1. ABOUT PAPS AND PRIVACY POLICY
1.1. Pegasus Airlines Peer Support Program “PAPS” is a support program that provides psychological and vocational guidance services in line with the principles of proactive approach and social support against situations that may pose a risk to flight safety in Pegasus Airlines pilots. Within the scope of the program, support is provided by "Peer Pilots" who have volunteered for the role and received training and also work at Pegasus Airlines. In this text, pilots who receive support under the PAPS Program will be referred to as "Supported Pilots". Pegasus Airlines will act as the accountable party for personal data used under the PAPS Program.
1.2. PAPS Management Team involved in the execution of the PAPS Program consists of the following people:
- • Safety Management Group Leader
- • Safety Management Manager
- • Senior Safety and HF Specialist
- • Accident and Incident Investigation Specialist
- • Company Doctor
- • Peer Support Group Representative
- • Independant Health Organization Representative
1.3. PAPS Oversight Committee involved in the execution of the PAPS Program consists of the following people:
- • CFOO
- • CSEO
- • Safety Management Group Leader
- • Safety Management Manager
- • Senior Safety and HF Specialist
- • Accident and Incident Investigation Specialist
- • Company Doctor
- • Peer Support Group Representative
- • Independant Health Organization Representative
1.4. The information about the identity of the data controller, the purpose for which your data will be processed, to whom and for what purposes it can be transferred, the method of collecting personal data, the legal reason and your rights regarding your personal data constitute the content of this "Privacy Policy" if you participate in the PAPS Program.
1.5. The scope of this Privacy Policy is limited only to the personal data processing activities carried out under the PAPS Program.
2. DATA CONTROLLER
Pegasus Hava Taşımacılığı A.Ş. (MERSİS No: 0-7230-0470-8500017), Adress: AEROPARK Yenişehir Mahallesi Osmanlı Bulvarı No: 11/A Kurtköy 34912 Pendik İstanbul, Türkiye, Phone: (+90) 216 560 7323, E-mail: KISISELVERILERIM@flypgs.com.
3. SCOPE OF PERSONAL DATA COLLECTED
3.1. Personal data refers to all kinds of information regarding an identified or identifiable nature of information of a person.
3.2. Whithin the scope of PAPS Program, personal data of Peer Pilots and Supported Pilots are present.
3.3. Within the scope of the application to the PAPS Program and the execution of the relevant support program, the identification information (name, surname), contact information (phone number, e-mail address) and personal information (the base information and title) of the Supported Pilot are available through the application form on the PAPS Website. It is recorded electronically and shared with the Peer Group Leaders and the relevant Peer Pilot during the Peer Pilot appointment process. Selection of Peer Pilot depends on the approval of the Supported Pilot in all circumstances. The applicant reserves the right to apply anonymously with a pseudonym in the application form instead of identity information. If the application is made on behalf of the Supported Pilot by another Pegasus Airlines employee or the Supported Pilot's relative, the identity and contact information of the applicant are also recorded.
3.4. Peer Pilots' credentials (name, surname), contact information (phone number, e-mail address), personal information (seniority, aircraft type, resume) and Professional Experience (education) information will be available to Peer Group Representatives in the PAPS Program operating system. PAPS Program operating system is hosted on Pegasus Airlines servers.
3.5. In the application form, a statement can be made about which subject they need support. This statement can be shared with the Peer Pilot during the support process. The support process is carried out between the Supported Pilot and the Peer Pilot in accordance with the principles of confidentiality. The evaluation records of the interviews are made available to the PAPS Management Team by the Peer Pilot in the PAPS Program operating system in a way that preserves the anonymity of the Supported Pilot.
3.6. Within the scope of the PAPS Program, the need to restrict or stop flight duties may be determined in cases that are considered to affect flight safety. In this case, the evaluation and decision making of the measure to be taken by Pegasus Airlines is carried out by the PAPS Oversight Committee.
3.7. The personal data obtained are stored to the extent necessitated by the personal data processing purposes and provided that these periods do not exceed. Apart from this, personal data stored in order to fulfill legal obligations are maintained for the periods specified in the laws.
4. PURPOSE OF USE OF PERSONAL DATA AND LEGAL REASONS
4.1. Within the scope of the PAPS Program, your personal data will be processed for the following purposes and based on the corresponding legal data processing requirement within this purpose:
| Purpose of Processing Your Personal Data |
Data Categories Processed for Purpose |
Legal Reason We Rely On When Processing Your Data For The Specified Purposes |
Participation in the PAPS Program as a Peer Pilot or Supported Pilot, continuing support service within the scope of the PAPS Program, monitoring all support processes by the Peer Group Representatives and the PAPS Management Team.
Continuation of the support process within the scope of the PAPS Program with professional support following your approval.
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Credentials, Contact Information, Personal Information, Professional Experience Information, Employee Relatives |
The source of the PAPS Program is Chicago International Civil Aviation Agreement Annex 19 (Safety Management), Turkish Civil Aviation Law No. 2920, Civil Aviation General Directorate regulations in In terms of the employer's obligation to supervise the employee in terms of flight safety and flight operation is derived from the Turkish Code of Obligations No. 6098 and Occupational Health and Safety Law No. 6331.
Your health data obtained during the PAPS Program can be shared with third parties who will provide you with professional support, upon your explicit consent, if you consent to receive professional support.
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5. TRANSFER OF PERSONAL DATA TO THIRD PARTIES
5.1. Your personal data subject to the PAPS Program will not be shared with any Pegasus Airlines employee or any other person who is not involved in the PAPS Program, except for the following cases:
- • Data transfers based on your explicit consent.
- • Information that will be deemed necessary or useful for the activity of the specialist who will provide professional support, based on your approval, if the need for the continuation of the support process with professional support is determined.
- • Information required to be conveyed to the authorized PAPS Oversight Committee regarding the assessment and decision regarding the limitation or suspension of flight duties in cases that are considered to affect flight safety.
- • Your personal data can be shared with official institutions if requested based on legal obligations legal processes, lawsuits and/or authorized administrative or judicial institutions. Your personal data may be disclosed to administrative or judicial authorities for the protection and establishment of rights when determined to be necessary for the implementation of the PAPS Program Rules or for the protection of Program participants.
6. YOUR RIGHTS REGARDING YOUR PERSONAL DATA
6.1. You can always apply to Pegasus seeking to: (a) understand if your personal data is processed; (b) request information on the processing of your personal data, (c) understand the purpose of processing for your personal data and whether these are used in line with this purpose; (d) know third parties to whom your personal data is transferred in Turkey and abroad and to inquire about the appropriate safeguards implemented for cross-border personal data transfers; (e) correct your incomplete or incorrect personal data processed and maintained; (f) request the destruction or anonymization of your personal data subject to the purposes for the processing of your personal data being fully exhausted; (g) have third parties notified of the transactions covered in items (e) and (f), (h) object to the results of any analysis of your personal data exclusively through automatic systems. You can forward these requests to the Data Controller in accordance with the application procedures specified in Article 5 of the Communiqué on Application Procedures and Principles, on behalf of the Personal Data Protection Manager, to the address of the relevant data controller specified in Article 2 or through other application channels specified in the same article.
6.2. We will finalize your requests as soon as possible and, in any case, within thirty days at the latest.
6.3. In order to provide support services under the PAPS Program and to improve your user experience, you must provide accurate and complete data to the data controller. If you suspect that the data proessed about you by the data controllers is not correct, please report this situation so that the necessary changes can be made.
7. OTHER TOPICS
7.1. For administrative and technical security measures related to the provision of services within the scope of the PAPS Program and other issues that may be related to your personal data, please review the relevant company regulations made available to you through the Pegasus Document Management System (QDMS) or, if you have any questions, contact the data controller via the channels mentioned above.
7.2. When the PAPS Website is visited, some information and files called cookies can be stored and reused later in order to facilitate the use of the site by the user. The type of information stored as a result of accepting a cookie by the user is specific to the accessed device and includes data such as the IP address, the date and time of visiting the website, which parts of the site were visited, and whether the pages to be accessed were successfully presented to the user. This information is kept in connection with the device, without being matched with the person. Cookie data are used to have more information about the use of the site and to see whether the site is working at an optimum level. This makes it possible to improve the provided online services.
7.3. This Privacy Policy has last been revised on
15.02.2021