Policy on the Processing of Personal Data
Purpose of the Protection and Processing of Personal Data
Operating within the scope of Yörükoğlu Ticaret Turizm Kuy. Pet. İnş. Ltd. Şti, a leading brand in the Tourism and Hotel Management and Hospitality sector, are the facilities below
Adalya Elite Lara Hotel
Adalya Ocean Hotel
Adalya Resort Hotel
Adalya Art Side Hotel
As the Data Officer, our Company is committed to ensuring the security of your personal data and we attach great importance to the processing, recording, transfer, sharing and storage of all kinds of personal data related to our Company, including data belonging to those benefiting from our products and services, in accordance with the Personal Data Protection Law No. 6698 (“PDP Law”).
The protection of personal data is one of our Company’s fundamental policies. Throughout the Company's existence, we have prioritized the confidentiality of personal data and adopted this as a working principle, and our employees are required to work in accordance with this principle. Our Company accepts and undertakes to comply with all responsibilities described by the PDP Law. With full awareness of this responsibility and as the Data Officer, we process, record, transfer, share and store your personal data in the manner described below and within the limits proscribed by official legislation.
If you have questions regarding the Company's Policy on the Processing of Personal Data, please contact us at the address(es) listed below:
Application Address: Kemerağzı Mah. Tesisler Cad. No:416 D:1, 07112 Kundu/Aksu/Antalya
Application E-Mail: hukuk@adalyahotels.com
Our Company reserves the right to update this Policy on the Processing of Personal Data at any time within the framework of any changes in applicable official legislation.
B. Collecting and Processing of Personal Data and Processing Objectives
Our Company's policy on the Protection and Privacy of Personal Data has been prepared in accordance with the PDP Law. In this context, the personal data you provide may vary according to the services, products or commercial activities provided by our Company; this personal data may be collected via offices, branches, dealers, call centres, our website, social media channels, mobile applications and similar tools, via verbal, written or electronic means, via automatic or non-automated methods.
In addition, your personal data will be processed when you access or visit the following areas with the intention of taking advantage of our Company’s products and services:
• our call center and/or website,
• our physical offices, facilities and/or units,
• our website and/or social media channels and platforms,
• Training, seminars, or organizations organized by our Company.
Your personal data, obtained from you with your consent or in accordance with the legislation in effect in the Republic of Turkey, may be processed by our Company and related companies/organizations and other real and/or legal persons as specified in clause (E) inclusive of Articles 5 and 6 of the PDP Law within the personal data processing requirements and purposes. These purposes include:
• Ensuring that activities conducted by our business units provide you with the most suitable products and services offered by our Company;
• Ensuring that the products and services offered by our Company are in accordance with your preferences, usage habits, and needs;
• Improving the quality of our services and our quality policy;
• Providing you with relevant general and special campaigns from our Company, including promotions, discounts, and similar advantages;
• Using your personal data to ensure that your preferences, transactions and navigation data are retained in the relevant media when you log in with your user name and password so that you may receive optimal services from the channels provided by our Company;
• Ensuring the legal and commercial security of the Company and its business relations (administrative operations for communication carried out by our Company, ensuring the physical security and control of the Company’s locations, evaluation processes of the partner/customer / supplier (manager and/or employees), legal compliance process, financial affairs, etc.);
• Providing you with the information, activities and services that you can request from our Company,
• Determining and implementing the commercial and business strategies of our Company;
• Ensuring the execution of our Company's human resources policies; and
• Execution of any legal obligation specified in the legislation, if clearly stated in the legislation or if necessary.
C. Method and Legal Reason of Personal Data Collection
Your personal data is obtained in the form of all kinds of verbal, written or electronic media in order to provide our products and services within the legal framework determined for the purposes stated in the above articles and, in this context, in order for our Companies to fulfill completely and accurately all obligations arising from the contract and the law. Your personal data collected for this legal reason is processed, recorded, transferred, shared, and stored for the purposes specified in clause (B) of this text within the scope of the personal data processing terms and purposes specified in articles 5 and 6 of the PDP Law.
• Processing of Personal Data of a Special Nature
In Article 6 of the PDP Law, some personal data is identified as ‘Special Nature’, with the risk of causing the victimization or discrimination of persons when it is unlawfully processed. This data includes race, ethnicity, political beliefs, philosophical beliefs, religion, sect or other beliefs, clothing, foundation or trade union membership, health, sexual life, criminal convictions and security measures, and biometric and genetic data. Our Company acts in accordance with the regulations stipulated in Article 6 of the PDP Lawl in order to process personal data of a special nature and is sensitive to the protection of this data.
Our Company processes personal data of a special nature provided that adequate measures are determined by the PDP Board, in accordance with PDP Law, in the following situations:
a. If the Personal Data Owner provides explicit consent:
Our guests can share their conditions with our Company and request customized services and share their special data for this purpose (In the case of requesting special service by sharing data of a special nature, for example, request for a thin pillow due to a neck hernia, request for a room on the ground floor due to heart disease, request for special meals due to allergies, etc.).
To be able to provide customized services to meet the needs of our guests, who identify those needs by sharing their data of a special nature, and to be able to offer the same services to those guests in the future, our Company will process their data of a special nature in the case that explicit consent is provided by the related person and solely to serve the purpose of collection.
b. If the Personal Data Owner does not provide explicit consent:
- Data of a special nature, with the exception of health- and sexual life-related data, in cases where stipulated the law, will be processed
- The Personal Data Owner’s data of a special nature regarding health and sexual life will be processed solely for the purposes of public health protection, preventive medicine, medical diagnoses, conducting treatment and care services, planning and management of health services, and financing purposes, by individuals under confidentiality obligation or by authorized institutions.
E. To whom, and for what purpose, processed data may be transferred
In order to serve the purposes stated in clause (B), your collected personal data can be transferred to the hotels listed below, which operate within the scope of Yörükoğlu Ticaret Turizm Kuy. Pet. İnş. Ltd. Şti.
• Adalya Elite Lara Hotel
Adalya Ocean Hotel
Adalya Resort Hotel
Adalya Art Side Hotel
and to our shareholders, business partners, suppliers, public authorities and private individuals authorized by law, in accordance with the personal data processing requirements and purposes stated in Articles 8 and 9 of the PDP Law.
F. Transfer of personal data abroad
Our Company has the authority to transfer personal data abroad, under the conditions stated in the Protection of Personal Data Law, in accordance with the other requirements in the PDP Law, after receiving the explicit consent of the Personal Data Owner.
G. The rights of the Personal Data Owner, as stated in Article 11 of the PDP Law
Within the scope of the PDP Law, we acknowledge that the person concerned has the right to be informed and acknowledged prior to the processing, recording, transfer, sharing and storage of their personal data, and the right to determine the fate of their data after the data has been processed, recorded, transferred, shared and/or stored.
In this context, if you submit your request for your rights as Personal Data Owners to our Company in accordance with the methods listed below in the Policy on the Processing of Personal Data, our Company will finalize the request within a maximum of 30 days, according to the nature of the request.
Regarding your rights as Personal Data Owners, issued by the Personal Data Protection Board pursuant to the Declaration on the Procedures and Principles of Application to the Data Officer:
• If your application submitted in writing, no fee will be charged for up to 10 pages. For additional pages, a processing fee of one (1) Turkish lira per page may be charged.
• In the event that the response to the application is provided via a recording medium such as a CD or a flash drive, any processing charges requested by our Company shall not exceed the cost of the recording medium.
In this context, the Personal Data Owners have the right:
• To learn whether their personal data has been processed;
• To request personal information if personal data is processed;
• To learn the purpose of the processing of personal data and whether it is being used appropriately;
• To learn the third parties to which personal data is transferred, in Turkey or abroad;
• To request the correction of personal data in the case of incomplete or incorrect processing, and to request the notification of the transaction to third parties to which the personal data is transferred;
• To request the deletion, destruction or anonymization of personal data within the framework of the provisions of Article 7 of the PDP Law;
• To object to the emergence of a result obtained via analysing the processed data exclusively through automatic systems that is damaging to the Personal Data Owner individual;
• To request for compensation of loss and/or damages arising from unlawful processing of personal data.
On the other hand, individuals do not have rights in relation to anonymized data. Our Company may share personal data with related institutions and organizations in order to exercise a judicial duty or the statutory powers of the state authority in accordance with the business and contractual relationship.
H. Duration of Processing Your Personal Data
In accordance with the PDP Law, your personal data processed for the purposes stated in the Policy on the Processing of Personal Data will be deleted, destroyed, or anonymized when the purpose of processing according to Article 7 / f.1 of the PDP Law is removed and/or the period for which we are required to process your data in accordance with the legislation expires.
• The conditions, according to the law, in which our Company may process your personal data without your explicit consent
Pursuant to Article 5 of the PDP Law, our Company may process your personal data, as specified above and in accordance with the law, without your consent in the following conditions:
• If you are unable to provide your explicit consent as the data owner and/or your personal data is required in order to protect your or someone else's life or physical integrity when your consent is legally invalid;
• When it is necessary to process the personal data of parties to a contract, provided that the Company and its related companies/organizations are directly related to the establishment or execution of a contract you have concluded with real and/or legal persons specified as specified in Article (C);
• When our Company is obliged to fulfill its legal obligation;
• When your personal data is publicized by you;
• When data processing is mandatory for the establishment, use or protection of a right;
• When it is compulsory to process data for the legitimate interests of our Company, without prejudice to your fundamental rights and freedoms.
J. To make a request in accordance with the Law on the Protection of Personal Data
Pursuant to Article 13 (1) of the PDP Law, you may submit your request to our Company to exercise the aforementioned rights by the method(s) determined or to be determined by the Personal Data Protection Board. Alternatively, you may submit your application in writing to our Company in accordance with the PDP Law.
To submit an application in writing, complete the Application Form at www.adalyahotels.com/KVKK and sign it. Then, select one of the following methods and deliver the form to our Companies.
• You can personally submit your official documents declaring your identity (e.g., photocopy of a legally valid identification document) with a signed copy of the form containing your comments about the rights you requested, to the following address:
Kemerağzı Mah. Tesisler Cad. No:416 D:1, 07112 Kundu/Aksu/Antalya
• You may submit the form and the official documents declaring your identity through a Notary.
or
• You may submit the form and the official documents declaring your identity to hukuk@adalyahotels.com with a secure electronic signature or a mobile signature.
You may submit the form and the official documents declaring your identity, as Data Owner, to our Company using the e-mail address that you have previously provided to the Company and which is registered in the Company's system.
According to the nature of the request, the Company will ensure that it is finalized within a maximum of 30 days.
The rights to personal data will be solely used regarding the personal data of the individual who submitted the request. Requests related to the data of persons other than the person who completed the form will not be taken into consideration. Forms that do not include official documents will not be considered. We inform you that we are obliged to share the data with official authorities if requested, even when data deletion requests are fulfilled.
