OTMAN TOURISM INVESTMENT TRAVEL FOOD CONSTRUCTION AND OPERATION INDUSTRY LIMITED COMPANY

INFORMATION NOTICE REGARDING THE PROCESSING OF PERSONAL DATA

Dear Guest,

This information notice on the protection of personal data, which has been prepared in the context of the Personal Data Protection Law No. 6698 applicable throughout our company and hotel mentioned below, provides general information.

Our company and hotel are as follows: OTMAN TOURISM INVESTMENT TRAVEL FOOD CONSTRUCTION AND OPERATION INDUSTRY LIMITED COMPANY (Pearly Hotel & Spa);

From now on, our hotel and company will be referred to as "Pearly Hotel & Spa" or "Hotel".

As the Pearly Hotel & Spa family, we attach great importance to the protection of your personal data. In this context, we process your personal data as the "Data Controller" in accordance with the Personal Data Protection Law No. 6698, taking necessary administrative and technical measures in accordance with the purposes and limits specified below. Therefore, through this "Information Notice Regarding the Processing of Personal Data", we would like to inform you about our processing of personal data and your rights arising from the Personal Data Protection Law No. 6698 and GDPR regulations as our esteemed guests and visitors.

1. Personal Data We Process

We may need to request information about you and/or your family members who are customers of Pearly Hotel & Spa, including but not limited to: • Identity information (such as name, surname, ID number, passport number, etc.). • Contact information (such as phone number, email address, postal address, etc.). • Personal information (such as date of birth, nationality, etc.). • Information about your children (such as name, date of birth, age, etc.). • Your credit card number (for bank collection and reservation purposes). • Your arrival and departure dates at the hotel. • Your preferences and interests (such as smoking/non-smoking room, preferred floor, type of bedding, newspaper/magazine type, sports, cultural interests). • Your questions/comments while staying or after staying at our establishment. • Sensitive health data that we must process in order to provide better service, ensure your health, and allow you to use our sports facilities. Information collected about individuals under the age of 18 is limited to name, nationality, and date of birth, and this information can only be provided to us by an adult. (All of the data listed above will be referred to as "Personal Data" throughout the text.)

 

1. 
   Time of Obtaining Your Personal Data

Personal data may be collected in various situations, including:

1. Hotel activities:

• Room reservation.
• Check-in and payment.
• Arrival and departure dates at the hotel.
• Food and beverage consumption at the hotel bar or restaurant during a stay.
• Requests, complaints, and/or disputes.
• Reservations (for weddings, meetings, and other events).
• Recommendation and survey forms.

The processing of personal data, as defined under the Personal Data Protection Law No. 6698, refers to any operation performed on personal data, either wholly or partially by automatic means or non-automatic means that form part of any data recording system, such as obtaining, recording, storing, retaining, changing, rearranging, disclosing, transferring, taking over, making obtainable, classifying, or preventing the use of personal data.

 

Participation in Marketing Programs or Events:

• Participating in customer surveys (such as Guest Satisfaction Survey) • Subscribing to newsletters to receive offers and promotions via email.

Transmission of Information from Third Parties:

• Information transmitted to our facilities through reservations made through tour operators, travel agencies, GDS reservation systems, and others.

Internet Activities:

• Linking to Pearly Hotel & Spa websites (IP addresses, identification information) • Online forms (such as online reservations, surveys, Pearly Hotel & Spa pages on social networks, login systems via networks such as Facebook).

Method and Legal Basis for Processing Your Personal Data

 In accordance with the purposes stated in Article 3 of the Notice for the fulfillment of the requirements of the accommodation and service processes offered within our hotel facilities, and/or for the fulfillment of all obligations of the Hotel, including its legal obligations, your Personal Data can be collected and processed by the relevant departments and authorized other departments of the Hotel through the following methods and means, both automated and non-automated:

Personally, your applications may be submitted in various ways, such as by hand, through the hotel's websites, by email, by mail, through references, or through the hotel's solution partners and suppliers (such as travel agencies, tour companies, reservation sites) and/or internet sites, social media accounts. Personal data is processed based on the following legal reasons stated in Article 5 of Law No. 6698, with information obtained during interviews that can be conducted in different ways (face-to-face, telephone, teleconference, video conference, fax, etc.):

1. Your explicit consent,
2. Explicitly prescribed by the law,

 

• In case you are unable to express your consent due to actual impossibility or if your consent is not legally valid, it is mandatory for the protection of your or someone else's life or physical integrity,
  • Processing of personal data related to the establishment or performance of a contract,
  • Being mandatory for the fulfillment of our legal obligations,
  • Being made public by the relevant person himself/herself,

VII Being mandatory for the establishment, exercise or protection of a right,

 

VIII Being mandatory for our legitimate interests, provided that it does not harm your fundamental rights and freedoms and your explicit consent is obtained. Your Special Category Health Data is processed with your explicit consent or if the conditions listed in Article 6 of the Law are met. Your personal data is processed in accordance with the Identity Notification Law No. 1774, the Tax Procedure Law, the Turkish Commercial Code No. 6102, the Personal Data Protection Law No. 6698 and other relevant legal regulations. Pearly Hotel & Spa complies with data processing principles and obligations specified in relevant legal regulations such as the Turkish Constitution, international agreements that our country is a party to, EU data protection regulations (GDPR) and KVKK.

1. Processing of Your Special Category Personal Data

 Under Article 6 of the Law No. 6698 on the Protection of Personal Data, certain personal data that may cause harm or discrimination to individuals if processed unlawfully are classified as "special category" personal data. These data include race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, dress and clothing, membership in associations or unions, health, sexual life, criminal convictions and security measures-related data, as well as biometric and genetic data. Our hotel complies with the provisions stipulated in Article 6 of the Law on the Protection of Personal Data regarding the processing of special category personal data and handles them with utmost care to ensure their protection.

Pearly Hotel & Spa carefully processes your sensitive personal data in accordance with the Personal Data Protection Law with the necessary precautions to be determined by the Personal Data Protection Board. We process such data in the following cases:

 

1. In the event of your explicit consent

 you can share your specific needs with our hotel by disclosing your current conditions, and for this purpose, you can share your sensitive personal data. For example, requesting a thin pillow due to a neck hernia, requesting a ground floor room due to heart problems, requesting a nut-free dessert due to peanut allergy, requesting gluten-free meals due to gluten allergy, and providing health information to determine whether you meet the necessary health conditions to benefit from the services offered at the facility or if you have any health condition that may prevent you from using the related sports activity services, etc.

The health information obtained with your explicit consent within our hotel will only be accessible to the responsible parties within the facility, even within the organization, and it will be restricted to this extent. Our hotel will process your sensitive personal data only with your explicit consent for the purpose of providing customized services to meet your defined needs, and to remember your needs in the future and provide the same services again. Your sensitive health data and other preferences are shared in a limited manner with our personnel who will provide the service, with the aim of minimizing vital risks for our valuable guests in accordance with the services they receive. This sensitive data will never be shared with other employees within our organization or third parties. All necessary administrative and technical measures are taken to protect this sensitive data, and utmost care is taken to ensure its protection with seriousness and sensitivity.

2. In the absence of your explicit consent

only personal data of special nature, other than sensitive health data, can be processed in cases provided by the laws. Your sensitive health data is processed only by individuals or authorized institutions who are subject to confidentiality obligations for the purposes of protecting public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and their financing. Your health data can only be shared with healthcare providers in situations where your explicit consent cannot be obtained (such as in case of an accident, or when you are too ill to provide explicit consent, or in emergency medical interventions).

 

1. Purposes of Processing Your Personal Data

Your personal data is processed for the establishment of our hotel's security and for you to benefit from the services provided to our visitors and guests, the management of our hotel's access records, and for the fulfillment of our legal and regulatory obligations in accordance with the personal data processing conditions specified in Articles 5 and 6 of the Law No. 6698 and for the fulfillment of our institution's obligations determined by the laws. Below are the purposes for which we process your personal data in detail:

1. To fulfill our obligations towards our customers.
2. To manage room reservations and accommodation requests:

• To create legal documents in compliance with accounting standards, to manage and store invoicing services.

Managing your hotel stay:

• Monitoring your service usage (phone, bar, pay-per-view TV, etc.)
• Managing access to rooms.
• Internal management of lists for customers exhibiting inappropriate behavior during their stay at the hotel (aggressive and antisocial behavior, non-compliance with hotel agreements, non-compliance with security regulations, theft, damage, or payment-related incidents).
• Conducting marketing activities to promote our brands. • Adapting and improving our products and services to better meet your needs.
• Customizing commercial offers and promotional messages that we send to you. • Informing you of special offers and new services created by Pearly Hotel & Spa and its affiliates in cases where you have given your explicit consent.
• Managing our relationships with customers before, during, and after their stay. • Carrying out segmentation processes based on reservation history and customer travel preferences to send targeted communications.
• Developing statistical and commercial ratings and performing reporting. • Understanding the preferences of new or existing customers and providing personalized service.
• Sending newsletters, promotions, and tourism, hotel, or service offers to you and contacting you by phone in cases where you have given your explicit consent.
• Managing requests to unsubscribe from newsletters, promotions, tourism offers, and satisfaction surveys.
• Considering the right to object and managing objection processes.
• Utilizing special telephone services to contact individuals staying at our hotel in the event of serious incidents that affect the hotel (natural disasters, etc.).
• Conducting surveys and analyzing customer feedback.
• Managing claims/complaints.
• Securing and improving the use of our hotel's websites, particularly in the following areas:
• Enhancing navigation.
• Implementing security and fraud prevention systems.
• Fulfilling our obligations under the Identity Information Law No. 1774.
• Fulfilling obligations under other relevant legislation (such as OHS activities, Tax Procedure Law obligations, etc.).

Apart from these, the fundamental purpose of processing your personal data is to provide you with a better experience and enable you, our valued guests, to benefit more fully and uninterrupted from our services.

1. Transfer of Your Personal Data

within Turkey or Abroad In order to provide services within the hotel, your personal data may be accessed by Pearly Hotel & Spa and its affiliates and may be transferred to these companies as needed. Your personal data may be transferred and/or made accessible (within Turkey) to third parties who provide storage, archiving, IT support (such as servers, hosting, cloud computing), financial institutions with whom we collaborate and/or receive services, consultancy firms that provide support in legal and similar areas, third parties that provide support in other areas related to the Hotel's activities, our business partners and authorized institutions and organizations for designated purposes under the control of our Hotel's technical units with necessary security measures in a controlled and limited manner. During the transfer of your data within Turkey, all obligations are fulfilled by our Hotel in accordance with the Law No. 6698 on the Protection of Personal Data and related legislation. In accordance with legal obligations and if necessary, your personal data may be transferred to state institutions, judicial bodies, and foreign missions established by international agreements (embassies, consulates, etc.).

1. Processing Period of Your Personal Data

 Your personal data will be processed until the end of the period specified for the storage of these data in the relevant legislation, if such a period exists. If no such period has been determined, your personal data will be processed until the end of the period required for the purpose for which they were processed. When these periods expire, your personal data will be immediately deleted, destroyed, or anonymized in accordance with legal regulations, either ex officio or at your request. During this period, if there is any change in your personal data, you are obliged to inform Pearly Hotel & Spa or the relevant group company in order to keep your records up to date and accurate.

1. Camera Surveillance of Hotel Facilities

The entrances and exits, corridors, common areas, and exteriors of the Pearly Hotel & Spa facility are monitored by cameras for the purpose of ensuring the security of the facility, our guests, and occupational health and safety, and there are camera symbols in the designated areas. We would like to emphasize that your rights are protected by the Constitution and the Law on Protection of Personal Data with respect to these images. The purpose of camera surveillance and recording is to identify certain actions, particularly theft, that may occur in the workplace. These records can only be accessed by authorized units of the Hotel. The records are kept for 14 days for security purposes and are destroyed at the end of this period.

 

8. Your Rights as a Data Subject Under the Law on the Protection of Personal Data (Article 11)

In accordance with Article 11 of the Law on the Protection of Personal Data, you may apply to our company to exercise the following rights:

1. a) to learn whether your personal data is being processed or not,
2. b) to request information if your personal data has been processed,
3. c) to learn the purpose of processing your personal data and whether they are being used in accordance with this purpose,
4. d) to learn the third parties to whom your personal data have been transferred, whether in Turkey or abroad,
5. e) to request correction of your personal data in case they are incomplete or incorrect,
6. f) to request deletion or destruction of your personal data in accordance with the conditions set forth in the law,
7. g) to request notification of the transactions carried out in accordance with subparagraphs (e) and (f) to the third parties to whom your personal data have been transferred,
8. h) to object to the occurrence of any result against yourself through analysis of your processed data exclusively by automatic systems,
9. i) to request compensation for any damages suffered due to unlawful processing of your personal data.

You have these rights. In order to exercise these rights, you can personally deliver a signed letter containing your explanations regarding the right you request to exercise, as well as necessary identification information, to OTMAN TURIZM YATIRIM SEYAHAT GIDA İNŞAAT VE İŞLETMECİLİK SANAYİ LTD.ŞTİ. at Kuşkavağı Mahallesi Akdeniz Bulvarı Konyaaltı Antalya-TÜRKİYE, or fill out our request form in person at our company, or send it by notary public or other methods specified in the Law on the Protection of Personal Data, or send it to [email protected] with a secure electronic signature.