| Title | : | SERBAN TURIZM YATIRIMLARI ANONIM SIRKETI |
| Adress | : | HUZUR MAH. MASLAK AYAZAGA CAD. B NO: 4 B SARIYER/ISTANBUL |
| Phone | : | +90 212 699 8888 |
| E-Mail Adress | : | info@hotelkomana.com |
| Registered Electronic Mail (KEP) | : |
We, Hotel Komana, have the data of the related parties subject to and in accordance with the restrictions and rules of the Personal Data Protection Law No.6698 for the purposes of providing services.
We would like to give you information for clarification on protection of privacy, fundamental rights and freedoms, especially considering the security of your personal data in accordance with the Personal Data Protection Law No.6698.
As Hotel Komana, we use utmost care and consideration to the security of your personal data. As per the legislation, all kinds of private and general personal data acquired/ collected within the scope of our service relationship by us as a data controller will be recorded, stored, updated, disclosed or transferred to third parties, as detailed below and always in accordance with the Law on the Protection of Personal Data and within and subject to the limits and restrictions prescribed by the legislation, can be classified and processed according to other procedures and principles specified in the legislation.
Our Principles regarding the processing of personal data as Hotel Komana are as follows;
a) Operate in accordance with the law and the rules of honesty,
b) Strive to provide correct and up to date,
c) Process for specific, explicit and legitimate purposes,
ç) Process in a limited and measured manner in connection with the purpose for which they are processed,
d) Keep for the period stipulated in the relevant legislation or required for the purpose for which they are
processed.
Identity and Contact Data : We may collect your personal and / or business contact information, including
the data on your identity and passport, such as your name, surname, your postal address, telephone number, fax
number, e-mail address and other similar data and identifiers.
Customer Transaction Data : We can collect your data such as call centre records, invoice, bill, check
information, order information, request information.
Financial Data : We collect information needed to process payments and prevent fraud, including bank
account numbers and other relevant billing information.
Physical Location Security Data : We may collect your data such as entrance and exit recording information,
camera records.
Transaction Security Data : If you connect to the Hotel Komana network, we may collect your data such as IP
address information, Internet site login and exit information.
Marketing Data : We may collect your data such as shopping history information, information obtained
through surveys and campaign studies. (see cookie policy)
Audio-Visual Records : We may collect your data such as audio-visual records.
Social Media Data : Data collected due to social media features that allow you to share information with
your social networks and interact with us on various social media sites.
Other Unique Identification Data : Examples of other unique identification data we collect from you include
information you provide when you interact in person with our service centres, help desk or other customer support
channels online, by phone or mail, your responses to customer surveys or to respond to your questions, and
additional information you provide to us to enhance our ability to facilitate the delivery of Hotel Komana services
provided to you.
We collect your personal data in line with the data processing conditions specified in Articles 5 and 6 of the Law
on the Protection of Personal Data, within the scope of our relationships, the legal regulations and the
continuity of our business processes, establishment of the right, protection, use, fulfilment of our contractual
obligations, carrying out operations and other purposes stated below we collect your data within it.
We process your data to provide comprehensive customer support and a seamless customer experience to you and to
personalize Hotel Komana services and communications for Customer Support and Satisfaction purposes.
We communicate to provide communication and information about Administrative Purposes and Hotel Komana services with
you; However, your data are processed for reasons such as responding to your questions or requests, communications
related to service completion or after-service support transactions and legally required communications.
Your data are processed for the following purposes : Transaction Support; completing purchases related to
our products or services; processing payments, arranging shipments and deliveries; facilitating repair and return
procedures.
Your data are processed for Security Purposes, to ensure the integrity and security of our websites, products,
services and to prevent security threats, fraudulent activities or other criminal or malicious activities that may
endanger your information. In addition, we can take additional security measures such as CCTV (Closed Circuit
Camera System) to protect our locations.
Your data are processed for the purposes of business Activities; Providing services, conducting business research
and analytics, corporate reporting and management, quality assurance practices (it may include tracking or
recording calls to our customer support services)
Your data are processed for the purposes of Research and Innovation; To develop new products, features and
services by using research and development tools and combining data analysis activities.
Marketing Purposes : Your data are processed with the aim of developing Hotel Komana services and delivering
them to you by making research and developments.
Compliance with Legislations : Your data are processed to respond to applicable laws, regulations, court
orders, government and law enforcement requests to properly operate our services and products, to protect
ourselves, our users and our customers, and to resolve any customer disputes.
In addition to the above mentioned purposes; your personal data are processed within the scope of similar
sub-purposes, provided that it is related to the purposes such as the execution of information security processes,
the execution of financial and accounting affairs, ensuring the security of data controller operations, collection
and following legal processes when necessary.
Your personal data are collected via automatic or non-automatic ways; with direct interactions by our company
from all kinds of service points; communication channels (telephone, mail, fax, social media, call centre, web,
survey, subscription etc.), automatic technologies or interactions (see Cookie Policy), third parties or public
resources (providing services and services) various third parties that assist), government agencies, our
applications and business partners from support services, closed-circuit recording systems for the above-mentioned
purposes, in accordance with the basic principles stipulated in the Law and foreseen in the laws specified in
Article 5 of the Law, the actual impossibility, the legal obligation of the data controller, the establishment and
execution of the contract, our legitimate interest as the data controller, the purpose of establishing, using and
protecting the right.
In addition, your personal data are processed by automatic or non-automatic methods for execution of the service,
availability and continuity of services related to our activities, quality and correct provision of the services
covered by the contract and measuring and increasing the service quality, providing information about services,
transmission of announcements and warnings, information research, determining and implementing our company's
strategies, customer service, planning, statistics, customer satisfaction studies, retention of information
requested by our company's public institutions, reporting, carrying out the works and transactions to be carried
out in accordance with the information obligations pursuant to Turkish Commercial Code No. 6102, Turkish Code of
Obligations No. 6098, Law No. 6563 on the Regulation of Electronic Commerce, Regulation on Commercial
Communication and Commercial Electronic Messages, Obligations in Occupational Health and Safety and Tax
Legislation and other related legislation, as long as the data processing purpose will continue to be valid.
We keep your Personal Data confidential. We do not sell, rent or exchange your Personal Data. We do not use or
share your Personal Data in ways that are unrelated to the persons we describe at the points where you provide
data or described in a valid contract, unless you have your consent.
Your collected personal data are collected as limited for the purposes specified in the Disclosure Text and
limited to the reasons that need to be transferred within the scope of the Law and the relevant legislation and
limited to these reasons;
We hire service providers or Business partners to manage or support certain aspects of the service.
Your data may be shared with parties such as organizations, security companies, logistics companies, banks,
insurance companies, consulting companies, lawyers, customer support, installation, technology services, e-mail
service providers, data hosting, debt collection service providers that provide services such as management or
support for Hotel Komana companies and Hotel Komana website in order to fulfil our contractual responsibilities, against
such organizations.
Our service providers and business partners are required to protect the personal data they receive from us in
accordance with the contract, and they are prohibited from using the personal data for any purpose other than
those specified by Hotel Komana.
We may also share your personal data, in good faith, when we believe we have an obligation, such as: respond to
fully authorized information requests from law enforcement agencies, regulators, courts and other public
authorities, including meeting national security or other law enforcement requirements, all to comply with laws,
regulations, subpoenas or orders, investigate and help prevent security threats, fraud or other criminal or
malicious activities, enforce / protect the rights and property of Hotel Komana and its affiliates, or to protect the
rights or personal safety of third parties using its property to the extent permitted by applicable law and in
accordance with the requirements of applicable law.
However, due to the transfer and storage technologies used, the data may be transferred abroad. We ensure that
your personal data will not be processed by our company for purposes other than those specified in this disclosure
document.
Pursuant to Article 5 of the Law, although explicit consent is one of the personal data processing requirements
in the law, it is not the only factor that gives legality to data processing. The law stipulates conditions for
data processing activities other than explicit consent. Accordingly, it is possible to process personal data
without seeking the explicit consent of the person concerned if one of the following conditions is met:
• the disclosure is clearly allowed/ required in the applicable laws
• It is mandatory for the protection of the life or physical integrity of the person who is unable to disclose his
consent due to actual impossibility or whose consent is not legally valid
• It is necessary to process personal data belonging to the parties of the contract, provided that it is directly
related to the establishment or performance of a contract
• It is mandatory for the data controller to fulfil his legal obligation
• It is made public by the person concerned
• Data processing is mandatory for the establishment, use or protection of a right
• If data processing is mandatory for the legitimate interests of the data controller, provided that it does not
harm the fundamental rights and freedoms of the person concerned
All necessary technical and administrative measures are taken for the security of all personal data collected by Hotel Komana. We take physical, technical, organizational and administrative measures against unauthorized access, abuse, disclosure or modification in accordance with Personal Data Security Guideline requirements published by the KVKK board, ISO / IEC 27001 Information Security, ISO / IEC 27017 Cloud Services Information Security, ISO / IEC 27701 Privacy Information Management standards, European Union General Data Protection Regulation GDPR.
Related to your personal data you are entitled to;
• learn whether your personal data are being processed
• request information about personal data if it has been processed
• learn the purpose of processing personal data and whether they are used in accordance with their purpose
• know the third parties to whom personal data are transferred domestically or abroad
• request correction of personal data in case of incomplete or incorrect processing
• request the deletion or destruction of personal data within the framework of the conditions stipulated in the
law
• request notification of the transactions made pursuant to above subparagraphs to third parties to whom personal
data have been transferred
• challenge to the occurrence of a result against the person himself by analyzing the processed data exclusively
through automated systems, and request the compensation of the damage in case of damage due to unlawful processing
of personal data
In accordance with the 1st paragraph of Article 13 of the Law on the Protection of Personal Data, you may submit
your request to exercise any of your rights stated above using the methods and information given below in
accordance with the "Communiqué numbered 30356 on Application Procedures and Principles for Data Supervisor"
published on March 10, 2018.
Information Required for Application;
• Name and Surname of the applicant
• The applicant is a citizen of the Republic of Turkey Identity Number, if not the nation with a passport number
or ID number is there
• The residence or workplace address of the applicant for notification
• Notification e-mail address, telephone or fax of the applicant
• Subject of the request of the applicant
• Information and documents based on the subject of the applicant's request
Application Methods :
• The Applicant may file the application by hand personally to our related central location of Hotel Komana by filling in the "Application Form" and writing an "Information Request Requirement of the Law on Protection
of Personal Data" in a sealed envelope.
• For applications made through a notary public to the address of Hotel Komana, the applicant must include "Request for Information as per the Law on Protection of Personal Data"
note on the notification envelope.
Your applications submitted to us will be answered upon evaluation of your right requests related to the personal
data within thirty (30) days from the date we receive your request. If your application is denied, the reasons for
the rejection are sent to the address you specified in the application via e-mail or mail.
Date of Issuance: 07.04.2018