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Privacy Notice

Privacy Notice



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))

IDENTITY DATA CATEGORY

PERSONAL DATA PROCESSED

PURPOSES OF PROCESSING PERSONAL DATA

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.

 

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

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.

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.

TRANSFER OF PERSONAL DATA

 

 

 

 

 

 

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.

CONTACT DATA CATEGORY

PERSONAL DATA PROCESSED

PURPOSES OF PROCESSING PERSONAL DATA

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

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.

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.

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.

CUSTOMER TRANSACTION DATA CATEGORY

PERSONAL DATA PROCESSED

PURPOSES OF PROCESSING PERSONAL DATA

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

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.

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.

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.

FINANCE DATA CATEGORY

PERSONAL DATA PROCESSED

PURPOSES OF PROCESSING PERSONAL DATA

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

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.

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.

 

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.

PROFESSIONAL DATA CATEGORY

PERSONAL DATA PROCESSED

PURPOSES OF PROCESSING PERSONAL DATA

Occupation,

Institution and Title Information

Conducting Customer Relationship Management Processes

Conducting Customer Satisfaction Activities

Conducting Company/Product/Service Loyalty Processes

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.

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.

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.

 

PHYSICAL PREMISES SECURITY DATA CATEGORY

PERSONAL DATA PROCESSED

PURPOSES OF PROCESSING PERSONAL DATA

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,

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.

 

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.

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.

TRANSACTION SECURITY DATA CATEGORY

PERSONAL DATA PROCESSED

PURPOSES OF PROCESSING PERSONAL DATA

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,

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.

METHODS OF COLLECTING

PERSONAL DATA

The personal data specified above is collected through information systems and electronic devices.

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.

MARKETING DATA CATEGORY

PERSONAL DATA PROCESSED

PURPOSES OF PROCESSING PERSONAL DATA

Survey Information (for participants)

Past Accommodation Information

 

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

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.

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.

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.

VISUAL AND AUDIO RECORDINGS DATA CATEGORY

PERSONAL DATA PROCESSED

PURPOSES OF PROCESSING PERSONAL DATA

Closed-Circuit Camera System Footage

 

 

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

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.

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.

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 .