1. PURPOSE

The purpose of this instruction is to prepare an information text regarding the personal data of the individuals defined as data subjects within the scope of the Personal Data Protection Law numbered 6698 published in the Official Gazette dated April 7, 2016, conducted at Telerko Turizm A.Ş Sueno Hotels.

2. SCOPE

This instruction is valid for the entire scope defined for the BGYS conducted at Telerko Turizm A.Ş Sueno Hotels.

3. DEFINITIONS

Organization: Telerko Turizm A.Ş. Sueno Hotels

Stakeholder: Organizations, groups, or individuals who will be directly or indirectly affected positively or negatively by the activities conducted within the scope of Telerko Turizm A.Ş Sueno Hotels.

Third Party: Legal entities and personnel that provide services to the organization through a contract.

Personnel: Personnel in the organization

Information Security: Protection of the confidentiality, integrity, and accessibility features of organizational assets

BGYS: Information Security Management System

SHBID: Sueno Hotels Information Technology Department

WEBSITES: Includes the websites within the scope of Telerko Turizm A.Ş These are sueno.com.tr; deluxe.sueno.com.tr; beach.sueno.com.tr; golf.sueno.com.tr; suenotur.com.

4. IMPLEMENTATION

The following information text will be published on the organization’s websites.

KVKK Disclosure Statement

TELERKO Turizm A.Ş. may need to collect, process, and transfer your personal data notified by you to our company in order to securely provide our valued customers with our services.

Our company takes the highest security measures possible to protect your privacy during the lawful collection, storage, processing, and, if necessary, sharing of your personal data.

The purpose of this information is to inform you in the most transparent way possible about how your personal data is collected, the purposes of processing, the legal reasons for processing, and your rights.

a) Data Controller

In accordance with the Personal Data Protection Law No. 6698 (Law No. 6698), your personal data will be collected and processed by TELERKO TURİZM A.Ş as the data controller within the scope explained below.

b) Purpose of Processing Personal Data

Your personal data will be processed within the scope of the purposes and conditions of personal data processing specified in Articles 5 and 6 of Law No. 6698, including but not limited to ensuring secure accommodation in line with our company principles, making necessary evaluations for the provided service, ensuring compliance with domestic and international legislation, fulfilling notification obligations, fulfilling legal obligations regarding information and document retention, preventing fraud, ensuring security, conducting market research and purchasing operations, managing legal processes, carrying out social responsibility projects, and providing you with uninterrupted better and reliable service, in accordance with the purposes and conditions of personal data processing specified in Articles 5 and 6 of Law No. 6698.

Your personal data may be processed for the purpose of establishing communication with you regarding any product and service specifically tailored to you, and, with your permission, for promotion, product/service offers, marketing, and campaign activities;

As well as developing suitable services and products for you, conducting customer satisfaction studies, conducting product studies by our company and its subsidiaries, and market research and determining target customer groups.

Your personal data may be processed for the purpose of fulfilling our company’s contractual and commercial obligations arising from contracts made or activities conducted with third parties, including real or legal persons, within the framework of contracts or jointly conducted activities, for the purpose of establishing communication with you, for legal and commercial assessment processes, legal and commercial risk analyses, and the execution of financial affairs.

c) Transfer of Processed Personal Data to Whom and for What Purpose

Your personal data may be transferred to business partners, shareholders, subsidiaries, affiliated group companies, and companies with which it operates as an intermediary/agency, support service providers receiving services complementary to or in extension of its activities, and other contracted organizations within the scope defined by the Personal Data Protection Law No. 6698, within the framework of the personal data processing conditions and purposes specified in Article 8 regarding the transfer of personal data and Article 9 regarding the transfer of personal data abroad.

In addition, in the event of information requests made by public institutions and organizations in accordance with the rights and authorities granted to them by law, the data obtained may be shared with such public institutions and organizations, and in the event of a dispute, it may be shared with the relevant authorities for the continuation of legal processes.

d) Which Personal Data is Collected, Method of Personal Data Collection, and Legal Basis

Your name, surname, profession, address, phone and fax numbers, email address, and other contact information.

Your family and demographic information.

Your identity and passport information.

Your travel and itinerary information.

Your accommodation and reservation details.

Your billing and payment method information.

Your voice recordings collected through our call center.

Camera/video/photograph recordings collected for security purposes.

Your health data collected to fulfill legal obligations regarding accidents.

Your product order information.

Information related to payments and refunds.

Information about your personal interests.

Information you provided to our employees within the scope of product and service requests and complaints.

Information about your use of our website, mobile applications, and other communication channels.

Email address information for sending information, advertisements, and promotional campaigns via bulk email delivery systems.

For users of our website, computer/hardware and connection information, page view statistics, traffic information about incoming and outgoing traffic, data related to ad data/advertising publications, IP addresses, and standard web log information, including other information arising from your visit to our website, your use of our services, and your interaction with our content and advertisements.

Your preferences regarding products or services or your past experiences are collected by the data controller.

These personal data collected by these methods can be processed and transferred within the scope of the purposes specified in paragraphs (b) and (c) of this Disclosure, in accordance with the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698.

e) Rights of the Personal Data Subject as per Article 11 of Law No. 6698

According to the regulation in Article 11 of Law No. 6698, you have the following rights:

To learn whether your personal data has been processed.

To request information if your personal data has been processed.

To learn the purpose of processing your personal data and whether they are used appropriately for their purpose.

To know the third parties to whom your personal data is transferred domestically or abroad.

In case your personal data are incomplete or incorrectly processed, to request their correction and to request that the transactions made in this context be notified to the third parties to whom your personal data are transferred.

If despite being processed in compliance with Law No. 6698 and other relevant legislation, the reasons requiring the processing of personal data have ceased, to request the deletion or destruction of your personal data and to request that the transactions made in this context be notified to the third parties to whom your personal data are transferred.

If you believe that a result is produced against you by exclusively analyzing your processed data through automated systems, to object to this.

In case you incur damages due to the unlawful processing of your data, you have the right to demand compensation for your damages. As per the first paragraph of Article 13 of Law No. 6698, you can submit your requests to use your aforementioned rights to our company in writing or through other methods that may be determined by the Personal Data Protection Board in the future. In this context, the channels and methods for submitting your applications to our company within the scope of Article 11 of Law No. 6698 are explained below.

To use your aforementioned rights, you can send your signed letter to our address “Telerko Turizm A.Ş. Levent Mah. Yeni Sülün Sok. No:38 Beşiktaş / İstanbul” in accordance with the KVKK Application Form Instruction available on our website or securely electronically sign and send it to “[email protected]”.

Thank you for your attention, and we would like to inform you that we will always be pleased to welcome you.