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INFORMATION ON THE LAW ON PERSONAL DATA PROTECTION

Privacy Notice

Most Recent Update: 23/12/2021

This disclosure text was prepared pursuant to article 10 of the Law no. 6698 on Protection of Personal Data (“LPPD”) and the Communiqué on Principles and Procedures to be Observed in Fulfillment of Disclosure Obligation by Siltur Otelcilik A.Ş. (“Feronya Hotel”) in the capacity of the data controller.

As Feronya Hotel, we care about protection of your personal data as our guests, visitors, suppliers, and business partners, and we want to inform you in accordance with the LPPD. The latest version of this text is accessible via https://www.feronya.com/en/information-on-the-law-on-personal-data-protection/ or you can ask for a current copy from the reception desk.

What is personal data?

Pursuant to the LPPD, personal data means any information relating to an identified or identifiable natural person (“Personal Data”).

Data on race, ethnicity, political opinion, philosophical belief, religion, sect or other beliefs, manners of clothing, association, foundation or union membership, health, sex life, criminal record and safety measures of individuals, as well as biometric and genetic data constitute private personal data ( Special Categories of Personal Data“”).

Which personal data are we processing?

Your personal data, obtained by means of digital and written forms, electronic messages, e-mail correspondences, telephone calls, and verbal interactions during your visit to Feronya Hotel, via our website, or throughout our business relationship, are collected and processed directly from you or third parties completely or partially by automated or non-automated means. If you share such data with our service-provider suppliers or our business partners with which we cooperate, we can also collect and process your personal data through these entities.

i. Our guests:

- Name and surname, TR ID number, passport number, date of birth, nationality, sex, hotel check in - check out dates and times, flight details, telephone number, e-mail address, agency/intermediary company details, VIP guest information and bank/credit card details are processed during reservation and check-in procedures for your customer record and operations.

In addition, additional data such as smoking/non-smoking room preference, honeymoon and birthday celebration can be processed with regard to the stay according to the preferences of our guests.

- Requests and complaints, orders, room entrance-exit records, reservation changes, CCTV footages, and your data concerning special nutritional preferences, if any, are collected and processed throughout the duration of your stay.

- Message receipt and delivery confirmations and timestamps, as well as e-mail messages, are stored during your electronic correspondences. The number you are using to call us and/or the number you specify for contact purposes are stored during telephone calls.

- We can collect your personal data concerning complaints, reviews, and requests in posts that you share on social media accounts managed on behalf of Feronya Hotel and records on various websites from relevant service providers and/or by means of our suppliers.

- Special Categories of Personal Data : In addition to the above, your other personal data that you willfully share with us with regard to preference for rooms designed for our disabled guests, chronic illnesses, allergic reactions, and your medical status that constitute Special Categories of Personal Data , which your share with us to enable us fulfill your preferences and needs.

ii. Our Visitors:

- Names and surnames, visit times, telephone numbers, and e-mail address details, collected during meetings and event organizations, are processed.

- Requests and complaints, orders, CCTV footages, and your data concerning special nutritional preferences, if any, which can be collected throughout the duration of your visit, are processed.

iii. Our Suppliers and Business Partners:

- Names and surnames, TR ID numbers, e-mail addresses, telephone numbers, titles, positions, tax offices/ID numbers, full address details, collected during agreement negotiation and drawing up, are processed.

- Bank, invoice, payment, and current account details are processed in accounting processes.

- Message receipt and delivery confirmations and timestamps, as well as e-mail messages, are stored during your electronic correspondences. The number you are using to call us and/or the number you specify for contact purposes are stored during telephone calls.

- Your images recorded with CCTV, which can be collected during your visit to our hotel, are processed.

iv. Website

- Data on Internet Protocol (IP) address used to connect your computer to the Internet; Internet browser add-on types and versions; e-mail addresses; device and connection details such as Internet browser type and version; time setting; operating system and platform; port address; entered URLs; cookie number; viewed or searched products can be collected. Anonymous data are collected by means of cookies.

What are the purposes and legal grounds for processing of your personal data?

Briefly, we process your personal data for the purposes of, limited to, and as required by conducting our business activities concerning Feronya Hotel products and services. Your personal data are not processed within the scope of any activity that is not related to products or services of Feronya Hotel. Further details on our personal data processing purposes and the legal grounds of our processing mechanisms can be found below.

Personal data required for fulfillment of our legal and lawful obligations:

As Feronya Hotel, we have various legal and lawful obligations pursuant to regulations such as Turkish Commercial Code, Turkish Code of Obligations, Labor Law, as well as other legislation such as legislation specific to the tourism industry, tax legislation, and occupational health and safety regulations.

Accordingly, your personal data specified above in section 2 (except fo Special Categories of Personal Data ) are processed on the legal grounds of express stipulation in the legislation and the need for compliance with a legal obligation to which the data controller is subject in accordance with paragraphs (2)(a) and (2)(ç) of article 5 of the LPPD for the purposes of legal conduct of our activities, ensuring physical location security, performance of internal and external audit and ethical activities, conducting occupational health and safety activities, conducting retention and archiving activities, follow-up of requests and complaints, ensuring security of data controller operations, and providing information to competent authorities, institutions, and organizations..

This scope includes, for example, retention of payment records for presentation during financial audits or disclosing your details in response to legal requests received from law enforcement authorities or administrative bodies.

Personal data required for drawing up and performance of agreements with you:

Your personal data should be processed to offer products and services requested or purchased during reservation and/or check-in procedures and within the scope of fulfillment of our obligations with respect to sales and service contracts entered into with you, contacting you as necessary within this scope, performance of operations regarding reservations, requests, and complaints, and conduct of these processes.

Accordingly, your personal data specified above in section 2 (except for Special Categories of Personal Data ) are processed on the legal grounds of the need to process personal data of contractual parties, provided that it is directly related to drawing up or executing an agreement in accordance with paragraph (2)(c) of article 5 of the LPPD for the purposes of conducting finance and accounting works, conducting assignment processes, conducting communication activities, conducting business activities, conducting after-sale support services for goods and services, conducting contractual processes, and follow-up of requests and complaints.

This scope includes, for example, using check-in/check-out dates and times for coordination of the procedures for preparation of rooms for our guests, or processing debit or credit card details for collection of payments.

Personal data required for establishment, exercise, or protection of a right:

As Feronya Hotel, we may have to process your personal data for legal legal proceedings initiated in our favor or against us (lawsuit, enforcement proceedings, investigation, complaint, etc), or to offer, exercise, or protect certain rights such as our rights to claim or your rights concerning your personal data.

Accordingly, your personal data specified above in section 2 (except for Special Categories of Personal Data ) are processed on the legal grounds of the need to process data for the establishment, exercise or protection of any right in accordance with paragraph (2)(e) of article 5 of the LPPD for the purposes of conducting finance and accounting works, ensuring physical location security, follow-up and conduct of legal affairs, conducting communication activities, conducting risk management processes, conducting retention and archiving activities, follow-up of requests and complaints, ensuring security of data controller operations, and keeping visitor records.

This scope includes, for example, processing your personal data to defend Feronya Hotel in any lawsuit to be filed against it or in a dispute, or if required to fulfill an information request made by you with regard to your personal data .

Personal data that must be processed for our legitimate interests:

As Feronya Hotel, we may have to process your personal data for our legitimate interests such as developing new products and services, improving existing products and services, increasing customer satisfaction, performing effective promotional and marketing activities, increasing sales rates and reducing our costs, increasing efficiency, quality management, management of commercial risks, training and improvement of personnel, and effective use of resources.

Accordingly, your personal data specified above in section 2 (except for Special Categories of Personal Data )are processed on the legal grounds of requirement of data processing for legitimate interests of the data controller, provided that fundamental rights and freedoms of the relevant person are not impaired in accordance with paragraph (2)(f) of article 5 of the LPPD for the purposes of ensuring training activities, company/product/service loyalty processes, physical location security; conducting communication activities; receiving and evaluating recommendations for improvement of business processes; conducting production and operation processes for goods and services; conducting customer relations management processes and customer satisfaction activities; conducting marketing analysis activities, advertising/campaign/promotion processes, strategic planning activities; managing and conducting investment processes; ensuring security of movable property and resources; and keeping visitor records.

This scope includes, for example, using your feedback and complaints regarding products and services to improve these, or processing your check-in / check-out times for effectiveness of in-house assignment and coordination processes.

Data that are made public by you:

Your personal data that you share through public channels such as social media accounts and websites can be processed on the legal grounds of being made public by the relevant person in accordance with paragraph (2)(d) of article 5 of the LPPD, limited to your purpose of sharing these. For example, if you share a review about Feronya Hotel on a public website, we can process such information shared by you in the process of evaluating and improving our products and services.

Personal data required for protection of life or physical integrity of you or another person:

We can process your relevant personal data specified above in section 2 (except for Special Categories of Personal Data ) on the legal grounds of the need for the protection of life or physical integrity of the person himself/herself or of any other person, who is unable to explain his/her consent due to the physical disability or whose consent is not deemed legally valid in accordance with paragraph (2)(b) of article 5 of the LPPD as an exception provided that we are convinced that it is necessary for protection of life or physical integrity of you or another person if you are unable to explain your consent due to physical disability or if your consent is not deemed legally valid in good faith.

For example, if we are aware that you have a chronic illness, we can share your most recent address and contact details or room number with your relatives and/or public authorities upon request if you cannot be reached for a certain period.

Personal data that are processed based on your explicit consent:

Your explicit consent is not needed for personal data processing activities performed pursuant to any of the legal grounds mentioned above in accordance with the LPPD. However, if you are our guest or visitor, we can process your personal data upon obtaining your explicit consent in certain limited circumstances.

- If you explicitly give consent, we can process your Special Categories of Personal Data specified above in section 2, which you share with us. In this scope, your personal data are processed for the purpose of offering appropriate means for your medical condition (preference for disabled-friendly rooms), management of activities such as event or catering organizations, or your special needs specific to your medical condition (chronic illness, allergy, etc.) only with your explicit consent and limited to the purpose of sharing.

With whom do we share your personal data?

Your personal data are shared as necessary with our local shareholders and affiliated companies from which we receive services or with which we cooperate in supply, production, operation, distribution, logistics, management, marketing, and product/service development processes concerning our products and services, and operational processes, our suppliers and business partners with which we have contractual relationships concerning the same matters, and real entities and private law entities that receive products or services within the scope of contractual relationships in line with the abovementioned processing purposes and based on applicable legal grounds.

Your personal data, shared in this scope, are shared in compliance with adequate protection and security measures regarding protection of personal data, to the extent necessary and limited to the products and services of Feronya Hotel.

In addition, your personal data are shared with competent public institutions and organizations, if requested lawfully and within the scope of their authorities .

Without prejudice to our legal obligations, your personal data are not disclosed to third parties for any purposes that are not related to the products and services of our affiliated companies.

What are your rights?

In accordance with article 11 of the LPPD, you have the following rights concerning your personal data:

You can find out whether we process your personal data,

You can request pertinent information if your personal data was processed.

You can find out the purpose of processing and whether your personal data was purposefully used.

You can find out local and foreign third parties to whom your personal data was transferred.

You can request your personal data to be corrected if they were processed incompletely or incorrectly,

You can request your personal data to be deleted or destroyed pursuant to the terms stipulated under the LPPD.

You can request notification of procedures conducted with respect to your request for correction of your personal data, or deletion or destruction pursuant to the terms determined within the scope of the LPPD, to third parties, to whom your personal data were transferred,

You can object to an outcome against you that might arise due to the analysis of your processed Personal Data exclusively by means of automated systems.

You can request compensation for your losses if you incur losses due to unlawful processing of your Personal Data.

You can submit your requests concerning these rights after creating your request pursuant to the conditions determined in the Communiqué on Principles and Procedures for Application to the Data Controller by completing the application form on our website or by sending your request in writing to the following address.

We are unable to process applications that do not meet the minimum requirements determined by the Personal Data Protection Board pursuant to the applicable legislation.

Feronya Hotel shall finalize your request at no charge, as soon as possible and at the latest within thirty (30) days according to the nature of your request. If fulfillment of your requests involves a cost, the fees in the tariff determined by the Personal Data Protection Board can be charged to you.

You can access official website of the Personal Data Protection Board, where you can find the most recent legislation and information on practices about protection of personal data, via https://kvkk.gov.tr.

In addition, you can access detailed information on our personal data processing activities through the Data Controllers Registry Information System, made public by the Personal Data Protection Board and located at the URL https://verbis.kvkk.gov.tr.

Data Controller : Siltur Otelcilik A.Ş. (Feronya Hotel)

Address : Abdulhakhamit Cad. No:58 Taksim, Beyoğlu/İstanbul

Trade Registry No : 225272-0

Central Registration System : 0770-0026-3490-0019

E-mail : feronya@feronya.com

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