DISCLOSURE TEXT

(For Hotel Guests)

Being the data controller

You can access the details of the explanations in this clarification text prepared in accordance with the KVKK Policy, which has been prepared and implemented, and the Personal Data Protection Law No.6698 (KVK Law), in the Data Controller KVKK Policy and the documents in its annexes ) at this accommodation facility owned by the company or companies of , CEYTUR CEYLAN TURİZM İŞLETİ SAN.VE TİC.A.Ş. (- hereinafter referred to as SİMENA HOTEL), which is the Data Controller.

Within this scope:

1. Your Processed Personal Data

2. Identity and Family Information [Name-surname, TCK No, Passport No, place of birth - date, marital status, gender, child name, number, age and date of birth, signature, voucher (travel card) information and registration card (accommodation card information), room type and number, flight number, hotel hosted, accommodation dates and amount]

3. Contact information [address, phone number, e-mail address, cap address]

4. Customer Transaction Information [(Vehicle license plate, questionnaire form, records for product and service delivery, demands, instructions, photos, wedding, special birthday anniversary, invoice information, order information, request information)

5. Physical Space Security Information [Entry-exit registration information of customers and visitors, camera records,]

6. Transaction Security Information [IP address, hotspot records, password and password information, website login and exit information, log records]

7. Financial Information [Credit card number, cvc code, expiry date]

8. Visual and Audio Records and Information [Visual and audio records and information]

9. Health Information [Information on disability, chronic diseases, illnesses, asthma, diabetes, heart, blood pressure diseases, personal health information,]

2. Collection Method of Your Personal Data and Legal Reasons

According to this clarification text, your personal data are transmitted by or by third parties that we have an agreement with as a requirement of operating with the solution partners in the contractual relationship with automatic or non-automatic methods provided that they are part of the data recording system. Information is obtained orally, in writing or electronically through documents and similar means.

These data can be processed directly due to your explicit consent within the framework of Article 5 of KVK Law No.6698, and in cases where your express consent is not required, in the presence of the following conditions. According to this;

1. It is clearly stipulated in the laws.

2. It is compulsory for the protection of the life or body integrity of the person who is unable to disclose his consent due to the actual impossibility or whose consent is not legally valid

3. It is necessary to process personal data belonging to the parties to the contract, provided that it is directly related to the establishment or performance of a contract.

4. It is mandatory for the data controller to fulfil his legal obligation.

5. It is made public by the person concerned.

6. Data processing is mandatory for the establishment, use or protection of a right.

7. It is mandatory to process data for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not damaged

Within the scope of Article 6 of KVKK numbered 6698, your private personal data other than health and sexual life can be processed based on your explicit consent or in accordance with the provisions of the same article in the cases stipulated by the law. In the absence of your explicit consent, your personal data relating to health and sexual life can only be collected by persons or authorized institutions and organizations under the obligation of confidentiality for the purpose of protecting public health, conducting preventive medicine, medical diagnosis, treatment and care services, planning and managing health services and financing. can be processed.

3. Purpose of Processing Your Personal Data

Your personal data, in accordance with Articles 4, 5 and 6 of KVK Law No.6698, comply with the law and the rules of honesty, being accurate and up-to-date when necessary, being processed for specific, clear and legitimate purposes, being linked, limited and proportionate to the purpose for which they are processed, They are processed within the following purposes, taking into account the principles of retention for the period stipulated in the relevant legislation or for the purpose for which they are processed.

1. Execution of Emergency Management Processes

2. Execution of Information Security Processes

3. Conducting Activities in Compliance with Legislation

4. Execution of Finance and Accounting Affairs

5. Execution of Loyalty Processes to Company / Products / Services

6. Ensuring Physical Space Security

7. Follow-up and Execution of Legal Affairs

8. Conducting Communication Activities

9. Execution of Goods / Service Sales Processes

10. Execution of Goods / Service Production and Operation Processes

11. Execution of Customer Relationship Management Processes

12. Conducting Activities for Customer, Guest Satisfaction, Service Quality

13. Organization and Event Management

14. Execution of Advertising / Campaign / Promotion Processes

15. Execution of Custody and Archive Activities

16. Execution of Contract Processes

17. Tracking of Requests / Complaints

18. Ensuring the Security of Data Supervisor Operations

19. Execution of Investment Processes

20. Informing Authorized Persons, Institutions and Organizations

21. Conducting Management Activities

22. Creating and Tracking Visitor Records

Your personal data are not processed except for the purposes shown above. All kinds of technical and administrative measures are taken by the enterprise to prevent the unlawful processing or illegal access of personal data.

4. Transfer of Your Personal Data

Your personal data can be transferred domestically or abroad in accordance with Articles 8 and 9 of KVK Law No. 6698, if the following conditions are met.

Personal data collected due to the existence of the conditions in Article 5 of KVK Law No.6698 or in line with your express consent, in accordance with the above-mentioned purposes and in accordance with the provisions of Articles 8 and 9 of the Law, shareholders, It can be transferred to third parties from whom service is received or provided to persons and institutions that interact, such as suppliers.

Provided that adequate precautions are taken, your personal data related to health can only be kept open by persons or authorized institutions and organizations under the obligation of confidentiality for the purpose of protecting public health, conducting preventive medicine, medical diagnosis, treatment and care services, planning and managing health services and financing. can be transferred without seeking consent.

It is necessary for the protection of the life or physical integrity of the person or someone else who is unable to disclose his consent due to actual impossibility or whose consent is not legally valid, is necessary to process personal data of the parties of the contract, provided that it is directly related to the establishment or performance of a contract. data processing is mandatory for the data controller to fulfill his legal obligation, data is publicized, data processing is mandatory for the establishment, use or protection of a right, data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm your fundamental rights and freedoms, and also the public Protection of health, preventive medicine, medical diagnosis, treatment and care services, The planned financing of health services and management purposes, secrecy personal data, provided to be performed by persons or competent institutions and organizations under the presence of adequate protection abroad, in case of the absence of adequate protection of an adequate protection of responsible data in Turkey and in the foreign countries in writing can be transferred abroad without your explicit consent, provided that they undertake and have the permission of the KVK Board. The absence of adequate protection in the event of an adequate protection of responsible data in Turkey and in foreign countries about to commit in writing and open your consent, subject to the Board's permission KVK transferred abroad without seeking. The absence of adequate protection in the event of an adequate protection of responsible data in Turkey and in foreign countries about to commit in writing and open your consent, subject to the Board's permission KVK transferred abroad without seeking.

The KVK Board determines whether there is sufficient protection in the foreign country and whether the transfer abroad will be allowed; international conventions that Turkey is a party, personal data demand that countries with reciprocity condition for transferring data between Turkey, with respect to any tangible personal data transfer, processing and the nature of the personal data, the purpose and duration of the legislation and practice on the issue of the country's personal data will be transferred personal It makes a decision by evaluating the measures undertaken by the data controller in the country where the data will be transferred and, if necessary, taking the opinion of the relevant institutions and organizations. Your personal data, without prejudice to the provisions of international conventions, Turkey or in a serious state of your interests will be damaged,

In this context, your personal data can be transferred for execution as follows:

1. Authorized Public Institutions and Organizations

2. Company partners and officials,

3. To business and solution partners,

4. Supplier persons and companies,

5. To the real or legal persons with whom we interact, for the following purposes, namely;

6. Execution of Emergency Management Processes

7. Execution of Information Security Processes

8. Conducting Activities in Compliance with Legislation

9. Execution of Finance and Accounting Affairs

10. Execution of Loyalty Processes to Company / Products / Services

11. Ensuring Physical Space Security

12. Follow-up and Execution of Legal Affairs

13. Conducting Communication Activities

14. Execution of Goods / Service Sales Processes

15. Execution of Goods / Service Production and Operation Processes

16. Execution of Customer Relationship Management Processes

17. Conducting Activities for Customer, Guest Satisfaction, Service Quality

18. Organization and Event Management

19. Execution of Advertising / Campaign / Promotion Processes

20. Execution of Custody and Archive Activities

21. Execution of Contract Processes

22. Tracking of Requests / Complaints

23. Ensuring the Security of Data Supervisor Operations

24. Execution of Investment Processes

25. Informing Authorized Persons, Institutions and Organizations

26. Conducting Management Activities

27. Creating and Tracking Visitor Records

5. Your Rights as Personal Data Owner

Within the scope of the law, the data owner, i.e. the person concerned

1. Learning whether personal data is processed,

2. Requesting information if personal data has been processed,

3. Learning the purpose of processing personal data and whether they are used appropriately,

4. To know the third parties to whom personal data are transferred domestically or abroad,

5. To request correction of personal data in case of incomplete or incorrect processing,

6. To request the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of KVKK,

7. To request notification of the personal data that are processed incorrectly and requested to be corrected and the personal data requested to be destroyed to third parties,

8. Object to the occurrence of a result against the person himself by analyzing the processed data exclusively through automated systems,

9. In case of damage due to unlawful processing of personal data, to demand the compensation of the damage,

has the rights.

In order for them to exercise their complaint rights as a personal data owner, you must first apply to the personal data controller by using the following communication channels. No complaint can be made to the KVK Board without exhausting this road.

Your request is answered by our company as the data controller as soon as possible and within 30 days at the latest, depending on the nature of the request.

If your application is rejected or the response is insufficient, or your application is not answered in time, you can use the right to complain to the KVK Board or apply directly to the judicial remedy.

Application Address and contact information:

6. Storage Period of Your Personal Data

Your personal data that needs to be processed with the above-mentioned methods and in line with the specified purposes are stored for the period specified in the data inventory, taking into account the time-out and rights-reducing periods specified in the law. In the event that the reasons for the processing of your data disappear or the periods required for the processing of your data in accordance with the legislation have expired, our Company will be deleted, destroyed or anonymised by using any of the destruction methods within six-month periods at the latest or within thirty days upon your request.

Deletion of your personal data is the process of making it inaccessible and unavailable for the relevant users in any way.

The destruction of your personal data is the process of making personal data inaccessible, retrieved and reusable in any way.

Anonymization of your personal data is to make the data unrelated to an identified or identifiable natural person, even by using appropriate techniques.

Transactions regarding the deletion, destruction and anonymization of your personal data are recorded. These minutes are kept for 5 years in the face of public requirements.

We present your information with our respect.

7. Identity of the Data Controller

KVKK

(Processing and Protection of Personal Data - Summary Text)

SCOPE AND PURPOSE

This Policy is within the scope of KVK Law No.6698 and KVK Policy Book (SİMENA HOTEL), namely CEYTUR CEYLAN TURİZM İŞLETME SAN.VE TİC.AŞ. and aims to make arrangements regarding the processing of personal data arising from or directly obtained from legal, commercial or financial relations with its customers, personnel and real or legal persons with whom it is in contact and interaction, to determine the conditions to be complied with, to declare and announce.

Disclosure Obligation

Entered into force on 07.04.2016 Within the scope of KVKK (Personal Data Protection Law) numbered 6698, Personal data is processed during SIMENA HOTEL's relations with its customers, employee personnel, as well as with real or legal persons with whom they communicate and interact, must be regulated in a legal order due to the obligations and requirements imposed by the legislation.

SİMENA HOTEL pays utmost attention and care to the principles of personal data security and confidentiality of the customers, personnel and the relevant persons with whom they communicate and interact. During the performance of the services, the personal data security of the relevant persons is given priority.

The aforementioned kAny personal data (including personal data of special nature) that can be associated with a real person in accordance with the provisions of the moment are considered as personal data within the scope of the KVK Law. These personal data are processed by SİMENA HOTEL in the capacity of Data Controller with the methods detailed below and within the framework of the limits ordered by the legislation.

"Processing of Personal Data" means obtaining, recording, storing, preserving, changing, reorganizing, disclosing, transferring, taking over, making such data fully or partially automatic or non-automatic, provided that it is a part of any data recording system. refers to all kinds of operations performed on data, such as classification or prevention of use.

Processing Purpose and Legal Basis of Personal Data

Personal data are automatically or non-automated as required by the legislation, such as registration to the platform, telephone, fax, e-mail, SMS and other social media channels, mobile applications, including audio and video recording, in written or verbal form, by SIMENA HOTEL electronically or can be collected in a physical environment.

Within the framework of Article 5 of KVKK numbered 6698

a) The explicit consent of the data owner,

b) It is clearly prescribed in the laws,

c) It is mandatory for the protection of the life or physical integrity of the person who is unable to disclose his consent due to the actual impossibility or whose consent is not legally valid,

d) It is necessary to process the personal data of the parties to the contract, provided that it is directly related to the establishment or execution of the contract issued as a result of the approval and / or signature with SIMENA HOTEL,

e) It is mandatory for SIMENA HOTEL to fulfil its legal obligation,

f) It has been made public by the relevant person personally,

g) Data processing is mandatory for the establishment, use or protection of a right,

h) Provided that it does not harm the fundamental rights and freedoms of the relevant person, data processing is mandatory for the legitimate interests of SİMENA HOTEL.)

And again within the scope of Article 6 Sharing and Transfer of Personal Data is processed within the specified personal data processing terms and purposes as follows:

a) With the Explicit consent of the data owner,

b) In other cases stipulated by laws

Requesting the personal data of the relevant person by official institutions and organizations in cases where the legislation deems necessary by domestic or foreign solution partners, project partners, programs and cooperation partners, supply providers, institutions and organizations, independent auditors, banks and financial institutions, other companies, individuals and organizations from which assistance and support is received, consultancy firms such as lawyers, financial advisors, law, informatics, quality and finance consultants, with which SIMENA HOTEL has commercial, legal and economic relations as a requirement of its activities and responsibility , can be shared and transferred by taking physical security measures. These sharing and transfer transactions are also valid for abroad.

SIMENA HOTEL can transfer, process and store media of the personal data about the related person in Turkey with obtaining the necessary security measures or mainly in EU countries, the United States, other countries, including Britain, where the storage, archiving, information technology support received servers, hosting companies, programs, other electronics such as cloud computing is located abroad.

Collection Method of Personal Data

All contracts / information forms and other documents signed by the consent and / or acceptance of the personal data of the relevant person, approval, acceptance and notifications made with electronic approval and / or signature, SİMENA HOTEL's administrative center, physical environments, call centers, websites , mobile applications, internet transactions, social media and other public areas, user interviews, scanning forensic records, market research, Identity Sharing System, SMS, digital applications to websites, mobile applications, written / digital applications to sales teams, call center. The data obtained in verbal, written, visual, sound recording or electronic media, in which the relevant person is contacted or may communicate in the future, is collected completely or partially automatically or as part of any data recording system and stored taking into account the statute of limitations in accordance with the relevant legislation.

Personal data collected by SIMENA HOTEL for the legal reasons stated above may be processed or transferred in line with the previously described purposes of this policy, taking into account the personal data processing conditions specified in Articles 5 and 6 of the Law on the Protection of Personal Data No.6698.

User Rights

(In accordance with Article 11 of KVK Law No. 6698)

Related persons, regarding their personal data have the right of requesting the followings via e-mail from The SIMENA HOTEL and also they have other rights written in the legislation.

1) Learning whether it has been processed,

2) Requesting information if processed,

3) Learning the purpose of processing and whether it is used appropriately,

4) Knowing the third persons transferred domestically or abroad,

5) Requesting correction if it is incomplete / incorrectly processed,

6) To request the deletion, destruction or anonymization of personal data in case the reasons requiring the processing of personal data disappear,

7) To request the notification of the transactions made in accordance with the above-mentioned subparagraphs (5) and (6) against the third persons to whom they are transferred,

8) Object to the emergence of a result against you because it is analysed exclusively with automatic systems,

9) To request the compensation of the damage in case of damage due to illegal processing

Data Controller Who Can Apply Under Law

SIMENA HOTEL is the Data Supervisor who is registered in the VERBIS system under www.kvkk.gov.tr

Within the scope of the abovementioned rights the related person can send its requests, complaints, suggestions to the address given below of SIMENA HOTEL by personal application or through a notary or by indicating the e-mail address specified by the user during the account opening and registered on the website. .

Name, surname in applications Name, TR identity number, place of residence or workplace address for notification, mobile phone number, e-mail address and the subject of the request must be present, and the information and documents related to the request must be attached to the application.

The official language of correspondence with SIMENA HOTEL is Turkish. For this reason, it is essential that all kinds of applications, correspondence, problems, complaints and suggestions are written and sent in Turkish.

Application is to be sent in writing and physically and must have a wet signature.

Demand, problem, suggestion and As a rule, responses to complaints are not subject to a fee. However, if there is a cost, fee or other cost related to the answer to be given, SİMENA HOTEL reserves the right to demand the fees in the tariff determined by the KVVK Regulations or other authorities.

For more detailed information or for your problems, requests, suggestions and complaints about the KVK Policy You are kindly requested to apply to the contact address below.

In addition, the KVK Policy book It is possible to obtain it from SIMENA HOTEL.

For your physical and written applications you can use the contact information given below: