Swissôtel Resort & Spa, Çeşme - Luxury hotel - PERSONAL DATA PROTECTION LAW

PERSONAL DATA PROTECTION LAW

INFORMATION CLARIFICATION NOTICE ABOUT THE PROTECTION OF PERSONAL DATA UNDER THE PERSONAL DATA PROTECTION LAW NO. 6698 (“KVKK”)

IDENTITY OF THE DATA CONTROLLER

Can Turizm Yatırımları ve İşletmeleri AŞ, in its capacity as the data controller (hereinafter referred to as the “Company”), processes your personal data within the scope of our commercial relations as described below. The personal data we process includes the following:

• Name, surname, address, email address, phone number, and other communication details,
• Financial and accounting information,
• Video and audio recordings obtained via cameras, photos, and telephone devices (If camera recordings are made, warning signs will be placed in relevant areas. If phone recordings are made, it will be notified that the voice recording is being processed).
• PURPOSES OF PROCESSING YOUR PERSONAL DATA

Your personal data may be processed by the Company for the following purposes, among others, in accordance with legal grounds:

• To communicate with you regarding activities related to our company via email, phone, etc.,
• To carry out processes related to accommodation services,
• To carry out contract processes, handle changes in contract terms, and conduct legal business and transactions with you,
• To manage financial and accounting operations such as invoicing, bank payments, account reconciliations,
• To manage the processes related to the provision/return/transportation of services and related supply chain operations,
• To tailor services offered by the Company to your preferences, usage habits, and needs,
• To inform you and enable you to benefit from campaigns, promotions, advertisements, and other advantages offered by the Company and its business partners,
• To implement necessary measures due to mandatory reasons such as contagious diseases like COVID-19,
• To prepare statistics and create relevant lists related to your transactions, to compile business statistics and analysis, and to carry out software, corporate resource planning, reporting, and marketing activities,
• To carry out business activities such as managing the company, implementing company policies,
• To ensure workplace health and safety within the scope of the activities you perform,
• To manage emergency response processes,
• To carry out necessary quality, confidentiality, and standard audits and ethical activities,
• To fulfill the obligations specified by regulations (tax regulations, debt laws, trade laws, customs regulations, occupational health and safety regulations, etc.),
• To ensure the safety of movable assets and resources at our hotel during your accommodation and other activities,
• To provide information to authorized persons, institutions, and organizations,
• To ensure the physical security of the Company’s premises through methods such as video recordings,
• To create and monitor visitor records,
• To fulfill legal obligations specified in the KVKK,
• To contact you in case of requests or complaints to our company and manage the related requests and complaints.

WHOM YOUR PERSONAL DATA MAY BE TRANSFERRED TO AND FOR WHAT PURPOSES

Your processed personal data may be shared, with limited information, with the following recipients, both within and outside of Turkey:

• Banks and payment system companies for payment services purposes,
• Occupational health and safety companies, workplace doctors, hospitals, and health institutions for the purposes of emergency medical interventions and fulfilling workplace health and safety obligations,
• Suppliers and solution partners for performing software, corporate resource planning, reporting, marketing, and other business functions,
• Audit firms and information security firms for necessary quality, confidentiality, and standard audits,
• Third parties working on behalf of the Company for processing personal data (e.g., IT support providers, customer satisfaction measurement, profiling and segmentation support, sales and marketing assistance such as SMS, mailing, archiving),
• International servers and cloud service providers located primarily in the EU, the USA, and Russia for data storage and processing,
• Audit firms, special integrator firms, independent audit firms, customs firms, tax/accounting firms, law firms for fulfilling obligations in accordance with the relevant legal provisions and for auditing business activities,
• Cargo companies for delivery purposes,
• Public institutions and organizations for fulfilling legal requirements and/or responding to official requests.

METHOD OF COLLECTION AND LEGAL BASIS FOR PERSONAL DATA

Your personal data is collected and processed in accordance with Articles 5 and 6 of the KVKK, based on legal grounds such as the Company’s obligations, legitimate interests, and to provide better and higher quality services, fulfill contractual obligations, and ensure workplace security. The data is collected and processed through verbal, written, or electronic means in accordance with the relevant legal requirements.

Your personal data is collected through the following methods:

• Information provided by you during your visit to our hotel or through phone calls,
• Through service contracts,
• Via email correspondence, mobile phone SMS and multimedia messages, cargo deliveries, information and analysis forms,
• Through social media platforms via our company’s social media accounts,
• For security purposes, via cameras installed at the workplace or visitor registration forms,
• Through legal documents and notifications received from official authorities.

RIGHT TO ACCESS AND REQUEST CORRECTION OF YOUR PERSONAL DATA

You have the right to request the following regarding your personal data by contacting us:

• To learn whether your personal data is being processed,
• To request information if your personal data has been processed,
• To learn the purpose of processing your personal data and whether it is used in accordance with that purpose,
• To know the third parties, both domestic and foreign, to whom your personal data has been transferred,
• To request correction of your personal data if it is inaccurate or incomplete,
• To request deletion or destruction of your personal data under the conditions specified in the relevant legislation,
• To request that the correction, deletion, or destruction actions be communicated to third parties to whom your data has been transferred,
• To object to a decision made solely based on automated processing, including profiling, if it negatively affects you,
• To request compensation for damages caused by the unlawful processing of your personal data.

To exercise your rights listed above, you may send your request in writing with your identity information and clarification of the specific right you want to use to the following address:
Celal Bayar Mahallesi, 51512 Sokak, No:43 Ilıca, Çeşme, İzmir or by email to cesme@swissotel.com, clearly stating that your request is related to KVKK. You can also contact us at +902327500000 during working hours (09:00-17:30) for assistance in submitting your request.

PHYSICAL VISITOR INFORMATION NOTICE REGARDING THE PROTECTION OF PERSONAL DATA UNDER LAW NO. 6698 ON THE PROTECTION OF PERSONAL DATA (“KVKK”)

IDENTITY OF THE DATA CONTROLLER

Can Turizm Yatırımları ve İşletmeleri AŞ (hereinafter referred to as the “Company”), as the data controller, processes personal data of visitors under certain circumstances when they visit our company premises. The personal data processed include:

• Identity data such as name and surname
• Turkish ID number and internet usage traffic data for internet access purposes
• Images and audio recordings obtained through cameras, photographs, and telephone devices (Warning signs are placed in areas where camera recording is conducted. Information is provided when phone calls are recorded.)

PURPOSES OF PROCESSING YOUR PERSONAL DATA

Your personal data may be processed by the Company for the following purposes, including but not limited to:

• Ensuring the continuity and supervision of quality, information security, and confidentiality policies
• Identifying and controlling entries and exits
• Ensuring physical security and confidentiality practices at the workplace
• Providing emergency medical interventions and fulfilling occupational health and safety obligations
• Complying with legal regulations and responding to requests from public institutions and organizations
• Taking necessary precautions against pandemics such as Covid-19, which may impact public health
• Fulfilling legal obligations specified in the KVKK

TO WHOM AND FOR WHAT PURPOSES YOUR PERSONAL DATA MAY BE TRANSFERRED

Your personal data, limited to necessary information, may be shared with domestic and international entities, including but not limited to:

• Audit firms, occupational physicians, public institutions, and organizations for regulatory compliance
• Servers located primarily in EU countries, the United States, and Russia, and the firms providing these server services, as well as cloud computing service providers when applicable
• Audit firms and information security firms for quality, confidentiality, and standard audits
• Public institutions and organizations when required to fulfill legal obligations or official requests

METHODS OF COLLECTING YOUR PERSONAL DATA AND LEGAL BASIS

To achieve the purposes outlined in the personal data processing section, the Company collects personal data in accordance with the conditions specified in Articles 5 and 6 of the KVKK through the following methods:

• Cameras and other similar devices installed in our hotel buildings
• Digital systems where personal data entry is required for internet access
• Visitor registration documents

RIGHT TO ACCESS AND REQUEST CORRECTION OF PERSONAL DATA

You may contact us to:

• Learn whether your personal data is being processed
• Request information if your personal data has been processed
• Learn the purpose of processing and whether data is used in accordance with that purpose
• Identify third parties to whom personal data is transferred domestically or abroad
• Request correction of incomplete or incorrect personal data
• Request deletion or destruction of personal data under the conditions specified in the applicable legislation
• Request notification of correction, deletion, or destruction processes to third parties to whom personal data has been transferred
• Object to the emergence of a result against you due to the exclusive analysis of processed data by automated systems
• Request compensation if you suffer damage due to unlawful processing of personal data

To exercise your rights, you may send a written request, clearly indicating that it pertains to KVKK, with your identification details and explanation of the right you wish to exercise, to our company address: “Celal Bayar Mahallesi, 51512 Sokak, No:43 Ilıca, Çeşme, İzmir” with a wet signature. Alternatively, you can send your signed request via email to cesme@swissotel.com, attaching the wet-signed document. If you experience difficulties reaching us, you may contact us at +902327500000 during weekdays between 09:00-17:30 for assistance in submitting your requests.