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POLICY ON PROTECTION OF PERSONAL DATA & PRIVACY POLICY

As Yeşilyurt İnşaat ve Turizm San. Ticaret A.Ş / Kartepe Turizm A.Ş (“Company”), with this 'policy' text prepared by us as the Data Controller pursuant to  Law No. 6698 on the Protection of Personal Data (“KVKK/PDD Law”) and associated legislation under this law, and within the contexts of Article 10 'Clarification Obligation of the Data Controller' and of Article 11 ' The Rights of the Related Person (Data Subject)', we intend to inform you about the purposes for which your personal data stored physically and electronically (e.g; computers, CDs, flash discs, etc.) at our Company will be processed; to whom and and for what purposes the processed personel data will be transferred; the method and the legal reason of collecting your personal data; and on your other rights listed under Article 11 of PDD Law.

As a Data Controller, your personal data are processed, saved, transferred, shared, and stored by us as described below and within the limits instructed by the related legislation.

Our Company reserves the right to update the 'Clarification Text on the Protection of Personal Data', the 'Policy on Protection and Processing of Personal Data and The Privacy Policy', the 'Declaration of Explicit Consent', and the 'Policy on the Storage and Disposal of Personal Data' according to amendments to be made to official legislation in force.

1. COLLECTION, PROCESSING AND PROCESSING PURPOSES OF PERSONAL DATA

Our company, which operates in the commercial areas specified in the Company's Articles of Association, collects and processes verbal, written or electronic personal data for the purposes of the agreements we have entered into, particularly due to regulations of the administrative bodies and other relevant autorities that govern the tourism industry. These personal data will be used to provide information related to our company's activities and to improve the quality of these services, to carry out our company's sales, marketing and other commercial activities, and in order to meet its information retention, reporting, statistics, and informing obligations. In addition, personal data can be used within the scope of works such as increasing the quality of our service we offer to you, as well as internal and external practices for Customer Relationship Management for sales and marketing activities.

Personal data will not be used for purposes other than those stated above without your explicit consent and will not be shared or transferred to third parties, except to public bodies/organizations for legal requirements and obligations.

Our Company may only share your personal data with our affiliates, subsidiaries, joint ventures, at home and abroad,  and/or public agencies and organizations authrorized by law to demand such data based on your explicit consent and in accordance with the applicable legislation in the circumstances set forth under Article 5/f-2 as well as with other organizations, suppliers, authorized dealers/vendors/business partners, at home and abroad, that we have contracted for the purposes of our business operations in order to provide you, our customers, with higher-quality services, opportunities and facilities, provided that sufficient protection measures are taken.

Your personal data may varies depending on the services, products offered and/or commercial activities performed by our Company, 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 company, your personal data can be processed by creating and updating them.

Also, your personal data may be processes when:

    • you call our call centre or use our website;
    • you visit our Company, our website and/or our social media channels; and
   • you participate in training courses, seminars, and events held by our Company or at the facilities of our Company. 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 company; (b) to recommend such products and services offered by our company that are customized according to your likes, usage habits, and needs; (c) for ensuring the legal and commercial security of our Company and of legal and natural persons who have a business relationship with our company (administrative operations for communication carried out by our company), ensuring the security and control of the physical areas of the company, business partners/customers/suppliers (their authorized persons or employees) assessment processes, legal compliance process, financial affairs, etc.), (d) to enhance the quality of the services offered by our Company and to improve our quality policy; (e) to inform you about and allow you to benefit from the general and special commercial and customer-oriented campaigns, promotions, discounts and similar advantages offered by our Company; (f) in order to provide you with the information and services as per your request; to process your personal data obtained when you log in to the relevant channels with user name and password or without using your username to receive services from the channels offered by our Companies as well as the data about your preferences, transactions, and browsing time registered in these channels; (g) to notify you about membership transactions to our Company as well as its 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; (h) to notify you on the information, activities, and services you may request from our Company; in the determination and implementation of the commercial and business strategies of our Company; (j) to ensure the implementation of our policies on HR, CRM, and sales;  (k) 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.

 
2. 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 offer our products and services of our company in line with the purposes specified under the heading above, and to perform our company's 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 in accordance with the terms and purposes of processing personal data as specified under Article 5 and 6 of PPD Law and for the purposes specified under the heading no 1 of this text;
 
3. PROCESSING OF DATA OF SPECIAL NATURE

According to the PPD Law No 6698, the data regarding the individuals'  race, ethnic origin, political opinions, philosophical beliefs, religions, sect or other beliefs, appearance and dressing, memberships of an association, foundation or trade-union, health, sexual life, criminal convictions and security measures, and biometrics and genetics information are personal data of special nature. Our company takes adequate measures determined by the Personal Data Protection Board in the processing of special quality personal data. In order to provide better service, our company will only process the special quality data of the persons by obtaining the consent of the data subject and only for the purpose of collection and for the cases required by law.
 
4. TRANSFER OF THE PROCESSED PERSONAL DATA:

Your personal data collected can be transferred to Yeşilyurt İnşaat ve Turizm San. Ve Tic. A.Ş./Kartepe Turizm A.Ş as well as to our shareholders, business partners, suppliers, organizations with whom we establish legal relations for commercial or other reasons, legally authorized public bodies and private persons in accordance with the terms and purposes defined under Article 8 and 9 of PPD Law, for the purposes described under the heading (B).
 
5. TRANSFER OF PERSONAL INFORMATION TO ABROAD

Our company has the authority to transfer the personal data to 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 explicit consent of the data subject for this purpose.
 
6. 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 for creating commercially critical statistical reporting and analyses when the purpose that requires the personal data 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.


7. CIRCUMSTANCES IN WHICH OUR COMPANY MAY PROCESS YOUR PERSONAL DATA AS REQUIRED BY LAW 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:

In cases clearly stipulated in the aforementioned law and other laws;

    • Processing of the personal data is deemed necessary to protect the life and physical integrity of the data subjects and others in cases in which the data subject is unable to give his/her consent due to actual impossibilities or where his/her consent is deemed legally unadmissable or invalid.
    • 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 Company and its 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 Company be able to perform its legal obligations;
    • If your personal data are anonymized by you through social media or by other physical means.
    • If data processing is necessary to establish, enforce or protect a right;
    • If data processing is required for our company's legitimate interests, provided that such processing shall not harm your fundamental rights and freedoms;

8. RIGHTS OF THE DATA SUBJECT LISTED IN ARTICLE 11 OF PPD LAW:

We accept that the data subject has the rights, under PPD Law: 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, your rights listed under Article 11 of PPD law No 6698 are as follows:

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;
ç) To get information on the third parties with which the personal data is shared domestically and abroad;
d) To request correction of personal data if they are incomplete or incorrectly processed;
e) To request deletion or destruction of personal data within the framework of the conditions set forth under article 7 of the said law;
f) to request notification of the operations made as per indents (d) and (e) 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;
ğ)To claim damage and compensation in case of damage to personal data due to unlawful processing;

 If you submit your requests regarding your rights as data subjects to our Company in accordance with the methods defined in the “Clarification Text Regarding the Processing of Personal Data”, our Company will conclude the request free of charge and within 30 days at the latest, considering the nature of the request.

    a) In accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller published by the Personal Data Protection Board, you can create your application containing your requests regarding your rights as data subject by following the instructions given on the page titled 'Procedure for the Application to the Data Controller under PPD Law No 6698'.