WhatsApp and other electronic or physical communication channels.

Depending on the nature of the processing activity, data is processed on the basis of the relevant legal processing conditions in Article 5 of the KVKK and, for special categories of data, Article 6.

Where required, the use of non-essential analytics and marketing technologies is based on your explicit consent.

Transfer of Personal Data

Where necessary to perform the service, your personal data may be shared, within the scope of the relevant legal conditions, with air carriers, airport and handling companies, healthcare institutions, ambulance and medical service providers, IT service providers, advisers and legally authorised public authorities.

Where data must be transferred abroad because of international operations and certain technology services used, the transfer mechanisms set out in Article 9 of the KVKK are applied.

Your Rights

You may submit requests regarding your rights under Article 11 of the KVKK to NOVAY Air in accordance with the methods set out in the legislation.

For more information, please see the Privacy Policy and KVKK Application Information sections.

NOVAY Air may use cookies and similar technologies on www.novayair.com to provide the user experience, protect site security, analyse site performance and, where the user gives their preference, measure marketing activities.

Strictly Necessary Cookies

These cookies are required for the website’s core functions, session management, security and the provision of services expressly requested by the user.

Under the relevant legislation, there may be cases where these cookies do not require separate explicit consent.

Google reCAPTCHA, used for form security, falls into this category: it is only loaded once the contact or flight request form is being used and, because it is needed to protect the forms against automated submissions, it works independently of your cookie preferences.

Security and Functional Technologies

These may be used for form security, preventing misuse and providing certain functions requested by the user.

The WhatsApp integration may be assessed under this category or, depending on the nature of the technical implementation, under another appropriate category.

Analytics Cookies

Used to understand how the website is used, measure visitor traffic and improve service quality.

NOVAY Air may use Google Analytics for this purpose.

Where required, analytics cookies are not activated without the user’s explicit consent.

Marketing Cookies

Used to measure the performance of advertisements and campaigns and assess the effectiveness of marketing activities.

NOVAY Air may use Meta Pixel for this purpose.

Marketing cookies are not activated without the user’s explicit preference.

Main Technology Providers Used

Google Analytics — Google: Analytics and site performance.

Meta Pixel — Meta: Advertising and marketing performance.

Google reCAPTCHA — Google: Form security and prevention of automated misuse.

WhatsApp — WhatsApp / Meta: Communication service that enables the user to contact NOVAY Air.

Some of these services may process data on infrastructure located outside Türkiye.

Where an international data transfer is required, the legal transfer mechanisms set out in Article 9 of the KVKK are applied.

Managing Cookie Preferences

Accepting or rejecting non-essential cookies is entirely the user’s choice.

Users can set their preferences in the cookie management panel shown on their first visit to the website and change them later via the “Cookie Preferences” link.

Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

Current Cookie List

The name, provider, purpose, category and retention period of the cookies used may change as the technologies used are updated.

The current cookie list and retention periods are shown in the Cookie Preferences panel on the website.

Data Subject Applications under the KVKK

You may submit requests regarding your rights under Article 11 of the Turkish Personal Data Protection Law No. 6698 to NOVAY Havacılık Sağlık Turizm ve Ambulans Hizmetleri A.Ş..

You may submit your applications

In writing: to Ataköy 7-8-9-10. Kısım Mahallesi, Çobançeşme E-5 Yan Yol Caddesi, B Blok No: 12/2, İç Kapı No: 59, Bakırköy / Istanbul, Türkiye,

or by other application methods provided for in the relevant legislation.

If you apply from an e-mail address you have previously provided to NOVAY Air and that is registered in NOVAY Air’s systems, you may send your application to:

kvkk@novayair.com

The application must include your name and surname; for citizens of the Republic of Türkiye, your T.R. identity number; for foreign nationals, your nationality, passport number or identity number if any; your address for notifications; your e-mail and telephone number if any; and the subject of the request.

Applications are concluded in accordance with the legislation as soon as possible depending on the nature of the request, and within 30 days at the latest.

Your use of www.novayair.com is subject to the following terms of use.

This website is operated by NOVAY Havacılık Sağlık Turizm ve Ambulans Hizmetleri A.Ş..

Site Content

The information on the website is provided for general information about NOVAY Air’s services.

NOVAY Air reserves the right to update, change or remove site content.

Flight and Service Requests

Flight, private jet, air ambulance or medical escort requests submitted through the website do not on their own constitute a confirmed booking or a binding service contract.

Provision of the service depends on aircraft and crew availability, operational conditions, airport suitability, flight permits, weather conditions, medical suitability and other relevant operational conditions.

Binding service terms are set out in the quote, booking or contract confirmed in writing by NOVAY Air.

Medical Information

No content on the website replaces medical diagnosis, medical advice or emergency healthcare services.

In medical emergencies, the official emergency medical services of the relevant country should be contacted.

The suitability of air ambulance and medical escort services is determined after the necessary medical and operational assessment.

Intellectual Property

The NOVAY Air brand, logo, design, texts, graphics, images and other content on the website are protected under the relevant intellectual property legislation.

Copying, reproducing, modifying or publishing the content for commercial purposes without NOVAY Air’s written permission is prohibited.

Third-Party Services and Links

The website may contain links to third-party websites or services.

NOVAY Air is not responsible for the content, security practices or privacy policies of third-party services outside its control.

Liability

NOVAY Air takes reasonable care to keep the information on the website accurate and up to date. However, information may change over time due to operational, technical or regulatory changes.

General information on the website does not constitute a guarantee of performance, availability or service for any particular flight or operation.

Governing Law

These terms of use are governed by the laws of the Republic of Türkiye.

The jurisdiction of the legally competent courts and other authorities is reserved for disputes.

Contact

NOVAY Havacılık Sağlık Turizm ve Ambulans Hizmetleri A.Ş.

Ataköy 7-8-9-10. Kısım Mahallesi, Çobançeşme E-5 Yan Yol Caddesi, B Blok No: 12/2, İç Kapı No: 59, Bakırköy / Istanbul, Türkiye

Web: www.novayair.com