Arslan Tourism and Construction Trade Inc. (Aldino Hotel)
Information Text on the Processing of Personal Data
A. PURPOSE OF THE PERSONAL DATA PROTECTION AND PROCESSING POLICY:
As Arslan Turizm ve İnşaat Ticaret Anonim Şirketi (“Company”), we would like to provide you with this “Information” letter, which we have prepared in our capacity as the Data Controller in accordance with the Law No. 6698 on the Protection of Personal Data (“LPPD”), within the framework of Article 10 titled “Information Obligation of the Data Controller” and Article 11 titled “Rights of the Relevant Person” of the LPPD; the purposes for which your personal data will be processed, to whom and for what purposes your processed personal data may be transferred, the method and legal reason for collecting your personal data, and your other rights listed in Article 11 of the LPPD:
As the Data Controller, we process, record, transfer, share and store your personal data as explained below and within the limits stipulated by official legislation.
Our Company reserves the right to update this “Information Text on the Protection of Personal Data” at any time within the framework of changes that may be made in the current official legislation.
B. COLLECTION, PROCESSING AND PROCESSING PURPOSES OF PERSONAL DATA:
Our company, which operates in the fields specified in detail in the Articles of Association, collects and processes your verbal, written or electronic personal data due to the regulations of the Tourism and Revenue Administration and other relevant institutions and the contracts we have concluded. This personal data will be used to provide services related to the activities of our company and to increase the quality of these services, to carry out our sales, marketing and other activities, and to comply with information storage, reporting and information obligations. In addition, your personal data may be used within the scope of studies such as CRM (Customer Relationship Management) applications to be carried out for sales and marketing activities and to increase the quality of the service we provide to you.
Your personal data will not be used for purposes other than those specified above without your explicit consent, and will not be shared or transferred to third parties except for legal obligations and official institutions/organizations.
Our company may only share your personal data in question with our domestic or foreign subsidiaries and direct or indirect affiliated companies and joint ventures or with public institutions or organizations authorized to request such data due to a legal obligation and, provided that sufficient precautions are taken, with institutions, suppliers, authorized dealers/resellers/business partners with whom we have agreements due to our activities, in Turkey or abroad, in order to provide value-added services, opportunities and facilities to you, our customers, and to increase the service quality, based on the explicit consent of the customers or in other cases stipulated in Article 5/f.2 of the KVKK, primarily the legislation we are subject to.
Your personal data may vary depending on the services, products or commercial activities provided by our Company; however, it may be collected verbally, in writing or electronically through automatic or non-automatic methods, offices, branches, dealers, call center, website, social media channels, mobile applications and similar tools. As long as you benefit from our Company's products and services, your personal data may be processed by being created and updated.
In addition, with the intention of using our Company's services; a. When you use our call center or website, b. When you visit our Company, website or social media channels/media, c. When you participate in training, seminars or organizations organized by our Company, your personal data may be processed. Your personal data obtained from you with your consent or due to other legal compliance reasons stated in the laws of the Republic of Turkey;
(I) Our business units can carry out the necessary work to enable you to benefit from the products and services offered by our company;
(II) Recommending the products and services offered by our company to you by customizing them according to your tastes, usage habits and needs;
(III) Ensuring the legal and commercial security of our Company and the people who have a business relationship with our Company (administrative operations for communication carried out by our Company, ensuring the physical security and control of the Company's locations, business partner/customer/supplier (authorized persons or employees) evaluation processes, legal compliance process, financial affairs, etc.);
(IV) Improving the quality of the services offered by our company and developing our quality policy,
(V) To inform you about and benefit from the general and special campaigns, promotions, advertisements, discounts and similar advantages offered by our company;
(VI) To process the data obtained together with your personal data, preferences, transactions and browsing time in the relevant channels when you log in with your user name and password in order to receive services from the channels provided by our company in order to provide you with the information and services you have requested;
(VII) To be able to make notifications (renewal, termination, etc.) regarding all kinds of loyalty cards issued and/or to be issued by our Company and its affiliated companies/organizations and website memberships of our Company and its affiliated companies/organizations, to inform you about all kinds of communication that can be established with you, new services and products to be offered, changes and innovations that may occur in personal data policies and membership conditions and similar issues;
(VIII) To inform you about the information, events and services you may request from our company;
(IX) Determining and implementing our company's commercial and business strategies;
(X) Ensuring the implementation of our company's human resources policies and;
(XI) If expressly stated in the legislation or if necessary, personal data may be processed by our Company and its related companies/organizations and other real and/or legal persons specified in Article (C) below, within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Personal Data Protection Law for the purposes of fulfilling a legal obligation determined by the legislation.
C. METHOD AND LEGAL REASON FOR COLLECTING PERSONAL DATA:
Your personal data is obtained in all kinds of verbal, written or electronic media, in line with the purposes specified in the above articles, so that our products and services can be offered within the determined legal framework as a Company and in this context, our Company can fully and accurately fulfill its responsibilities arising from the contract and the law. Your personal data collected for this legal reason is processed, recorded, transferred, shared and stored within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Personal Data Protection Law, for the purposes specified in Article (B) of this text.
D. PROCESSING OF SPECIAL NATURE DATA:
According to the Personal Data Protection Law, data regarding race, ethnic origin, political views, philosophical beliefs, religion, sect or other beliefs, appearance and dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures, as well as biometric and genetic data are special personal data. Our company also takes the measures determined by the Personal Data Protection Board at an adequate level in the processing of special personal data. In order to provide better service, our company will process special personal data of individuals only with the consent of the relevant person and only for the purpose of collection.
E. TO WHOM AND FOR WHAT PURPOSES PERSONAL DATA CAN BE TRANSFERRED:
Your collected personal data may be transferred to Arslan, as well as to our shareholders, business partners, suppliers, legally authorized public institutions and private persons, in accordance with the personal data processing conditions and purposes specified in Articles 8 and 9 of the Personal Data Protection Law, in order to serve the purposes specified in Article (B).
F. TRANSFER OF PERSONAL DATA ABROAD:
Our company is authorized to transfer personal data abroad within the conditions determined by the Personal Data Protection Board in the Personal Data Protection Law, in accordance with other conditions in the law and after obtaining the express consent of the person for this purpose.
G. RIGHTS OF THE PERSONAL DATA OWNER STATED IN ARTICLE 11 OF THE PDPL:
Within the scope of the Personal Data Protection Law, we accept that the relevant person has the right to be informed and to obtain approval before the processing, recording, transfer, sharing and storage of his/her personal data, and that he/she has the right to determine the fate of his/her data after the processing, recording, transfer, sharing and storage of the data. In this context, if you forward your requests regarding your rights as personal data owners to our Company through the methods set out below in this “Information Text on the Processing of Personal Data”, our Company will finalize the request free of charge within thirty days at the latest, depending on the nature of the request.
In accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller published by the Personal Data Protection Board, regarding your requests regarding your rights as personal data owners, I. If your application will be answered in writing, no fee will be charged for up to ten pages. A processing fee of 1 Turkish Lira may be charged for each page over ten pages. II. If the answer to the application is given on a recording medium such as a CD or flash memory, the fee that may be requested by our Company as the data controller cannot exceed the cost of the recording medium.
In this context, personal data owners have the right to; a. Learn whether or not their personal data has been processed, b. Request information if their personal data has been processed, c. Learn the purpose of processing personal data and whether or not it is used in accordance with its purpose, d. Know the third parties to whom personal data is transferred domestically or abroad, e. Request correction of personal data if it is processed incompletely or incorrectly and request notification of the action taken within this scope to third parties to whom personal data is transferred, f. Request deletion, destruction or anonymization of personal data within the framework of the conditions stipulated in Article 7 of the Personal Data Protection Law and request notification of the action taken within this scope to third parties to whom personal data is transferred, g. Object to the emergence of a result to the detriment of the person by analysis of processed data exclusively through automated systems, h. Request compensation for the damages incurred due to unlawful processing of personal data.
However, individuals do not have any rights regarding anonymized data within the Company. Our Company may share personal data with relevant institutions and organizations in accordance with the business and contractual relationship, for the purpose of exercising the legal powers of a judicial duty or state authority.
H. PERIOD FOR WHICH YOUR PERSONAL DATA WILL BE PROCESSED:
In accordance with the PDP Law, your personal data processed for the purposes specified in this “Information Text on the Processing of Personal Data” will be deleted, destroyed or anonymized and will continue to be used by us when the purpose requiring processing is eliminated according to Article 7/f.1 of the PDP Law and/or when the limitation periods required for us to process your data pursuant to the legislation expire.
I. CASES WHERE OUR COMPANY MAY PROCESS YOUR PERSONAL DATA WITHOUT YOUR EXPRESS CONSENT AS REQUIRED BY LAW:
Pursuant to Article 5 of the KVKK, our Company may process your personal data, which is specified above and obtained in accordance with the law, without your explicit consent in the following cases:
Cases where it is clearly foreseen in the laws; I. If you are unable to give your consent as the data owner due to a de facto impossibility or if your consent is not legally valid, the processing of your personal data is mandatory for the protection of your life or physical integrity or that of another person; II. If it is directly related to the establishment or performance of a contract you have made with our Company and its affiliated companies/organizations, other real and/or legal persons specified in Article (C), the processing of personal data belonging to the parties to the contract is mandatory; III. If it is mandatory for our Company to fulfill a legal obligation; IV. If your personal data is made public by you; V. If data processing is mandatory for the establishment, exercise or protection of a right; VI. If data processing is mandatory for the legitimate interests of our Company, provided that it does not harm your fundamental rights and freedoms.
J. TO MAKE A REQUEST IN ACCORDANCE WITH THE PERSONAL DATA PROTECTION LAW:
In accordance with Article 13, paragraph 1 of the PDP Law, you may submit your request to our Company to exercise your rights specified above through the method(s) determined/to be determined by the Personal Data Protection Board. Alternatively, if you wish, you may submit your application in writing to our Company in accordance with the PDP Law. In order to exercise these rights stipulated in Article 11 of Law No. 6698, you may contact us at any time by sending an e-mail to kvkk@hotelaldino.com. Only the e-mail address kvkk@hotelaldino.com must be used for matters related to your personal data, and requests and notifications received from channels other than this address will not be taken into consideration.
Rights regarding personal data can only be exercised regarding the data belonging to individuals. Requests regarding the data of persons other than the person who filled out the form and attached official documents proving your identity will not be taken into consideration. Forms without official documents proving your identity will not be taken into consideration. We would like to inform you that even when data deletion requests are fulfilled, we are obliged to share the data with official authorities if requested by the official authorities.
