UNDER THE PERSONAL DATA PROTECTION LAW
INFORMATION TEXT ON THE PROCESSING AND PROTECTION OF PERSONAL DATA
This clarification text, in accordance with the provisions of the Personal Data Protection Law No. 6698 (hereinafter referred to as the “Law”). Pol Turizm Sağlık Sanayi Ticaret ve Anonim Şirketi – Arin Resort Bodrum, established in Turkey, will hereinafter be referred to as the “Company”. Data controller; Pol Turizm Sağlık Sanayi Ticaret ve Anonim Şirketi – is the person authorized by Arin Resort Bodrum during the acquisition of the specified personal data for the purpose of clarifying the procedures and principles regarding the processing of personal data of our guests. We process your personal data as defined in the Law, limited to the purposes and conditions within the personal data processing conditions specified in the 2nd paragraph of Article 5 and the 4th paragraph of Article 6 of the Law.
According to this;
If expressly ordered by law during the continuation of the service offered to you by our company,
The processing of your personal data by our company is directly related to and necessary for the establishment or performance of a contract,
Processing of your personal data is mandatory for our company to fulfill its legal obligation,
Provided that your personal data has been made public by you; Processing of you by our company in a limited way for publicization purposes,
Processing of your personal data by our company is mandatory for the establishment, use or protection of the rights of our company, you or third parties,
It is mandatory to process personal data for the legitimate interests of our company, provided that it does not harm your fundamental rights and freedoms,
It is mandatory for our company to process personal data to protect the life or physical integrity of the personal data owner or someone else, and in this case, the personal data owner is unable to express his/her consent due to actual or legal invalidity,
It is prescribed by law in terms of special categories of personal data other than the health and sexual life of the personal data owner,
In such cases, our company processes your personal data.
In this context, our company processes your personal data for the following purposes:
Planning and execution of corporate sustainability activities
event management
Guest/customer relationship management
Management of relationships with business partners or suppliers
Execution/monitoring of company financial reporting and risk management transactions
Execution/follow-up of company legal affairs
Planning and execution of corporate communication activities
Execution of corporate governance activities
Request and complaint management
Ensuring the security of community values
Carrying out work to protect the company’s reputation
Managing investor relations
Providing information regarding legislation to authorized institutions
Your personal data may be processed to create and track visitor records.
Your personal data,
Within the scope of our commercial relations or our business relationship with you;
Within the framework of the purpose that requires processing and in connection with this purpose, in a limited and measured manner,
By maintaining the accuracy and most up-to-date version of personal data as you provide or have been notified to us,
It will be recorded, stored, maintained, rearranged, shared with institutions authorized to request this personal data by law, and transferred to domestic or international ([1]) third parties, under the conditions stipulated by the KVKK, transferred, classified and in other ways listed in the KVKK. We inform you that it can be processed.
The company attaches special importance to the security of personal data and takes all necessary technical and administrative measures. Following the end of the service, your identity data and contact data detailed under the heading of processed data below will be retained for 10 years, your special personal data ([2]) in accordance with the limitations of the law, your visual and audio personal data and your family and relative personal data will be retained for 2 years. It will be preserved by taking all necessary technical and administrative measures.
Although your personal data may vary depending on the service provided by the company and the company’s commercial activities; It can be collected verbally, in writing or electronically, by automatic or non-automatic methods, through company units and offices, group companies, websites, social media channels, mobile applications, agencies and similar means. Your personal data may be processed by creating and updating as long as you benefit from the products and services offered by our company and group companies.
In addition, your personal data may be processed when you use our call centers or our website to use company services, when you visit the Company or our website, when you request to receive Company service through agencies, when you participate in training, seminars or organizations organized by the company.
YOUR PROCESSED PERSONAL DATA
Identity Data: Name, surname, date of birth, nationality, place of birth, gender, marital status, TR ID card information (TR ID number, serial number, wallet number, father’s name, mother’s name, place of birth, province, district, neighborhood, volume number, family sequence number, serial number, household number, page number, registration number, place of issue, reason for issue, date of issue, previous surname), copy of identity card, Passport number
Contact Data: Telephone number, Zip code, full address information, e-mail address, corporate e-mail address
Special Personal Data: Health data, Food allergy, Disease monitoring date information, Disease symptoms information, Disease Monitoring rates information, ([3])
Visual and Audio Data: Photographs, audio recordings, camera recordings of real persons (video footage such as birthday celebrations, etc.)
Family and Relative Data: Name, surname, TR ID of spouse and children. Identity Number, passport number, date of birth, telephone number, name, surname and e-mail address of relatives who can be reached in case of emergency
Transaction Security Data: IP address information, website entry and exit information
Marketing Data: Behavioral and transactional information obtained through surveys, campaigns and tracking technologies
Other: Vehicle license plate, VIP service and arrival and departure times, VIP service stop data, internet access logs, entry and exit logs, Guest Product acceptance information, Guest arrival and departure dates, agency/company information, profession.
TO WHOM AND FOR WHAT PURPOSE PROCESSED PERSONAL DATA CAN BE TRANSFERRED?
Your collected personal data may be transferred to our business partners, suppliers, our company’s officials and shareholders, legally authorized public institutions and private individuals within the scope of our legitimate interest within the framework of achieving the above-mentioned purposes, and to our business partners for the purpose of providing personal advertising services if you give explicit consent; It can be transferred to legally authorized public institutions and legally authorized private persons within the scope of the data processing conditions set out in Article 5 of the KVKK, in accordance with the rules regarding the transfer of personal data specified in Article 8 of the KVKK, within the scope of being clearly stipulated in the law and fulfilling our legal obligations. Your personal data collected in this context; Carrying out the necessary work by our business units to benefit you from the products and services offered by our company, recommending the products and services offered by our company by customizing them according to your tastes, usage habits and needs, ensuring the legal and commercial security of the people who are in business relations with our company and our company group (company administrative operations for communication carried out by our company, ensuring the physical security and control of our company’s locations, business partner / customer / supplier (officials or employees) evaluation processes, reputation research processes, legal compliance process, audit, financial affairs, etc.), our company’s commercial and business It can be transferred within the framework of the conditions specified in the disclosure text, for the purposes of determining and implementing strategies and ensuring the execution of our Company’s guest services policies.
Definition of Persons to whom Data Can Be Transferred Purpose of Data Transfer
Business Partner (agency, customer, etc.) defines the parties with whom the company establishes a business partnership for purposes such as receiving or selling services while carrying out its commercial activities. Limited to ensuring that the purposes of establishing the business partnership are fulfilled and to evaluate the authorized person or employee.
Supplier defines the parties that provide products/services to the company on a contractual basis in accordance with the company’s orders and instructions while carrying out the Company’s commercial activities. Limited to ensuring that the products and services that the company outsources from the supplier and necessary to carry out the company’s commercial activities are provided to the company.
Company Officials Members of the company’s board of directors and other authorized natural persons Ensuring the physical security and control of the company’s locations, Designing strategies regarding the commercial activities of the company in accordance with the provisions of the relevant legislation, ensuring management at the highest level, financial affairs, etc. limited to the purposes
Legally Authorized Public Institutions and Organizations Public institutions and organizations authorized to receive information and documents from the company in accordance with the provisions of the relevant legislation. Limited to the purpose requested by the relevant public institutions and organizations within their legal authority.
METHOD AND LEGAL REASON FOR COLLECTING PERSONAL DATA
Your personal data may be disclosed to you in any verbal, written or electronic environment, in line with the purposes stated above.
and services are provided within the specified legal framework and in this context, our company can fulfill its contractual and legal responsibilities completely and accurately. For these legal reasons, your personal data is collected using manual or electronic media, within the scope of the personal data processing conditions and purposes stated in this disclosure document.
According to Article 11 of the Law, you have the following rights:
Learning whether personal data is processed or not,
Requesting information if personal data has been processed,
Learning the purpose of personal data and whether they are used for their intended purpose,
Knowing the third parties to whom personal data is transferred at home or abroad ([4]),
Requesting correction of personal data if they are incomplete or incorrectly processed,
Requesting the deletion or destruction of personal data, (Request a form from the Human Resources Department for your request.)
Requesting that the transactions carried out in accordance with paragraphs (d) and (e) be notified to third parties to whom personal data is transferred,
Objecting to the emergence of a result that is unfavorable to the person by analyzing the processed data only through automatic systems,
Requesting the compensation of the damage in case of damage due to personal data being processed contrary to the Law,
Regarding the expenses to be incurred by the Company to ensure the fulfillment of the requests, the Company reserves the right to request these expenses from the requesting Personal Data Owner within the scope of the tariff specified in Article 13(**) of the KVKK titled “Application to the Data Controller”. Since the Personal Data Protection Board has not determined any method at this stage, you must submit your application to the Company in writing, in accordance with the KVKK. In this context, the channels and procedures through which you can submit your application in writing to the Company within the scope of Article 11 of the KVKK are explained below:
In order to exercise your above-mentioned rights, you can hand-deliver your wet-signed petition, which includes the necessary information that identifies you and your explanations about your right that you request to exercise from the rights specified in Article 11 of the KVKK, to the address of the data controller specified above, with identification documents, or through a notary or through a notary public. You can send it via other methods specified in KVKK or send the relevant form to [email protected] within the scope of ‘secure electronic signature’.
(*) Data Controller:
In order to continue the activities of the Company, your personal data is processed by the Company as “Data Controller” within the framework explained by the law; will be able to obtain, record, store, preserve, update, change, rearrange for the purpose of continuing services and activities, disclose to third parties in cases and to the extent permitted by the legislation, transfer, transfer, share, classify, anonymize and process in other ways listed in the law. What should be understood from the concept of data controller is; It is the natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system.
Data controller: Pol Tourism Health Industry Trade and Joint Stock Company-Arin Resort Bodrum
Trade Registry Number: 018277
Mersis Number: 0730074777300002
Email : [email protected]
Address: Turgutreis, Bahçelievler Mah, Şehit Kenan Aybey Caddesi No: 123, 48960 Bodrum/Muğla
Conditions for processing personal data ARTICLE 5
(1) Personal data cannot be processed without the explicit consent of the relevant person. (2) It is possible to process personal data without the express consent of the relevant person if one of the following conditions exists: a) It is clearly provided for by law. b) It is necessary for the protection of the life or physical integrity of the person or someone else who is unable to express his/her consent due to actual impossibility or whose consent is not given legal validity. c) It is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract. ç) It is mandatory for the data controller to fulfill its legal obligation. d) It has been made public by the person concerned. e) Data processing is mandatory for the establishment, exercise or protection of a right. f) It is necessary to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.
(**) Application to the data controller ARTICLE 13
(1) The relevant person submits his/her requests regarding the implementation of this Law to the data controller in writing or by other methods determined by the Board. (2) The data controller finalizes the requests in the application free of charge as soon as possible and within thirty days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost, the fee in the tariff determined by the Board
a fee may apply. (3) The data controller accepts the request or rejects it by explaining the reason and notifies the relevant person in writing or electronically of his/her response. If the request in the application is accepted, the necessary action will be taken by the data controller. If the application is due to the error of the data controller, the fee collected will be refunded to the relevant party.
([1]) Within the scope of the amendment to the law no. 7499 published in the Official Gazette no. 32487 dated 12.03.2024, Article 9 of the law no. 6698 is applied regarding the transfer of personal data abroad. In this context, personal data may be transferred abroad by data controllers and data processors if one of the conditions specified in Articles 5 and 6 is met and there is an adequacy decision regarding the country to be transferred, sectors within the country or international organizations.
([2]) Within the scope of the amendment to the law no. 7499 published in the Official Gazette no. 32487 dated 12.03.2024, in accordance with Article 3 of the law no. 6698; (3) Processing of sensitive personal data is prohibited. However, processing of this data;
a) The express consent of the person concerned, b) It is clearly foreseen by law, c) It is necessary for the protection of the life or physical integrity of the person who is unable to express his consent due to actual impossibility or whose consent is not given legal validity, d) Personal information made public by the person concerned. It is related to data and is in accordance with the will to be made public, d) It is mandatory for the establishment, use or protection of a right, e) The protection of public health, preventive medicine, medical diagnosis, treatment and care services are carried out by persons under the obligation of confidentiality or by authorized institutions and organizations. and is necessary for the purposes of planning, management and financing of health services, f) It is mandatory for the fulfillment of legal obligations in the fields of employment, occupational health and safety, social security, social services and social assistance, g) Foundation established for political, philosophical, religious or union purposes. , associations and other non-profit organizations or formations, provided that they are in accordance with the legislation they are subject to and their purposes, are limited to their fields of activity and are not disclosed to third parties; It is possible if it is directed to current or former members and members or people who are in regular contact with these organizations and formations.
([3]) Within the scope of footnote no. 2 above
([4]) Within the scope of footnote no. 1 above
