Personal Data Protection Law

LAW ON PROTECTION OF PERSONAL DATA

AKK TURİZM EMLAK INS. TRADE. LTD. ŞTİ.

Clarification Text on the Processing of Personal Data

A. PURPOSE OF PERSONAL DATA PROTECTION AND PROCESSING POLICY:

AAK Turizm Emlak İnş. Trade Ltd. Sti. (“Company”), in accordance with the Law on Protection of Personal Data No. 6698 (“KVKK”), Data Controller With this "Information" letter we have prepared in our capacity, within the framework of Article 10 titled "Information Obligation of the Data Controller" and 11 titled "Rights of the Relevant Person" in the KVKK; for what purpose Your personal data will be processed, to whom and for what purpose your processed personal data will be transferred, the method and legal reason for the collection of your personal data, and your other rights listed in Article 11 of the KVKK. We would like to inform you about:

In the capacity of Data Controller, we process, record, transfer, share and store your personal data as explained below and within the limits ordered 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 the changes that can be made in the current official legislation.

B. COLLECTION, PROCESSING AND PROCESSING OBJECTIVES OF PERSONAL DATA:

Our company, which operates in the fields specified in detail in the Company's Articles of Association, due to such activities; Your verbal, written or electronic personal data is collected and processed due to both the regulations of the Tourism and Revenue Administration and other relevant institutions and the contracts we have concluded. This is personal your data, to be able to provide services related to the activities of our company and to increase the quality of these services, to perform sales, marketing and other activities of our company, to store information, report, will be used to comply with information obligations. In addition, your personal data will be used in CRM (Customer Relationships) to increase the quality of service we offer you and for sales and marketing activities. It can also be used within the scope of studies such as management) applications.

Your personal data will not be used for purposes other than the above-mentioned purposes without your explicit consent, and will not be shared or transferred to third parties, except for legal obligations and official institutions/organizations.

Our company, your personal data in question only; KVKK art. In other cases stipulated in 5/f.2, our value-added customers In order to provide services, opportunities and opportunities and to increase service quality, with our domestic or foreign affiliates and directly or indirectly affiliates and joint ventures or legal with public institutions or organizations that are authorized to request such data as a necessity and provided that adequate measures are taken, domestic or foreign institutions with which we have a contract for our activities, suppliers, authorized dealers/dealers/business partners.

Although your personal data may vary depending on the services, products or commercial activities provided by our Company; automatic or non-automatic methods, offices, branches, It will be possible to gather verbally, in writing or electronically through 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 can be processed by being created and updated.

In addition, with the intention of using the services of our Company;
a. When you use our call center or website,
b. Visit our company, our website or our social media channels/media when you do,
c. When you attend trainings, seminars or organizations organized by our company,l Your data will be able to be processed. Compliance with other law expressed in the laws of the Republic of Turkey with your consent or your personal data obtained for reasons;

(I) Our business units can carry out the necessary work to benefit you from the products and services offered by our company;

(II) Customizing and recommending the products and services offered by our company according to your tastes, usage habits and needs;

(III) Ensuring the legal and commercial security of our Company and the persons who have business relations with our Company (Administrative operations for communication carried out by our Company, providing physical security and control, business partner/customer/supplier (authorized or employees) evaluation processes, legal compliance process, financial affairs etc.);

(IV) Improving the services provided by our company and improving our quality policy,

(V) To be informed about and benefit from the general and special campaigns, promotions, promotions, discounts and similar advantages offered by our company;

(VI) When you log in with your user name and password in order to receive services from the channels offered by our company, your personal data, preferences, transactions and browsing time in the relevant channels To process the data obtained with you in order to provide you with the information and services you have requested;

(VII) All kinds of loyalty cards issued and/or to be issued by our Company and its related companies/organizations and website memberships of our Company and its related companies/organizations. notifications (renewal, expiration, etc.), all kinds of communication that may be established with you, new services and products to be offered, changes or innovations that may occur in personal data policies and membership conditions. and to inform about similar issues;

(VIII) To inform you about the information, events and services you will request from our company;

(IX) Determination and implementation of our company's commercial and business strategies;

(X) Ensuring the execution of our company's human resources policies and;

(XI) Personal data processing specified in Articles 5 and 6 of the KVK Law for the purposes of fulfilling a legal obligation determined by the legislation, if it is clearly stated in the legislation or if necessary It can be processed by our Company and its related companies/organizations and other real and/or legal persons specified in Article (C) below, within the terms and purposes.

C. METHODOLOGY AND LEGAL REASON FOR COLLECTING PERSONAL DATA:

Your personal data can be collected in any verbal, written or electronic media in line with the purposes stated in the above articles as a Company. It is obtained in order to provide our services within the determined legal framework and in this context, for our Company to fully and accurately fulfill its contractual and legal responsibilities. For this legal reason Your collected personal data is processed, recorded, transferred for the purposes specified in article (B) of this text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVK Law, shared and stored.

D. PROCESSING OF PRIVATE DATA:

According to the KVK Law, the race, ethnic origin, political opinion, philosophical belief, religion, sect or other belief, dress and dress, association, foundation or union of the persons Membership, health, sexual life, criminal conviction and security measures, as well as biometric and genetic data are special personal data. Our company, in the processing of special quality personal data, it also takes the measures determined by the Personal Data Protection Board at a sufficient level. In order to provide better service, our company can only collect the sensitive data of the persons with the consent of the relevant person and only i am collectingwill work to serve your pain.

E. TO WHOM AND FOR WHAT PURPOSES THE PROCESSED PERSONAL DATA MAY BE TRANSFERRED:

Your collected personal data is transferred to AAK Turizm Emlak İnş. Trade Ltd. Sti. as well as to our shareholders, business partners, suppliers, legally authorized public institutions and private individuals, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVK Law.

F. TRANSFERRING PERSONAL DATA ABROAD:

Our company, within the conditions determined by the Personal Data Protection Board in the KVK Law, in accordance with the other conditions in the law and after obtaining the explicit consent of the person for this purpose. has the authority to transfer abroad.

G. RIGHTS OF THE PERSONAL DATA OWNER STATED IN ARTICLE 11 OF THE KVK LAW:

Within the scope of the KVK Law, the data subject has the right to be informed and approved before the personal data is processed, recorded, transferred, shared and stored. We accept that it has the right to determine the fate of the data after it is processed, recorded, transferred, shared and stored. In this context, your rights as personal data owners In case you submit your requests regarding the Processing of Personal Data to our Company through the methods set out below in this "Information Text on the Processing of Personal Data", our Company will respond to the request within thirty days at the latest, depending on the nature of the request. will be finalized free of charge.

Regarding your requests regarding your rights as personal data owners, in accordance with the Communiqué on Application Procedures and Principles to the Data Controller published by the Personal Data Protection Board.

I. If your application is to be answered in writing, up to ten pages will not be charged. A transaction fee of 1 Turkish Lira may be charged for each page over ten pages.

II. If the response to the application is given in 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;
a. Learning whether personal data is processed,
b. If personal data has been processed, requesting information about it,
c. Purpose of processing personal data and their Learning whether it is used for its intended purpose,
d. Knowing the third parties to whom personal data is transferred at home or abroad
e. In case of incomplete or incorrect processing of personal data, their to request the correction of the transaction and to notify the third parties to whom the personal data has been transferred,
f. Requesting the deletion, destruction or anonymization of personal data within the framework of the conditions stipulated in Article 7 of the KVK Law, requesting people to be notified,
g. Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,
h. In the event that personal data is damaged due to unlawful processing, it has the right to demand the compensation of the damage.

On the other hand, individuals do not have a right to anonymized data within the Company. Our company, personal data, in accordance with the business and contractual relationship, a judicial duty or government authority. It can be shared by the relevant institutions and organizations in order to use its legal powers.

H. TIMES THAT YOUR PERSONAL DATA WILL BE PROCESSED:

In accordance with the KVK Law, your personal data processed for the purposes specified in this "Clarification Text Regarding the Processing of Personal Data", the purpose that requires processing according to Article 7/f.1 of the KVK Law is eliminated. data when removed and/or in accordance with the legislation.Once the expiry of the time-out periods that we are required to process your personal data, your personal data will be deleted, destroyed or anonymized by us and continue to be used. will be.

I. SITUATIONS WHERE OUR COMPANY CAN PROCESS YOUR PERSONAL DATA WITHOUT YOUR EXPRESS CONSENT, ACCORDING TO THE LAW:

Pursuant to Article 5 of the KVKK, our Company may process the above-mentioned personal data that it has received in accordance with the law, without your explicit consent, in the following cases:

Cases expressly stipulated in the laws;
I. In cases where you, as the data owner, are unable to express your consent due to actual impossibility, or in cases where your consent is not legally valid, you or a It is necessary to process your personal data in order to protect the life or bodily integrity of someone else,
II. Provided that it is directly related to the establishment or performance of a contract you have concluded with our company and its related companies/organizations, other real and/or legal persons specified in Article (C), It is necessary to process the personal data of the parties to the contract,
It is compulsory for our company to fulfill a legal obligation,
IV. Your personal data has been made public by you,
V. Data processing is mandatory for the establishment, exercise or protection of a right,
VI. 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 ACCORDING TO THE PERSONAL DATA PROTECTION LAW:

In accordance with paragraph 1 of Article 13 of the KVK Law, you can forward your request to our Company to exercise your above-mentioned rights, using the method(s) determined/to be determined by the Personal Data Protection Board. Alternatively, if you wish, you can submit your application in writing to our Company in accordance with the KVK Law. You can always contact us at kvkk@garciahotels.com to use your rights in article 11 of Law No. 6698. You can contact us by sending an e-mail to Only kvkk@garciahotels.com e-mail address should be used for matters related to your personal data. Submissions will not be considered.

Rights regarding personal data can only be exercised about personal data. Persons other than the person who filled out the form and attached official documents identifying your identity. Requests for data will not be considered. Forms without official documents identifying your identity will not be considered. Even when data deletion requests are fulfilled, the request is made by the official authorities. If requested, we inform you that we are obliged to share the data with the official authorities.