TIMESHARE OWNER, HOTEL GUEST AND SERVICE RECIPIENT
PRIVACY NOTICE ON PERSONAL DATA
Data Controller (KVKK Art. 10(a))
This Privacy Notice has been prepared, pursuant to Article 10 of Personal Data Protection Law No. 6698 (“KVKK” or the “Law”) and the Communiqué on the Procedures and Principles to Be Followed in Fulfilling the Obligation to Inform, by Nevresta Turizm Mimarlık İnşaat İşletmecilik Ticaret Anonim Şirketi in its capacity as Data Controller.
Table Setting Out the Personal Data Processed and the Purposes of Processing (KVKK Art. 10(b)), and the Methods of Collection and Legal Grounds for Processing of Personal Data (KVKK Art. 10(ç))
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IDENTITY DATA CATEGORY |
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PERSONAL DATA PROCESSED |
PURPOSES OF PROCESSING PERSONAL DATA |
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First Name and Last Name, Signature, Turkish Identity Number, Place and Date of Birth, Marital Status, Mother’s and Father’s Names, Gender Identity Card Serial Number, Province, District, Neighborhood and Village of Civil Registration, Volume No., Family Serial No., Serial No.
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Conducting Activities in Compliance with Legislation Conducting Finance and Accounting Affairs Conducting Company/Product/Service Loyalty Processes Ensuring the Security of Physical Premises Monitoring and Conducting Legal Affairs Conducting Internal Audit/Investigation/Intelligence Activities Conducting Communication Activities Conducting/Supervising Business Activities Conducting After-Sales Support Services for Goods/Services Conducting Sales Processes for Goods/Services Conducting Customer Relationship Management Processes Conducting Customer Satisfaction Activities Conducting Storage and Archiving Activities Conducting Contract Processes Tracking Requests/Complaints Ensuring the Security of Data Controller Operations Providing Information to Authorized Persons, Institutions and Organizations |
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LEGAL GROUNDS FOR PROCESSING PERSONAL DATA |
Your identity data is processed by Nevresta Turizm Mimarlık İnşaat İşletmecilik Ticaret Anonim Şirketi for the achievement of the purposes listed above on the basis of the following legal grounds set forth in the relevant legislation and Article 5 of the KVKK, namely: that the processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of that contract; that processing is necessary for the legitimate interests of the Data Controller, provided that it does not harm the fundamental rights and freedoms of the Data Subject; that processing is necessary for the Data Controller to comply with its legal obligations; and that processing is expressly provided for by law. |
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METHODS OF COLLECTING PERSONAL DATA |
The personal data specified in the identity data category is collected by electronic or non-electronic means through face-to-face meetings, contracts, electronic/printed forms, mobile applications, accounting software and facility management software. |
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TRANSFER OF PERSONAL DATA
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Your identity data will be transferred, in line with the achievement of the purposes set out above and in accordance with the personal data processing conditions set forth in Articles 8 and 9 of the Law, to legally authorized public institutions and organizations and legally authorized private-law persons (pursuant to Identity Notification Law No. 1774), to the suppliers with which we have a service relationship under the agreements between us, and, in the event of a legal dispute, to our attorneys with whom we have a contractual relationship. Your first name, last name and Turkish Identity Number data within the identity data category is transferred, for the purposes of conducting finance and accounting affairs and conducting activities in compliance with legislation, to the data centers of the accounting software provider we use and to our accountant/certified public accountant with whom we have a contractual relationship. As a result of the use of facility management software, your data is transferred, for the purposes of conducting business activities, conducting service processes, carrying out guest registration, tracking and appointment operations in an efficient, up-to-date and accurate manner, and conducting communication activities, to the data centers of the supplier with which we have a contractual relationship. |
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CONTACT DATA CATEGORY |
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PERSONAL DATA PROCESSED |
PURPOSES OF PROCESSING PERSONAL DATA |
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E-mail Address, Contact Address, Landline Phone Number, Mobile Phone Number |
Conducting Activities in Compliance with Legislation Conducting Finance and Accounting Affairs Conducting Company/Product/Service Loyalty Processes Monitoring and Conducting Legal Affairs Conducting Communication Activities Conducting After-Sales Support Services for Goods/Services Conducting Sales Processes for Goods/Services Conducting Customer Relationship Management Processes Conducting Customer Satisfaction Activities Conducting Storage and Archiving Activities Conducting Contract Processes Tracking Requests/Complaints Ensuring the Security of Data Controller Operations Providing Information to Authorized Persons, Institutions and Organizations |
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LEGAL GROUNDS FOR PROCESSING PERSONAL DATA |
Your contact data is processed by Nevresta Turizm Mimarlık İnşaat İşletmecilik Ticaret Anonim Şirketi for the achievement of the purposes listed above on the basis of the following legal grounds set forth in the relevant legislation and Article 5 of the KVKK, namely: that the processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of that contract; that processing is necessary for the legitimate interests of the Data Controller, provided that it does not harm the fundamental rights and freedoms of the Data Subject; that processing is necessary for the Data Controller to comply with its legal obligations; and that processing is expressly provided for by law. |
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METHODS OF COLLECTING PERSONAL DATA |
The personal data specified in the contact data category is collected by electronic or non-electronic means through face-to-face meetings, contracts, electronic/printed forms, mobile applications, accounting software and facility management software. |
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TRANSFER OF PERSONAL DATA |
Your contact data will be transferred, in line with the achievement of the purposes set out above and in accordance with the personal data processing conditions set forth in Articles 8 and 9 of the Law, to legally authorized public institutions and organizations and legally authorized private-law persons, to the suppliers with which we have a service relationship under the agreements between us, and, in the event of a legal dispute, to our attorneys with whom we have a contractual relationship. Your e-mail address and contact address data within the contact data category is transferred, for the purposes of conducting finance and accounting affairs and conducting activities in compliance with legislation, to the data centers of the accounting software provider we use and to our accountant/certified public accountant with whom we have a contractual relationship. As a result of the use of facility management software, your data is transferred, for the purposes of conducting business activities, conducting service processes, carrying out guest registration, tracking and appointment operations in an efficient, up-to-date and accurate manner, and conducting communication activities, to the data centers of the supplier with which we have a contractual relationship. |
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CUSTOMER TRANSACTION DATA CATEGORY |
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PERSONAL DATA PROCESSED |
PURPOSES OF PROCESSING PERSONAL DATA |
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Request/Complaint Information, Pre-Registration Information, Invoice Information, Accommodation Information |
Conducting Activities in Compliance with Legislation Conducting Finance and Accounting Affairs Monitoring and Conducting Legal Affairs Conducting Internal Audit/Investigation/Intelligence Activities Conducting/Supervising Business Activities Conducting After-Sales Support Services for Goods/Services Conducting Sales Processes for Goods/Services Conducting Customer Relationship Management Processes Conducting Customer Satisfaction Activities Conducting Storage and Archiving Activities Conducting Contract Processes Tracking Requests/Complaints Providing Information to Authorized Persons, Institutions and Organizations |
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LEGAL GROUNDS FOR PROCESSING PERSONAL DATA |
Your customer transaction data is processed by Nevresta Turizm Mimarlık İnşaat İşletmecilik Ticaret Anonim Şirketi for the achievement of the purposes listed above on the basis of the following legal grounds set forth in the relevant legislation and Article 5 of the KVKK, namely: that the processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of that contract; that processing is necessary for the Data Controller to comply with its legal obligations; that processing is expressly provided for by law; and that processing is necessary for the legitimate interests of the Data Controller, provided that it does not harm the fundamental rights and freedoms of the Data Subject. |
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METHODS OF COLLECTING PERSONAL DATA |
The personal data specified in the customer transaction data category is collected by electronic or non-electronic means through printed/electronic forms, face-to-face meetings, surveys, mobile applications, accounting software and facility management software. |
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TRANSFER OF PERSONAL DATA |
Your customer transaction data will be transferred, in line with the achievement of the purposes set out above and in accordance with the personal data processing conditions set forth in Articles 8 and 9 of the Law, to legally authorized public institutions and organizations and legally authorized private-law persons, to the suppliers with which we have a service relationship under the agreements between us, and, in the event of a legal dispute, to our attorneys with whom we have a contractual relationship. Your invoice information data within the customer transaction data category is transferred, for the purposes of conducting finance and accounting affairs and conducting activities in compliance with legislation, to the data centers of the accounting software provider we use and to our accountant/certified public accountant with whom we have a contractual relationship. As a result of the use of facility management software, your data is transferred, for the purposes of conducting business activities, conducting service processes, carrying out guest registration, tracking and appointment operations in an efficient, up-to-date and accurate manner, and conducting communication activities, to the data centers of the supplier with which we have a contractual relationship. |
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FINANCE DATA CATEGORY |
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PERSONAL DATA PROCESSED |
PURPOSES OF PROCESSING PERSONAL DATA |
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Bank Account Information, IBAN, Credit Card Information, Payment/Debt Information, |
Conducting Activities in Compliance with Legislation Conducting Finance and Accounting Affairs Conducting Internal Audit/Investigation/Intelligence Activities Conducting Business Continuity Activities Conducting After-Sales Support Services for Goods/Services Conducting Sales Processes for Goods/Services Conducting Customer Relationship Management Processes Conducting Contract Processes Conducting Storage and Archiving Activities Tracking Requests/Complaints Ensuring the Security of Data Controller Operations Providing Information to Authorized Persons, Institutions and Organizations |
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LEGAL GROUNDS FOR PROCESSING PERSONAL DATA |
Your finance data is processed by Nevresta Turizm Mimarlık İnşaat İşletmecilik Ticaret Anonim Şirketi for the achievement of the purposes listed above on the basis of the following legal grounds set forth in the relevant legislation and Article 5 of the KVKK, namely: that the processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of that contract; that processing is necessary for the Data Controller to comply with its legal obligations; and that processing is necessary for the legitimate interests of the Data Controller, provided that it does not harm the fundamental rights and freedoms of the Data Subject. |
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METHODS OF COLLECTING PERSONAL DATA |
The personal data specified in the finance data category is collected by electronic or non-electronic means through printed/electronic forms, contracts, face-to-face meetings, mobile applications, accounting software and facility management software.
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TRANSFER OF PERSONAL DATA |
Your finance data will be transferred, in line with the achievement of the purposes set out above and in accordance with the personal data processing conditions set forth in Articles 8 and 9 of the Law, to legally authorized public institutions and organizations and legally authorized private-law persons, to the suppliers with which we have a service relationship under the agreements between us, and, in the event of a legal dispute, to our attorneys with whom we have a contractual relationship. Your data within the finance data category is transferred, for the purposes of conducting finance and accounting affairs and conducting activities in compliance with legislation, to the data centers of the accounting software provider we use and to our accountant/certified public accountant with whom we have a contractual relationship. As a result of the use of facility management software, your data is transferred, for the purposes of conducting business activities, conducting service processes, carrying out guest registration, tracking and appointment operations in an efficient, up-to-date and accurate manner, and conducting communication activities, to the data centers of the supplier with which we have a contractual relationship. |
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PROFESSIONAL DATA CATEGORY |
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PERSONAL DATA PROCESSED |
PURPOSES OF PROCESSING PERSONAL DATA |
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Occupation, Institution and Title Information |
Conducting Customer Relationship Management Processes Conducting Customer Satisfaction Activities Conducting Company/Product/Service Loyalty Processes |
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LEGAL GROUNDS FOR PROCESSING PERSONAL DATA |
Your professional data is processed by Nevresta Turizm Mimarlık İnşaat İşletmecilik Ticaret Anonim Şirketi for the achievement of the purposes listed above on the basis of the following legal grounds set forth in the relevant legislation and Article 5 of the KVKK, namely: that processing is necessary for the legitimate interests of the Data Controller, provided that it does not harm the fundamental rights and freedoms of the Data Subject. |
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METHODS OF COLLECTING PERSONAL DATA |
The personal data specified in the professional data category is collected by electronic or non-electronic means through face-to-face meetings and facility management software. |
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TRANSFER OF PERSONAL DATA |
Your professional data will be transferred, in line with the achievement of the purposes set out above and in accordance with the personal data processing conditions set forth in Articles 8 and 9 of the Law, to legally authorized public institutions and organizations and legally authorized private-law persons, to the suppliers with which we have a service relationship under the agreements between us, and, in the event of a legal dispute, to our attorneys with whom we have a contractual relationship. As a result of the use of facility management software, your data is transferred, for the purposes of conducting business activities, conducting service processes, carrying out guest registration, tracking and appointment operations in an efficient, up-to-date and accurate manner, and conducting communication activities, to the data centers of the supplier with which we have a contractual relationship.
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PHYSICAL PREMISES SECURITY DATA CATEGORY |
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PERSONAL DATA PROCESSED |
PURPOSES OF PROCESSING PERSONAL DATA |
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Facility Entry/Exit Records CCTV Recording Data License Plate Information (for those entering with a private vehicle) |
Conducting Emergency Management Processes, Ensuring the Security of Physical Premises, Monitoring and Conducting Legal Affairs, Conducting Occupational Health/Safety Activities, Conducting Activities in Compliance with Legislation, Conducting Finance and Accounting Affairs, Ensuring the Security of Data Controller Operations, Ensuring the Security of Movable Property and Resources, |
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LEGAL GROUNDS FOR PROCESSING PERSONAL DATA |
Your physical premises security data is processed by Nevresta Turizm Mimarlık İnşaat İşletmecilik Ticaret Anonim Şirketi for the achievement of the purposes listed above on the basis of the following legal ground set forth in the relevant legislation and Article 5 of the KVKK, namely: that processing is necessary for the legitimate interests of the Data Controller, provided that it does not harm the fundamental rights and freedoms of the Data Subject.
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METHODS OF COLLECTING PERSONAL DATA |
The personal data specified above is processed through the closed-circuit camera system, lists, and monthly monitoring and referral forms. |
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TRANSFER OF PERSONAL DATA |
Your physical premises security data will be transferred, in line with the achievement of the purposes set out above and in accordance with the personal data processing conditions set forth in Articles 8 and 9 of the Law, to legally authorized public institutions and organizations and legally authorized private-law persons, to the suppliers with which we have a service relationship under the agreements between us, and, in the event of a legal dispute, to our attorneys with whom we have a contractual relationship. |
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TRANSACTION SECURITY DATA CATEGORY |
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PERSONAL DATA PROCESSED |
PURPOSES OF PROCESSING PERSONAL DATA |
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IP Address Device MAC Address Website Login/Logout Log Records Log Records of Activities Performed on the Device |
Conducting Information Security Processes, Managing Access Authorizations, Conducting Activities in Compliance with Legislation, Monitoring and Conducting Legal Affairs, Conducting Storage and Archiving Activities, Ensuring the Security of Data Controller Operations, Providing Information to Authorized Persons, Institutions and Organizations, |
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LEGAL GROUNDS FOR PROCESSING PERSONAL DATA |
Your personal data within the transaction security data category is processed by Nevresta Turizm Mimarlık İnşaat İşletmecilik Ticaret Anonim Şirketi for the achievement of the purposes listed above on the basis of the following legal grounds set forth in the relevant legislation and Article 5 of the KVKK, namely: that processing is expressly provided for by law and that processing is necessary for the Data Controller to comply with its legal obligations. |
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METHODS OF COLLECTING PERSONAL DATA |
The personal data specified above is collected through information systems and electronic devices. |
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TRANSFER OF PERSONAL DATA |
Your transaction security data will be transferred, in line with the achievement of the purposes set out above and in accordance with the personal data processing conditions set forth in Articles 8 and 9 of the Law, to legally authorized public institutions and organizations and legally authorized private-law persons, to the suppliers with which we have a service relationship under the agreements between us, and, in the event of a legal dispute, to our attorneys with whom we have a contractual relationship. |
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MARKETING DATA CATEGORY |
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PERSONAL DATA PROCESSED |
PURPOSES OF PROCESSING PERSONAL DATA |
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Survey Information (for participants) Past Accommodation Information
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Conducting Audit/Ethics Activities, Conducting Company/Product/Service Loyalty Processes, Conducting After-Sales Support Services for Goods/Services, Conducting Customer Relationship Management Processes, Conducting Customer Satisfaction Activities, Conducting Strategic Planning Activities, Tracking Requests/Complaints |
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LEGAL GROUNDS FOR PROCESSING PERSONAL DATA |
Your marketing data is processed by Nevresta Turizm Mimarlık İnşaat İşletmecilik Ticaret Anonim Şirketi for the achievement of the purposes listed above on the basis of the following legal grounds set forth in the relevant legislation and Article 5 of the KVKK, namely: that processing is necessary for the legitimate interests of the Data Controller, provided that it does not harm the fundamental rights and freedoms of the Data Subject; and that the processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of that contract. |
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METHODS OF COLLECTING PERSONAL DATA |
The personal data specified in the marketing data category is collected by electronic or non-electronic means through survey forms, electronic/printed forms, face-to-face meetings and facility management software. |
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TRANSFER OF PERSONAL DATA |
Your marketing data will be transferred, in line with the achievement of the purposes set out above and in accordance with the personal data processing conditions set forth in Articles 8 and 9 of the Law, to legally authorized public institutions and organizations and legally authorized private-law persons, to the suppliers with which we have a service relationship under the agreements between us, and, in the event of a legal dispute, to our attorneys with whom we have a contractual relationship. |
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VISUAL AND AUDIO RECORDINGS DATA CATEGORY |
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PERSONAL DATA PROCESSED |
PURPOSES OF PROCESSING PERSONAL DATA |
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Closed-Circuit Camera System Footage
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Conducting Emergency Management Processes Conducting Audit/Ethics Activities Monitoring and Conducting Legal Affairs Conducting/Supervising Business Activities Conducting Risk Management Processes Ensuring the Security of Data Controller Operations Providing Information to Authorized Persons, Institutions and Organizations |
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LEGAL GROUNDS FOR PROCESSING PERSONAL DATA |
Your visual and audio recording data is processed by Nevresta Turizm Mimarlık İnşaat İşletmecilik Ticaret Anonim Şirketi for the achievement of the purposes listed above on the basis of the following legal grounds set forth in the relevant legislation and Article 5 of the KVKK, namely: that processing is necessary for the legitimate interests of the Data Controller, provided that it does not harm the fundamental rights and freedoms of the Data Subject. |
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METHODS OF COLLECTING PERSONAL DATA |
The personal data specified in the visual and audio data category is collected by electronic means through video recording systems, video cameras and photographic devices. |
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TRANSFER OF PERSONAL DATA |
Your visual and audio recording data will be transferred, in line with the achievement of the purposes set out above and in accordance with the personal data processing conditions set forth in Articles 8 and 9 of the Law, to legally authorized public institutions and organizations and legally authorized private-law persons, to the suppliers with which we have a service relationship under the agreements between us, and, in the event of a legal dispute, to our attorneys with whom we have a contractual relationship. |
Your Rights as a Data Subject (KVKK Art. 10(d))
You may submit your requests under Article 11 of the Personal Data Protection Law, entitled “Rights of the Data Subject,” in accordance with the Communiqué on the Procedures and Principles for Applications to the Data Controller, by sending a written application to Nevresta Turizm Mimarlık İnşaat İşletmecilik Ticaret Anonim Şirketi at Mustafa Kemal Mah. Dumlupınar Bul. No: 266a İç Kapı No: 18 Çankaya/Ankara or by e-mail, solely from your e-mail address registered in our system, to bilgi@akropol.com .