EYÜBOĞLU HOTEL PDPL PRIVACY POLICY
EYÜBOĞLU HOTEL (hereinafter referred to as "HOTEL") value the protection and processing of your personal data in accordance with the law. For this purpose, we invite you to read this Text on the processing of your personal data within the scope of the Personal Data Protection Law No. 6698 (hereinafter referred to as "PDPL").
This Privacy Policy should be interpreted together the 'Terms of Use Text', 'Cookie Policy', 'HES Code Explicit Consent Text' and 'Commercial Messages Explicit Consent Text', which you can easily access from our Website.
1. DATA CONTROLLER
As HOTEL, we inform you that we are processing your personal data as a data controller within the scope of the Personal Data Protection Law No.6698 (hereinafter referred to as " PDPL ") and other relevant legislation.
2. WHICH PERSONAL DATA DO WE PROCESS?
• Your credentials (such as name and surname, gender, nationality, Republic of Turkey identity number);
• Personal data such as name and surname in the sound recording we obtain when you communicate with our Hotel via phone;
• Your contact information (your e-mail address, residence, and telephone number);
• In transactions made with our Hotel representing legal and real persons with the title of Merchant or Tradesman, the workplace information, name-surname and contact address of the representative person;
• Your personal information such as your date of birth and nationality; if you have children or other persons coming under your supervision, their name, surname, date of birth and age;
• Card number, expiration date, customer number and security code, IBAN information regarding the credit card and debit card you share with us for payment and reservation transactions;
• Personal data regarding your interests and lifestyle (e.g. smoking/non-smoking room, activities and food&drink you prefer at our facilities, type of bedding, type of newspaper/magazine you read and sports activities.
• Visual and Audio Recordings (video recordings, photographs containing you that we collect through CCTV cameras)
• Marketing (Shopping history information, information obtained through surveys and campaigns)
• All Customer Transactions we carry out with you regarding the services we provide (invoice, promissory note, check information, mail-order details, reservation details)
• Health data that we may have to process in order to serve you better and to take care of your health (for example, blood group, past diseases, chronic diseases, allergen conditions, your HES code within the scope of COVID-19 precautions)
We remind you that the information collected about persons under the age of 18 is limited to name, nationality and date of birth and that only the adult supervising them can provide this information. (In the text, all of the above-mentioned data will be referred to as "Personal Data".)
3. FOR WHICH PURPOSES DO WE PROCESS YOUR PERSONAL DATA?
We process your personal data:
• To be able to inform you about the services we provide in our hotel, to create reservation, check-in and check-out records, to receive payments for products and services;
• To be able to provide the highest quality services we need to offer you within the scope of the Contract with our hotel;
• To be able to record your personal data on the online software systems used by our hotel to carry out sales and marketing activities,
• To be able to send you commercial electronic messages including information, approval and promotion in accordance with the rules in the Law No. 6698 on the Protection of Personal Data, the Law No.6563 on the Regulation of Electronic Commerce and the Regulation on Commercial Communication and Commercial Electronic Messages;
• To receive your opinions and suggestions about the products and services provided by our hotel and to measure customer satisfaction;
• To be able to share your identity information with law enforcement officers at your entrance to the hotel as per our legal obligation;
• Ensuring the legal, technical and commercial work security of the relevant persons in a business relationship,
• Follow-up and execution of legal affairs,
• To keep the invoices, receipts, transaction notes, order forms and all kinds of documents related to the contract between us for the periods stipulated by the law in accordance with our document storage obligations in the Turkish Commercial Code, Tax Laws and other laws;
• In order to ensure the general safety of our guests, our employees and our hotel through CCTV cameras, to prevent or detect when a crime is committed, or to resolve questions or complaints.
4. WHAT ARE THE LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA?
The HOTEL processes your personal data in accordance with Article 5 of the Personal Data Protection Law No.6698 for the following reasons:
• Obtaining your explicit consent;
• It is clearly stipulated in the laws.
• It is compulsory for the protection of the life or physical integrity of the person or another person who are unable to disclose consent due to actual impossibility or whose consent is not legally valid.
• Provided that it is directly related to the establishment or performance of a contract, it is necessary to process personal data belonging to the parties to the contract.
• As a data controller, it is mandatory for the HOTEL to fulfil its legal obligation.
• It is made public by the relevant person.
• Data processing is mandatory for the establishment, use or protection of a right.
• Provided that the fundamental rights and freedoms of the relevant person are not harmed, data processing is mandatory for the legitimate interests of the data controller, i.e. the HOTEL.
We process data related to the individuals' race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, attire and clothing, association, foundation or union membership, health, sexual life, criminal conviction and security measures as well as biometric and genetic data based on the legal grounds listed in Article 6 of the PDPL:
• If you have your express consent;
• We process your personal data of special nature other than health and sexual life only in cases stipulated by law ;
• Your personal data regarding health and sexual life can only be processed 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, for planning and managing health services and financing.
5. HOW DO WE COLLECT YOUR PERSONAL DATA?
EYÜBOĞLU HOTEL collects your personal data by verbal, written or electronic means in the following ways:
• Documents such as identity document, mail-order form, receipt, forms you fill in, consent texts and HES Code consent text that you provide us in order to benefit from the services of our hotel and to conclude the contract between us;
• Information and documents you share in e-mail, telephone, fax, short message, Whatsapp communication and postal communications with you;
• Personal data recorded during your calls to our hotel;
• When you contact us through our social media accounts such as Facebook and Instagram and share your personal information with us.
6. WHAT ARE YOUR RIGHTS UNDER THE SCOPE OF PDPL?
You can use the rights listed below and granted to you in accordance with the PDPL and other relevant legislation by contacting our Hotel:
• Learning whether your Personal Data is processed,
• If your Personal Data has been processed, requesting information regarding this,
• Learning the purpose of processing Personal Data and whether they are used appropriately for their purpose,
• To know the third parties to whom your Personal Data is transferred at home or abroad,
In order to be able to fulfil this request, the legal purpose of processing Personal Data must be no longer valid, the legal storage periods must have expired or the relevant limitation terms must have passed. Your request for deletion will not be fulfilled before these periods expire.
• Requesting correction of your Personal Data if it is incomplete or incorrectly processed,
• Requesting the deletion or destruction of your Personal Data within the framework of the conditions stipulated in the PDPL legislation,
• When you exercise your right to request the correction or deletion of your Personal Data, requesting that your request be notified to third parties to whom your Personal Data has been transferred,
• Objecting to the occurrence of a result against you by analyzing the processed data exclusively through automated systems. In the event that you suffer any damage due to unlawful processing of Personal Data, you have the right to demand the compensation of this damage.
7. THE PROCEDURE AND DURATION OF OUR COMPANY TO ANSWER THE APPLICATIONS
If the personal data owner duly submits his request to our Company, our Company will conclude the request free of charge as soon as possible and latest within thirty days depending on the nature of the request.
However, if the transaction requires an additional cost, the fee in the tariff determined by the PDP Board will be collected by our Company from the applicant.
Our company may request information from the concerned person in order to determine whether the applicant is the owner of the personal data.
8. PERSONAL DATA COLLECTED WITH OUR CLOSED CAMERA RECORDING SYSTEM AND STORAGE PERIODS
We use Closed Camera Recording System in our hotel to create the safest possible environment for our customers.
In the service area of the entrance doors, restaurant, activity halls, building exterior, visitor waiting room, parking lot, elevators and floor corridors in our hotel, images are recorded by means of security cameras and in order to ensure the security of the building, and the recording process is supervised by the security unit.
The personal data in question is automatically processed on the basis of the legal ground that "it is mandatory for the data controller to fulfil his legal obligation" and "data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data controller" in Article 5 of the Law. The personal data in question may be transferred to the judicial authorities or the relevant law enforcement officers upon request in accordance with the resolution of legal disputes or in accordance with the relevant legislation.
The data collected by the cameras in question are deleted after 10 days.
9. TRANSFER OF YOUR PERSONAL DATA TO THIRD PARTIES DOMESTIC AND ABROAD
Eyüboğlu Hotel will not transfer your Personal Data to other real or legal persons residing domestic or abroad if you do not have an explicit consent.
However, in the event of one of the following exceptional cases, your Personal Data may be transferred without your explicit consent.
• It is clearly stipulated in the laws.
• It is compulsory for the protection of the life or physical integrity of the person or another person who are unable to disclose consent due to actual impossibility or whose consent is not legally valid.
• Provided that it is directly related to the establishment or performance of a contract, it is necessary to process personal data belonging to the parties to the contract.
• As a data controller, it is mandatory for the Eyüboğlu Hotel to fulfil its legal obligation.
• It is made public by the customer.
• Data processing is mandatory for the establishment, use or protection of a right.
• Provided that the fundamental rights and freedoms of the customer are not harmed, data processing is mandatory for the legitimate interests of the Eyüboğlu Hotel.
• Provided that adequate precautions are taken, the transfer of your Personal Data about your health is necessary for the protection of public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing.
In the event of one of the exceptional cases listed above, your personal data may be transferred abroad without your explicit consent, only if there is sufficient protection in the foreign country to which the Personal Data will be transferred (the countries with sufficient protection are determined and announced by the Personal Data Protection Board), and, in the absence of sufficient protection, if the data controllers in Turkey and the relevant foreign country undertake an adequate protection in writing and if there is permission from the Personal Data Protection Board Data.
10. THIRD-PARTY WEBSITES
Our site contains links to third party websites and your data can be transferred to third parties.
This “PDPL Clarification Text” is completely separate from the privacy practices of third parties to whom information is transferred and EYÜBOĞLU HOTEL does not have any control or responsibility about the data processing policy and practices of these third parties.
These ‘PDPL Clarification Text’ do not include applications beyond its control, information collected by third party websites and/or platforms, information collected by third parties through links on the EYÜBOĞLU HOTEL website, or headlines, campaigns and other advertisements or promotions on third party websites sponsored and/or participated by the EYÜBOĞLU HOTEL. If you share personal information on third party websites and/or use/visit these sites, the privacy policy and terms of service on those sites apply.
11. ENSURING DATA SECURITY
EYÜBOĞLU HOTEL takes all kinds of technical and administrative measures to keep personal information strictly confidential, to consider it as a confidentiality obligation and to provide the necessary and reasonable protections to protect the confidentiality, security and integrity of personal data.
The Hotel undertakes to take all necessary measures and show due diligence to prevent any loss, abuse, unlawful use or alteration of your personal data and to prevent any or all of your personal information from entering the public domain or unauthorized use or disclosure to a third party.
12. HOW DO WE PROCESS YOUR PERSONAL DATA IN COMMUNICATIONS WE HAVE BY PHONE?
EYÜBOĞLU HOTEL processes your personal data including name, surname, telephone number and voice recording that you share with us during your calls in a limited manner in order to;
• be able to address you correctly,
• provide you with complete and accurate information about our services and products;
• be able to confirm the call;
• be used as evidence in possible future disputes;
• monitor service quality.
These personal data are processed automatically by telephone, depending on the legal ground in Article 5 of the Personal Data Protection Law No. 6698 that reads "data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned".
These collected data will not be shared with third parties other than judicial authorities.
13. PROTECTION OF PERSONAL DATA WE COLLECT THROUGH MAIL ORDER
Your identity information and credit card number, CVC code and information about expiration date you send to us via mail-order are collected and stored by EYÜBOĞLU HOTEL in accordance with the PDPL legislation.
In case of withdrawal of any amount other than the mail-order form approved by you for the price of the products you ordered, you can naturally object to the bank and it does not pose a risk as you can prevent the payment of this amount.
14. YOUR PERSONAL DATA PROCESSED THROUGH OUR BUSINESS PHONE AND WHATSAPP
In order to communicate with you more effectively and quickly, and provided that we obtain your express consent, we can communicate with you via Whatsapp, text message or call through our business phone, and share your reservation and payment information with you on this platform.
We recommend that you also take a look at the Whatsapp 'Privacy Policy' to learn more about how personal data that may be shared with your express consent on Whatsapp can be processed and stored.
15. HOW CAN YOU USE THE RIGHTS YOU HAVE WITHIN THE SCOPE OF PDPL?
In accordance with PDPL 13/1; the inquiries to be made to EYÜBOĞLU HOTEL, i.e. the Data Controller, regarding these rights must be submitted to us in writing or by other methods determined by the Personal Data Protection Board ("Board"). In this context, the inquiries to be made to our Company in "writing" should be conveyed to us,
• with the applicant's personal application,
• through a notary public,
• by the "secure electronic signature" of the Applicant as defined in the Electronic Signature Law No. 5070 and sending to the registered e-mail address of the Company. Our contact information to use this right is as follows.
Title: EYUBOĞLU HOTEL
Mersis No: 0384012212700011
E-mail address: mail@eyubogluhotel.com
Post address : Karanfil Sokak no: 73 Bakanlıklar Çankaya/ANKARA