This clarification notice prepared within the scope of the protection of personal data is a general disclosure notice within the framework of the Law No. 6698 on the Protection of Personal Data, which is applied throughout our company and our hotel, whose name is provided below.
Our company and hotel:
PERA MAGNA TURIZM ISLETMELERI A.S. (RuinAdalia Hotel),
(hereinafter referred to as “RuinAdalia Hotel” or “Hotel”)
As RuinAdalia Hotel, we attach great importance to the protection of your personal data. In this context, we process your personal data as “Data Protection Officer” in accordance with the Law No. 6698 on the Protection of Personal Data (“KVKK”), within the scope of the purposes and limits set out below, and we pay utmost attention to take the necessary administrative and technical measures accordingly. For this reason, we would like to inform you about our processes of processing your personal data through this "Clarification Notice on the Processing of Personal Data" and your rights arising from the Law No. 6698 and GDPR regulation of our valued guests and visitors within the framework of the KVK Law.
- Your Personal Data Processed By Us
We will have to request information about you and/or your family members who are customers of RuinAdalia Hotel as follows:
• Identity details (e.g. name & surname, Turkish ID number, Passport Number).
• Contact details (e.g. telephone number, e-mail address, your Contact Address).
• Personal details (e.g. date of birth, nationality).
• Details about your children (e.g. name, date of birth, age).
• Your credit card number (for bank collection and booking purposes).
• Check-in and check-out dates.
• Your preferences and interests (e.g. smoking/non-smoking room, preferred floor, type of bedding, type of newspaper/magazine, sports, cultural interests)
• Your questions/comments during or after your stay in our facility.
• Special category health data that we have to process in order to provide you with better service, to protect your health and to enable you to use our sports complexes (e.g. blood type, previous illnesses, allergenic conditions, whether you have a disease that will prevent you from sports activities, etc.). Information collected about persons under 18 years of age is limited to name, nationality and date of birth and may only be provided to us by an adult. (In this notice, all of the data listed above shall be collectively referred to as “Personal Data”).
2. Time of Obtaining Your Personal Data
Personal data may be collected in various circumstances, including:
- Hotel activities;
• Booking a room.
• Arrival at the hotel and payment.
• Check-in and check-out dates.
• Eating and drinking in the hotel bar or restaurant during a stay.
• Requests, complaints and/or disputes.
• Your reservations (Weddings, Meetings and Other Organisations).
• Suggestion and questionnaire forms.
Within the framework of the Law No. 6698 on the Protection of Personal Data, the processing of personal data refers to all kinds of operations performed on personal data, such as obtaining, recording, storing, retaining, modifying, editing, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data by fully or partially automatic means or by non-automatic means provided that it is part of any data recording system.
- Participation in marketing programmes or events:
• Participation in customer surveys (e.g. Guest Satisfaction Survey)
• Subscription to newsletters to receive offers and promotions via e-mail.
- Transmission of information from third parties:
• Information transmitted to our facilities through the reservations you make through tour operators, travel agencies, GDC reservation systems and others.
- Internet activities:
• Connection to RuinAdalia Hotel websites (IP addresses, cookies)
• Online forms (online booking, surveys, login systems on social networks such as RuinAdalia Hotel, Facebook login, etc.).
Method and Legal Reason for Processing Your Personal Data
Your Personal Data may be collected and processed by the relevant departments of the Hotel and other authorised departments through automatic or non-automatic methods within the framework of the purposes specified in Article 3 of the Clarification Notice in order to fulfil the requirements of the service processes offered within the accommodation and hotel facilities in our Hotel, to carry out accommodation and other service processes and/or to fulfil all obligations, including the legal obligations of the Hotel, by the following methods and means:
• By hand for personal applications or through the websites of the Hotel, electronic mail, postal mail, references or through the solution partners and suppliers (e.g. travel agencies, tour companies, booking sites) and/or websites, social media accounts that the Hotel works with.
• Through the information obtained during interviews that can be conducted in different ways (face-to-face, telephone, teleconference, video conference, fax, etc.). Your personal data are processed for the following legal reasons set out in Article 5 of Law No. 6698;
- In the event of explicit consent given by data subject,
- In the event that processing of personal data is expressly provided for by the laws,
- In the event that processing of personal data is necessary for the protection of your life or physical integrity or of any other person, who is unable to explain his/her consent due to the physical disability or whose consent is not deemed legally valid.
- Processing of personal data, provided that it is directly related to the establishment or performance of the contract.
- In the event that processing of personal data is necessary for compliance with a legal obligation to which the data protection officer is subject.
- In the event that personal data have been made public by the data subject,
- In the event that processing of personal data is mandatory for the establishment, exercise or protection of a right,
- In the event that the processing of data is 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 are processed based on your explicit consent or in the event that the conditions listed in Article 6 of the Law are fulfilled. Your personal data are processed in accordance with the Identity Disclosure Law No. 1774, Tax Procedure Law, Turkish Commercial Code No. 6102, Personal Data Protection Law No. 6698 and other relevant legal regulations. RuinAdalia Hotel acts in accordance with the data processing principles and obligations specified in the Constitution of the Republic of Turkey, international conventions to which our country is a party, EU Data Protection Legislation (GDPR) and the relevant legal legislation, especially KVKK, in the processing of your Personal Data.
3. Processing of Your Special Category Data
In Article 6 of the Law No. 6698 on the Protection of Personal Data, some personal data that have the risk of causing victimisation or discrimination when processed unlawfully are defined as “special category data”, which include data on race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, association - foundation or trade union membership, health, sexual life, criminal conviction and security measures, and biometric and genetic data.
Our hotel acts in accordance with the regulations stipulated in Article 6 of the Personal Data Protection Law in terms of processing special category data and acts sensitively in the protection of such data.
RuinAdalia Hotel processes your sensitive personal data in accordance with the Law on the Protection of Personal Data, provided that adequate measures to be determined by the KVK Board are taken in the following cases:
1. In the event of an explicit consent given by you as data subject
You can share the conditions you are in with our Hotel, request customised service for yourself and share your special category data for this purpose. (For example, asking for a thin pillow due to neck hernia, asking for a room on the ground floor due to heart disease, asking us to prepare dessert without nuts due to peanut allergy, serving gluten-free meals due to gluten allergy, and your health information about whether you have a condition that will prevent you from benefiting from the relevant sports activity services in order to make a decision about whether you meet the health conditions required to benefit from the services offered at the facility, etc.).
Access to such health information, which is obtained with your explicit consent within our hotel, is restricted even within the facility so that only those responsible for them can see them within the facility where you receive service. In order for us to provide personalised services for your needs that you have defined by sharing your special category data and to provide the same services again by remembering your needs in the future, our Hotel will process your special category data only with your explicit consent and only to serve the purpose to collect them. Your special category health data and your special category data related to your other preferences are shared within the facility only with our personnel who will provide the service in a limited manner in order to provide in-house service and to minimise the factors that will pose a life risk to our valued guests in line with the service provided to you. Your special category data will never be shared with other employees or third parties within the facility. All necessary administrative and technical measures are taken in order to protect this special category data and care is taken to protect the data responsibly and with due diligence.
- In the event of absence of an explicit consent
Your special category personal data other than your special category health data may only be processed in cases stipulated by law. Your special category data related to your health is processed only for the purposes of protecting public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing, by persons or authorised institutions and organisations under the obligation of confidentiality. Apart from that, your special category health data may, without obtaining your explicit consent, only be shared with health institutions in cases where your explicit consent may not be obtained (if you have an accident, if you become ill to the extent that you cannot declare your explicit consent, in cases requiring emergency medical intervention).
4. Purposes of Processing Your Personal Data
In order to establish the security of our hotel and to enable our visitors and guests to benefit from the services provided by our hotel, to manage the access records of our hotel, to fulfil our obligations arising from laws and regulations, your personal data are processed for the purposes detailed below in order to fulfil the personal data processing conditions specified in Articles 5 and 6 of Law No. 6698 and the obligations of our facility stipulated by law.
1. Fulfilling of our obligations to our customers,
2. Managing room bookings and accommodation requests,
• Preparing legal documents in accordance with accounting standards, managing invoicing services and storing invoices.
Management of your hotel stay,
• Monitoring your use of services (telephone, bar, pay TV, etc.)
• Managing access to rooms,
• Internal management of lists of customers who behaved inappropriately during their stay in the hotel (aggressive and antisocial behaviour, non-compliance with the hotel contract, non-compliance with security arrangements, theft, damage or payment-related incidents),
• Carrying out marketing activities, promoting our brands,
• Adapting and improving our products and services to better meet your needs,
• Customising the commercial offers and promotional messages we send you,
• Notifying you about special offers and new services created by RuinAdalia Hotel and its affiliates in cases where we have your explicit consent,
• Managing our relationships with customers before, during and after their stay,
• Conducting segmentation based on booking history and customers' travel preferences in order to send targeted notifications,
• Developing and reporting statistics and commercial scores,
• Being aware of the preferences of new or old customers and providing personalised services,
• Sending you newsletters, promotions and tourism, hotel or service offers or contacting you by telephone in cases where we have your express consent,
• Managing requests to unsubscribe from newsletters, promotions, tourism offers and satisfaction surveys,
• Recognising the right to object and managing the objection procedures,
• Making use of special telephone services to call people staying in our Hotel in the event of serious events (natural disasters, etc.) affecting the hotel,
• Conducting surveys and analysing surveys and customer comments,
• Managing claims/complaints,
• Securing and improving your use of our Hotel's websites, especially in the following areas:
• Improving website navigation,
• Implementing security and fraud prevention systems,
• Fulfilling our obligations under the Identity Disclosure Law No. 1774.
• Fulfilling the obligations imposed by other relevant legislation (e.g. arising from OHS Activities, Tax Procedure Law etc.).
Apart from this, the main purpose of processing your personal data is to host you better and to ensure that our valued guests benefit from our services more and uninterruptedly.
5. Domestic or International Transfer of Your Personal Data
Your personal data may be accessed by RuinAdalia Hotel and its affiliates in order to provide services within the hotel, and your personal data may be transferred to these companies when necessary.
Your personal data may be transferred and/or made accessible to organisations providing storage, archiving, information technology support (such as server, hosting, cloud computing) services at home and abroad, financial institutions that provide cooperation and/or services, consultancy firms that provide support in law and similar fields, and third parties that provide support in other fields related to the activities of the Hotel, as well as our business partners and authorised institutions and organisations in a controlled and limited manner (domestically) by taking the necessary security measures under the control of the technical units of our Hotel.
During the domestic transfer of your data, all obligations are fulfilled by our Hotel within the framework of the Law No. 6698 on the Protection of Personal Data and the relevant legislation. Within the framework of legal obligations and if necessary, your Personal Data may be transferred to state institutions, judicial bodies, and foreign missions established under international agreements (embassies, consulates, etc.).
6. Retention Period of Your Personal Data
If there is a period of time stipulated in the relevant legislation for the retention of your personal data, your personal data may be retained until the end of this period, or if no such period has been determined, your personal data may be retained until the end of the period required for the purpose for which they are processed. In the event that the specified period expires, your Personal Data shall be deleted, destroyed or anonymised immediately ex officio or upon your request in accordance with the rules of the legislation. In the event that there is a change in your Personal Data within this period, you are obliged to inform RuinAdalia Hotel or our related group company in order to keep your records up-to-date and accurate.
7. Surveillance of Hotel Facilities by Camera
The entrances and exits of the RuinAdalia Hotel facility, corridors, common areas and exteriors of the facilities are monitored with cameras for the purpose of facility security, safety of our guests and occupational health and safety, and there is a camera icon in the specified areas. We would like to state that your rights are reserved in accordance with the provisions of the Constitution and KVKK regarding video recordings taken by such cameras. The purpose of surveillance with the camera is to identify certain actions that may occur in the facility, especially theft. Such recordings can only be accessed by the authorised units of the Hotel. The records are kept for 21 days for security purposes and are destroyed at the end of the period.
8. Your Rights as a Data Subject under the KVK Law (Article 11)
In accordance with the Article 11 of KVK Law, you have the right,
a) to learn whether your personal data are processed or not,
b) to demand for information as to if your personal data have been processed,
c) to learn the purpose of the processing of your personal data and whether these personal data are used in compliance with the purpose,
d) to know the third parties to whom your personal data are transferred in country or abroad,
e) to request the rectification of the incomplete or inaccurate data, if any,
f) to request the erasure or destruction of your personal data within the framework of the conditions stipulated in the relevant article of the law,
g) to request reporting of the operations carried out pursuant to sub-paragraphs (e) and (f) to third parties to whom your personal data have been transferred,
h) to object to the occurrence of a result against you by analysing the data processed solely through automated systems,
i) to claim compensation for the damage arising from the unlawful processing of your personal data.
In order to exercise your rights mentioned above, you can personally submit or send a signed letter stating your request, which includes the necessary information identifying your identity and your explanations regarding your right you request to use from the rights specified in Article 11 of the KVK Law, to the address info@ruinadalia.com.tr to the attention of PERA MAGNA TURIZM ISLETMELERI A.S.. In addition, you can also fill in a request form by applying in person within our company, you can send it through a notary public or other methods specified in the KVK Law, or you can send the relevant application to info@ruinadalia.com.tr with a secure electronic signature.