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 Clarification Text and Declaration of Consent under the Personal Data Protection Law No. 6698

As a Data Controller under Personal Data Protection Law No.6698, we, as Yeşilyurt İnşaat ve Turizm San. Tic. A.Ş / Kartepe Turizm A.Ş (the “Company”), will process personal data of our customers and employees and transfer them to third parties at home and abroad, to the extent permitted by related legislation. With this clarification text, we inform you about our mutual rights and obligations in accordance with the provisions of the Law.

A. Purpose of the Policiy on Protection and Processing of Personal Data:

As a leading brand in the Tourism and Hospitality industry of Turkey with its established hotels, Yeşilyurt İnşaat ve Turizm San. Tic. A.Ş/Kartepe Turizm A.Ş. (hereinafter referred to as "the Company"), as the data controller, approaches the security of your personal data with the utmost sensitivity. Keeping that in mind, we attach great importance to the processing, recording, transferring, sharing and storage of any personal data of all persons associated with our Company, including those benefiting from our products and services in accordance with the Protection of Personal Data Law ('PPD Law').

The protection of personal data is among the basic policies of our Company and our companies have always given a great priority to the confidentiality of personal data, adopted this as a working principle and instructed its employees to always work in line with this principle. Our company agrees and undertakes to comply with all the responsibilities imposed by the PPD Law. With full awareness of this responsibility and as a Data Controller, we process, save, transfer, share and store your personal data as described below and within the limits instructed by the related legislation.

B . Collection, Processing and Processing Purpose of Personal Data

The policy of our company on Protection of Personal Data is prepared in accordance with Law No 6698 on Protection of Personal Data and related legislation issued under the same law. In this context, your personal data may varies depending on the services, products offered and/or commercial activities performed by our Companies, and they can be collected verbally, in printed form or electronically by automatic and/or non-automatic means, offices, braches, dealers, call centres, website, soscial media channels, mobile applications, etc. As long as you benefit from the products and services of our companies, your personal data can be processed by creating and updating them.
In addition, your personal data may be processed in the following situations:

a. When you call our call centre or use our website;
b. When you visit our company, facilities and/or units;
c When you visit our website and/or our social media channels;
d. When you participate in training, seminars and/or events arranged upon your demand by our Companies or at our in-house facilities;
for the purpose of benefitting from the products and services of our Companies.

Your personal data obtained based on your consent and/or as requested under the laws of Repıblic of Turkey for conformity reasons may be used for the following purposes;

a. for enabling our units to do the necessary works to allow you to benefit from the products and services offered by our companies;
b. to recommend and offer products and services offered by our companies customized according to your likes, usage habits, and needs;
c to enhance the quality of the services offered by our Company and to improve our quality policy
d. to inform you about and allow you to benefit from general and special campaigns, promotions, discounts, and similar advantages offered by our Companies;
e. in order to process your personal data when you log in with user name and password to receive services from the channels offered by our Companies, the data about your preferences, transactions, and browsing time registered in these channels for providing you with the information and services you request;
f. to inform you about any loyalty cards issued and/or to be issued by our companies and their affiliated companies/organizations, to notify you about the subscriptions to our Companies as well as their affiliated companies/organizations (renewal, expiration, etc.), any communication to be established with you, new service to be offered and to inform you about changes, innovations and similar issues that may occur in products and personal data policies and membership conditions;
g∙ for ensuring the legal and commercial security of our Companies and of legal and natural persons who have a business relationship with our companies (administrative operations for communication carried out by our companies), ensuring the security and control of the physical areas of the companies, business partners/customers/suppliers (their authorized persons or employees) assessment processes, legal compliance process, financial affairs, etc.),
h. for managing security operations, accidents, or other similar incidents for medical/insurance purposes;
i. for conducting market research and R&D (research and development) as well as to develop and improve our product range, services, information technology systems, and security systems;
j. for ensuring the safety of our employees working in our facilities by making use of video camera footage and to help with the prevention, identification, investigation, and prosecution of criminal offenses as well as to establish, enforce or defend our legal rights by taking the photographs into account;
k. To notify you on the information, activities, and services you may request from us;
l. in the determination and implementation of the commercial and business strategies of our Companies;
m. to ensure the implementation of human resources policies of our companies; and
n. for performing a legal obligation determined by the legislation, if it's clearly stated in the legislation or if necessary;
by our Companies and their affiliated Companies/organizations and other real and/or legal persons specified in Article (E) below, under the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law No. 6698.
C. The Method And The Legal Reason Of Collecting Personal Data
Your personal data is acquired through any verbal, written or electronic means, in order to provide our products and services of our companies in line with the purposes specified in the articles above, and to fulfill our companies' contractual and legal responsibilities in a complete and correct manner. Your personal data collected based on this legal reason is processed, recorded, transferred, shared and stored according to the terms and purposes of processing personal data as specified under Article 5 and 6 of PPD Law No 6698 and for the purposes specified under paragraph (B) of this text;

D. Processing of Data of Special Nature

Under Article 6th of the Law No. 6698, some of the personal data that are at risk of causing victimization of or discrimination against individuals are specified as “of special nature” when processed illegally. These data include information on race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, appearance and dressing, memberships of an association, foundation or trade-union, health, sexual life, criminal conviction and security measures, and biometrics and genetics; Our companies act in accordance with the regulations stipulated in Article 6 of the PPD Law in terms of processing of personal data of special nature and act with sensitivity in the protection of these data.

Our companies process sensitive personal data (data of special nature) in accordance with the PPD Law, provided that sufficient precautions to be determined by the PPD Board are taken:

a. If explicit consent of the data subject is available:
Our guests can request customized service by sharing their conditions with our Companies and share their special quality data for this purpose (when our guest requests special service by sharing their special quality data; for example, requesting a thin pillow due to neck hernia; requesting a room on the ground floor due to a heart disease; or requesting dessert without nuts due to allergies, etc.). Our Companies will only process the special quality data of our guests by obtatining their explicit consent and only for data collection purposes in order for us to able to offer them customized services and to remember these needs of our guests in the future.

b. In the absence of explicit consent of data subject;
– Except for data relating to health and sexual life of the data subject, special data may be processed as stipulated under the Law.
– Special data relevant to health and sexual life of the data subject may only be processed for purposes of protection of public health, operation of preventive medicine, medical diagnosis, treatment, and care services, planning and management of health services and financing by persons under the obligation of secrecy or authorized institutions and organizations.

E. Transfer of the Processed Personal Data:

Your collected personal data may be transferred between Yesilyurt Insaat ve Turizm San.Tic. AS and Kartepe AS  and to our shareholders, business partners, suppliers, and to legally authorized public and private entities, in accordance with the terms and purposes of personal data processing defined under Articles 8 and 9 of PPD Law No 6698.

F. Transfer of Personal Data Abroad

Our company has the authority to transfer the personal data abroad in accordance with the conditions set by the Personal Data Protection Board in the PPD Law and other conditions in the law and after obtaining the express consent of the data subject for this purpose.

G. Rights of the Data Subject listed in Article 11 of PPD Law:

We accept that the data subject has the rights, under PPD Law No 6698: to know about any transaction to be made regarding the processing and transferring of his/her personal data; to give or withhold his/her explicit consent before processing, recording, transferring, sharing and storing his/her personal data; and to determine the fate of his/her data following the processing, recording, transferring, sharing and storing the data. In this context, if you submit your requests regarding your rights as data subjects to our Companies in accordance with the methods defined in the “Clarification Text Regarding the Processing of Personal Data”, our Companies will conclude the request free of charge and as soon as possible considering the nature of the request and within 30 days at the latest.

Pursuant to the Communiqué on the Procedures and Principles of Application to the Data Controller published by the Personal Data Protection Board, regarding your requests about your rights as data subjects;

i. If your application is to be answered by writing, this will be free of charge up to ten pages. For each page subsequent to ten pages, 1 Turkish Lira may be charged as processing fee.

ii. If the answer to the application is given in a recording medium such as CD, flash memory, etc., the fee that may be charged by our Companies as data controller cannot exceed the cost of the recording medium.
In this context, personal data owners have the following rights;
a. To find out if their personal data is processed;
b. If so, to request information on such processing;
c To find out the purpose of processing personal data and whether they are used appropriately;
d. To get information on the third parties with which the personal data is shared domestically and abroad;
e. to request the correction of personal data in case of incomplete or incorrect processing, and to request that such correction to be notified to third parties to whom such data is transferred;
f. To request deletion, destruction, and/or anonymization of personal data within the framework of the conditions set forth under article 7 and to request notification of the operations made within this context to third parties to whom personal data have been transferred;
g∙ To object any negative results due to analysing the processed data exclusively through automated systems,
h. To claim damage and compensation in case of damage to personal data due to unlawful processing
. However, the data subject has no right whatsoever on the data anonymized internally in the Company. Our companies may share the personal data pursuant to a business and/or contractual relationship with the relevant agencies and bodies in order to exercise the legal powers of a judicial duty or state authority.

H. Periods of Processing Your Personal Data:

Your personal data processed pursuant to PPD Law No6698 for the purposes specified in this "Clarification Text Regarding the Processing of Personal Data" shall be deleted, destroyed, and/or anonymized and continue to be used by us when the purpose that requires the personal to be processed ceases to exist in accordance with Article 7/f.1 of PPD Law or when the periods of limitation imposed on us have expired.

İ. Situations Where Our Companies Can Process Your Personal Data Without Your Explicit Consent:
In accordance with Article 5 of the PPD Law No 6698, our Company may process your personal data mentioned above and obtained in accordance with the law without seeking your explicit consent in the following circumstances:

The circumstances stipulated in the Law;
    • In cases where you are unable to declare your consent or in cases where your consent is deemed legally invalid, in order to protect the life and physical integrity of you or of another person;
    • In cases where personal data of the parties to an agreement between you and natural and/or legal persons specified under Chapter (C) are required to be processed by our Companies and their affiliated companies, provided that such processing has to be directly related to the establishment and/or performance of such agreements;
    • If it's necessary in order for our Companies be able to perform their legal obligations;
    • If your personal data are anonymized by you;
    • If data processing is necessary to establish, enforce or protect a right;
    • If data processing is required for our companies' legitimate interests, provided that such processing shall not harm your fundamental rights and freedoms;

J. In Order To Make A Request Under the Law on Protection of Personal Data:

You may make a request about exercising your rights mentioned above pursuant to Paragraph 1 of Article 13 of PPD Law No 6698 and in accordance with the regulations set forth in the Law and related legislations as well as pursuant to the method(s) determined/to be determined by the Personal Data Protection Boards either by applying to our Companies or to the addresses specified under "Procedure Regarding Pre-Application by the Data Subject to the Data Controller pursuant to Article 11 of PDD Law No 6698" which can be found on our website by following the procedures specified in the said text.

Take care to include official documents identifying you to your application (E.g.; idedntity card, driver license, passport, etc.)
You may forward them to our Companies as Data Controller. Our companies will ensure that the request is concluded within 30 days at the latest depending on the nature of the request.

The rights related to personal data apply only to the personal data of the data subject. Requests related to the data of people other than the person who completed the form with accompanying official identification documents, will not be taken into consideration. Forms without accompanied official documents that identify your identity will not be considered. We kindly inform you that even after fulfilling the data deletion requests, we are obliged to share such data with the official authorities upon demand by the relevant authorities.

Privacy Policy

The website you are currently visiting is a property of and operated by the Company. By using our website, you agree that your personal data acquired and collected through our website may be used.

Our Companies are committed to protecting your personal privacy. This policy applies only to this website and does not apply to websites owned by third parties. If you do not agree with the terms of our current Privacy Policy announced in this section of the site related to the use of our website, we kindly request that you do not share your personal data on this site.

If you do not share your personal data with your explicit consent, we assure you that the Company will not collect and process any personal data from your visits to our site. By sharing your personal data, you authorize us to use this information in accordance with the terms of the Privacy Policy.

The personal data you may share can be used for the following purposes:
    • To send press releases or notifications via email;
    • To send printed publications and/or other communications;
    • To deliver the products you purchased or rewards you have won;
    • To process your booking requests and to manage your account;
    • To compute the statistical data on your transactions; and
    • To derive commercial statistics and analysis related to website usage.

If you choose not to share your personal data on this site, you will be unable to enjoy certain rights such as accessing certain areas of the site, requesting online newsletters, making online bookings, applying for jobs, giving feedback about our businesses or sending us e-mails.
Cookies are small data files that allow our website to collect and store a range of data found on your desktop, laptop or mobile device. The company may use such "cookies" to collect information such as private sections of the website you visit and our services you use on our website. We collect this information to improve our website, the products, etc., that you are interested in and/or you need. These "cookies" may also be used to help you perform your transactions faster when and/or if you revisit our website. For example, our website may recognize the personal data you provide to prevent its usage and to avoid the same information being asked again. Many web browsers can be preset to accept a 'cookie'. You can set your own web browser, optionally, to reject "cookies" or to be alerted when "cookies" are sent. Rejecting the 'cookies' on the site you visit may prevent you from visiting certain areas of the site or receiving the customized information when you visit the site.

By determining when you log into our website, the pages you browsed and the duration of your visit, we can assess the effectiveness of our website. Website measurement statistics can be used to personalize your website experience - anonymously and holistically - along with the creation and assessment of statistics on the use of our website.

Information about your computer, such as your IP address (the number associated with your computer when you use the Internet), the type of Web browser you are using, and the operating system you are using, may also be collected and linked to your Personal Information. This is necessary to ensure that our website provides the best experience and effective information sources for our visitors.

We take reasonable precautions to ensure the security of your personal data. All identifiable personal data is subject to limited access to prevent unauthorized access to, modification, or misuse of the data.

Institutions that provide services to companies are required to keep such information confidential and are not allowed to use this information for any purpose other than to perform the services they provide for the Companies.

Our companies reserve the right to update this 'Clarification Text on the Protection of Personal Data' within the framework of the amendments to be made to the official legislation in force.