LPPD

INFORMATION FOR THE LAW ON THE PROTECTION OF PERSONAL DATA

INFORMATIVE NOTE ON

THE LAW ON THE PROTECTION OF PERSONAL DATA

In our capacity as a data controller, we, Bilintur Bilkent Turizm İnşaat Yatırım ve Ticaret Anonim Şirketi (the “Company”), will use your personal data in accordance with the applicable legislation by implementing the required security measures to ensure that your personal data is processed in compliance with the law and to protect your privacy. Our goal is to inform you in the most transparent manner possible about how your personal data is collected, the purposes for which it is processed, the individuals with whom it is shared, the legal grounds for which it is processed, and the rights you have in this regard, in accordance with Article 10 of the Law No. 6698 on the Protection of Personal Data.

 

1.                  General Information on the Law

 

The Law No. 6698 on the Protection of Personal Data (the “Law”) was passed on March 24, 2016, and it was published in the Official Gazette No. 29677 on April 7, 2016. The Law No. 6698 on the Protection of Personal Data was adopted in order to protect the fundamental rights and freedoms of individuals, particularly the right to privacy in one’s private life, when personal data is processed. It also serves to regulate the obligations of individuals and legal entities that process personal data, as well as the procedures and principles that must be followed.

2.                  Scope of this Informative Note

This Informative Note applies to all of our current and prospective clients, business partners, suppliers, website users, and any other third party who shares their data with our Company.

 

3.                  Purpose of, and Legal Grounds for, Processing your Personal Data

 

Managing our relationships with our suppliers and business partners: As part of our due diligence process when entering into any agreement with our business partners and suppliers, we may process certain personal data contained in their certificates of authorized signatories in order to confirm the authority of those signing on their behalf, such as any signatory’s name and surname, e-mail address, phone number, address, Turkish Citizen ID number, date of birth, and place of birth. We process such personal data on the legal basis that such processing is required for the purposes of entering into and performing agreements with third parties.

 

  1. Sale and Marketing: We may process your name and surname, e-mail address, phone number and postal address, along with the voice recordings of your conversations with our call center and your responses to polls, in order to present our advertisements and campaigns, conduct traffic measurements for sales and marketing activities, perform statistical analyses and analyze our customer portfolio, perform segmentation and profiling activities, measure and enhance customer satisfaction, obtain our customers’ opinions and recommendations on new products and services, and present customized advertisements, campaigns, advantages, and benefits to you regarding our

 

various services, such as dining, catering, events, meetings, pool, spa, and other recreational activities, provided that we get your consent as required under the E-Commerce Law. When you visit the Company’s website or use the mobile application, cookies and other similar technologies that collect and store information about you may be used to process the data you provide. You can review and modify your cookie preferences in the relevant settings. Please visit our website https://www.bilkentotel.com.tr to read our Cookie Policy.

 

  1. Complaints Handling and Call Center Services: For the purposes of handling complaints, addressing the caller correctly, providing information and support services, responding to your complaints or requests or as evidence that may be used in the event of any dispute, we may process your name, surname and email address, phone number as well as the recording of your phone conversation with the call center. However, this processing will be limited to our legitimate interests and will not have an impact on your fundamental rights and freedoms.

 

  1. Management of Reservations and Guest Relations: We may process your name and surname, e-mail address, phone number, postal address, bank account number, and Turkish citizen ID card number in order to process your reservation and manage your stay, provide various services to you such as food and beverages, events, meetings, pool and spa use, receive your orders, process your payments, issue the necessary records and documentation, and collaborate with third party logistics service providers in order to send out certain products (such as food or other products order, or complimentary daily planners and cards for our customers). The legal basis for processing your personal data for the purposes set out above is that such processing is necessary for the execution and performance of our agreement. We may also collect and store your credit card information (card number, expiration date, CVV) when you check into our Hotel, and we may use this information to secure the payment of the costs of our products and services, such as mini bar, food and beverage, pool and spa use, if you provide us with your explicit consent in advance. In the event that you give your explicit consent to the processing of your credit card information, your credit card information will be deleted immediately after you check-out of the hotel and complete your payments, and it will not be retained in any way or transferred to third parties at any time thereafter. If you do not express your explicit consent to the processing of your credit card information, you will be prompted to choose one of the following alternatives: A cash deposit in the amount established by our Company will be required from you as a guarantee, which will be held in our Company’s safe until the conclusion of your check-out. Alternatively you may allow us to empty the minibar in the room you are staying in and pay upfront in cash for any item or service offered by the Hotel.

 

  1. Ensuring Security: In order to ensure the security of the Company, prevent potential accidents, wrongful acts or offences and report them to the appropriate authorities if they cannot be prevented, we collect your voice and

 

image data by using audio video surveillance and recording devices at the Hotel’s entrance and corridors, office spaces, terrace and recreational areas, spa and pool. We process such personal data without interfering with your fundamental rights and freedoms, and on the legal basis that the processing of such data is required for the purposes of our legitimate interests as explained above.

 

  1. Performing our Duties under Law on Providing Identity Information: As required by the Law on Providing Identity Information, we collect your personal data such as your name and surname, Turkish citizen ID card number, and date and place of birth when you make a reservation, and we transmit this data to the Police Department.

 

  1. Processing of Employee Data: For more information on how we handle employee data, please see our privacy notice, which can be found at bilkentotel.com.tr.

 

  1. Information on individuals or legal entities to whom your personal data may be transferred: We may collect and transfer your personal data for the purposes described above to the third parties listed below in compliance with the requirements and purposes of processing personal data as set forth in Articles 8 and 9 of the Law No. 6698:

 

  1. The parent of our Company, i.e. Bilkent Holding A.Ş., given that it oversees and provides services to our Company, as well as any direct or indirect subsidiary of Bilkent Holding A.Ş.;

 

  1. Any person or entity as required under the Tax Procedure Code, the Law on the Court of Accounts, the Law on the Prevention of Laundering Proceeds of Crime, the law on the Prevention of Money Laundering, the Turkish Commercial Code, the Code of Obligations, the Law on Reporting Identities and other applicable laws and regulations;

 

  1. Any governmental authority or entity authorized under the applicable law, the Governor’s Office, the Ministry of Internal Affairs, the law enforcement forces, the National Police Department, the public prosecutors’ offices and other judicial authorities, and any other governmental and legal authority that may lawfully request the transfer of such data;

 

  1. Any internal or external auditors and audit firms, given that our Company is required to be audited under the Turkish Commercial Code No. 6102;

 

  1. Any individual or legal person from whom we receive product/service comparison, analysis, valuation or advertising services or any other

 

service for the purposes given above, any individual or legal person that we collaborate with or subject to the same program, or any service provide that we contract for sending out our messages to our Clients, provided that such transfer complies with the conditions of and purposes for processing personal data under Articles 8 and 9 of the Law No. 6698.

 

4.                  Methods We Use for Collecting your Personal Data

 

The Personal Data we collect about you may be obtained through our website, through the actions of our sales and marketing department personnel and other personnel who receive your reservations, through any questionnaire that you may complete during our customer visits, as a result of our digital marketing efforts, on the basis of the relevant agreements, applications and forms and offers, or through the use of cookies that our system employs to identify you when you access our website.

 

We will process your personal data on the basis of your explicit consent, where the processing of any individual piece of data necessitates your explicit approval, or on any other legal basis specified in Article 5 of the Regulation (as referred to in Section 3 above).

 

 

5.                  Data subjects’ rights under Article 11 of the Law No. 6698

 

If you, as a data subject, submit an application to exercise any of your rights via one of the methods given below, the Company will process your request as soon as possible, and at the latest within thirty days, depending on the nature of the application you submit. There will be no charge for responses that are up to ten pages in length. For each additional page exceeding 10 pages, a transaction fee of 1 Turkish Lira will be charged. Our Company may charge a fee if the response to the application is provided on a recording medium such as a CD or flash memory, but the fee will not be greater than the cost of the recording media.

 

As a data subject, you have the right to

 

  1. learn whether or not your personal data has been processed;

 

  1. request further information about the processing of your personal data, if you believe that your personal data has been processed;

 

  1. learn the purpose of the processing of your personal data, and whether or not the processing of your personal data has been carried out strictly within the limits of this purpose:

 

  1. obtain information about the identities of any local or foreign third parties to whom your personal data has been disclosed;

 

  1. request that your personal data be corrected if it has been processed incorrectly or incompletely, and that third parties to whom your personal data has been transferred be notified of the correction;

 

  1. request that your personal data be deleted or destroyed if the legal grounds previously used as a basis for processing your personal data under the Law No. 6698 or any other applicable law or regulation no longer applies, and that third parties that third parties to whom your personal data has been transferred be informed of this deletion or destruction, as the case may be;

 

  1. object to any adverse consequences of the analysis of your personal data solely through automated systems;

 

  1. compensation for any damages that may have resulted from the unlawful processing of your personal data.

 

To exercise any of your rights listed above, you should submit your application in Turkish and in written form, as required by Article 13, Paragraph 1 of the Law No. 6698 and the Communique on the Principles applicable to and the Procedures to be Followed When Submitting Applications to Data Controllers. You may deliver your application to our Company in printed form, or by sending an e-mail using your secure electronic mail address, secure electronic signature, mobile signature, or an e-mail address that you have previously provided to our Company and that has been recorded in our Company’s system. In response to applications, our Company only provides information about the applicant and does not provide information about the applicant’s family members or third parties. We reserve the right to request additional information in order to verify your identity before responding to your application.

 

The following information should be included in your application:

 

  1. your name and surname, together with your signature if your application is submitted in printed form;

 

  1. your Turkish ID Card number, if you are a Turkish citizen; or your nationality and passport number, if you are a foreign national;

 

  1. the address of your primary residence or place of business, which will be used for notification;

 

  1. your e-mail address, telephone number, and fax number, which will be used for notification; and

 

  1. the purpose of your

 

You must also include any supporting information or documentation you may have in relation to the application.

 

You may submit written applications, along with any required documentation, to info@bilkentotel.com.tr, our Company’s e-mail address as the data controller. Additionally, you may apply by completing the Data Subject Application Form, which is available at www.bilkentotel.com.tr. If you wish to use the officially registered electronic mail system, please contact bilintur@bilintur.hs03.kep.tr with your request.

 

Depending on the nature of your application, you should provide complete and accurate information and documentation to enable us to verify your identity. If you do not provide the required information and documentation, our Company may be unable to conduct the inspections on your application completely and thoroughly. Our Company reserves its legal rights in this regard. As a result, you should provide complete and accurate information and documentation, as required by the nature of your application, when submitting your application.

 

If diagnosed with COVID-19 and determined not to require hospitalization based on the examination conducted by the relevant medical institution, I agree to remain in my room with my family or any other person with whom I am sharing my room, and not to leave it.

Name and Surname:

Room Number:

Signature:

 

This procedure is followed in accordance with the requirements of the Secure Tourism Certificate issued by the Ministry of Culture and Tourism of the Republic of Turkey, as set forth in Article 3 on Emergency and Isolation in the regulation of February 8, 2022 for Covid-

19 and Hygiene Measures to be taken by Accommodation Facilities Throughout the Pandemic.