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İSTANBUL TURİZM VE OTELCİLİK ANONİM ŞİRKETİ PROCESSING OF PERSONAL DATA CLARIFICATION TEXT

Our company ISTANBUL TURIZM VE OTELCILIK A.S. which is the operator of The Marmara Hotels and The Marmara Esma Sultan Mansion, places utmost importance on ensuring the security of your personal data that you provide to us using our web site or via other means. "Law on the Protection of Personal Data" with No. 6698 has entered into force. We would like to inform you about the aforementioned regulation and definitions specified in this regulation:

Personal data : All kinds of information about a specific identified or identifiable natural person, 
The processing of personal data: Provided that the personal data is fully or partially automated or as a part of any data record system; any operation that is performed on the data such as obtaining with non-automatic ways, recording, storage, preservation, modification, rearrangement, disclosure, transfer, acquisition, attainability, classification or prevention of its use,
Data processor: The natural or legal person, who processes personal data on behalf of the data responsible with the authority given by him/her,
Data recording system: Recording system where the personal data is processed being configured according to specific criteria,
Data responsible: Any natural or legal person who is responsible for the establishment and management of the data recording system, determination of the purposes and means of processing of personal data. Acts as our company's data responsible under the law. 
With the data responsible title, our company and our branches, call center, affiliated companies, our group companies in the name of our company or through, being including following and not being limited to, our social media pages and our websites by travel agents that we work with, or through any channel, your personal and/or private data may be, completely or partly, achieved, saved, stored, modified, updated periodically, checked, re-edited, categorized, required or maintained for the purpose they are processed until the date required or defined in the applicable law, in cases of actual legal or service-related requirements, may be shared with public institutions and organizations, 3rd party real person/legal entity, service provider and supplier firms, insurance companies working with our company located in Turkey or abroad and/or our company's sub-agencies, may be prevented from being transferred abroad or its usage in cases of actual legal or service-related requirements.

Data Responsible and Representative

Your personal data, in accordance with Law No. 6698 on Protection of Personal Data ("Law No. 6698"); ISTANBUL TURİZM VE OTELCİLİK A.Ş. will be able to process the data as explained below.

The Purpose of Personal Data to be Processed

Your collected personal data (name, surname, birth date, mobile telephone number, e-mail, gender, address, job, education, marital status, car license plate data, identity datas, accommodation and expense  datas, vessel/transportation/journey datas, insurance datas, social media accounts, shopping datas, invoice datas, consumption preferences etc.) will be processed by our business units in order to contact you about the contract terms, current situations and updates which you draw up with our company, to give you the necessary information, to navigate and inform you to the campaigns regarding our products and services which you our Customers might be interested in, to increase the Customer satisfaction, to use it in various marketing and advertisement activities, to inform our customers about our services, to evaluate the customer complaint and recommendations, to fulfill our legal liabilities and use our right deriving from the regulation on force, to benefit you from the products and services, to meet the customer needs, to ensure our company’s performing of human resources policies; to ensure the legal and commercial security of our company, in accordance with the personal data processing requirements and purposes stated in Articles 5 and 6 of Law No. 6698 for the purpose of determining and implementing business and business strategies of our Company.

Your personal data will not be used apart from the aforementioned purposes without your explicit consent, will not be shared with or transfered to the third persons except legal liabilities and official institution/organizations.

To whom and how the processed personal data can be transferred

Your collected personal data will be processed by our business units to benefit you from the products and services offered by our Company, the products and services offered by our Company will be recommended to you by customizing them according to your taste, usage habits and needs, the basis of our company's human resources policies, business partners(people and organizations that offer services including and not limited to accommodation companies, airline companies,  land and sea transportation companies, car rental companies, insurance companies, the transfer crews), suppliers, shareholders, affiliates, legally authorized public institutions and private persons in accordance with Article 8 and 9 of the Law No. 6698, for the purpose of determining and implementing the commercial and business strategies of our Company, it may be transferred within the framework of the stated personal data processing requirements and purposes.

Method and Legal Reason of Collecting Personal Data

Your personal data are collected in written ,verbal or electronic environment by our Company with automatically  or non-automatically  methods and with different channels (through our company/our branches/the tourism agencies we work with, our call center/partner or suppliers and all kinds of channels not being limited with them) and different legal grounds to improve the products and services we offer and to carry out our business activities. Your personal data collected pursuant to this law may also be processed and transmitted to the purposes set forth in items (b) and (c) of this Clarification Document within the scope of the personal data processing requirements and purposes set forth in Articles 5 and 6 of Law No. 6698.

Processing Time of Your Personal Data

In accordance with the Privacy Act, when the purpose of processing disappears as per the Privacy Act article 7 / clause 1 and/or the due date of our data process expires regarding the regulation, your persoal data processed with the purposes included in hereby "Clarification Document on Processing Personal Data" will be erased, destroyed or kept on being used anonymized.

Processing the Special Quality Data 

Data relating to race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, appearance and dressing, membership of association, foundation or trade-union, health, sexual life, criminal conviction and security measures, and biometrics and genetics are special categories  in accordance with Law No. 6698 on Protection of Personal Data.
Our company takes sufficient stipulated precautions in accordance with Board of Processing the Personal Data while processing your special quality data. Our company will only process your data after getting the approval of relevant parties and only to be able to provide better services. Conditions for Processing of Personal Data without obtaining explicit consent.

Personal data may be processed without obtaining the explicit consent of the data subject if one of the below conditions exists:

a) It is expressly permitted by any law;
b) It is necessary in order to protect the life or physical integrity of the data subject or another person where the data subject is physically or legally incapable of giving consent;
c) It is necessary to process the personal data of parties of a contract, provided that the processing is directly related to the execution or performance of the contract;
ç) It is necessary for compliance with a legal obligation which the controller is subject to;
d) The relevant information is revealed to the public by the data subject herself/himself;
e) It is necessary for the institution, usage, or protection of a right;
f) It is necessary for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed.

The Rights of the Personal Data Holder in accordance with Article 11 of Law No. 6698

OAs personal data owners, if we inform you of your requests regarding your rights as described below, our Company will conclude the request as soon as possible and within thirty days at the latest, free of charge. However, if the transaction also requires a cost, our company will charge the fee at the rate specified by the Personal Data Protection Board. In this context, personal data holders are entitled to;

a) Learn whether or not her/his personal data have been processed;
b) Request information as to processing if her/his data have been processed;
c) Learn the purpose of processing of the personal data and whether data are used in accordance with their purpose;
ç) Know the third parties in the country or abroad to whom personal data have been transferred;
d) Request rectification in case personal data are processed incompletely or inaccurately;
e) Request deletion or destruction of personal data within the framework of the conditions set forth under article 7;
f) Request notification of the operations made as per indents (d) and (e) to third parties to whom personal data have been transferred;
g) Object to occurrence of any result that is to her/his detriment by means of analysis of personal data exclusively through automated systems;
ğ) Request compensation for the damages in case the person incurs damages due to unlawful processing of personal data
by applying to the data controller.

In accordance with the first paragraph of Article 13 of the PDP (Personal Data Protection) Law, you must submit your request for the use of your above mentioned rights to our Company by "written" or other methods determined by the Board of Personal Data Protection. Since the Personal Data Protection Commission has not set any method at this stage, you must submit your application in writing to our Company in accordance with the mandatory provisions of the PDP Act. The channels and procedures you will submit in writing to our Company within the framework of Article 11 of the PDP Act in this framework are explained below.

To use your abovementioned rights you can send your request with your registered information to the address of Osmanlı Sokak No: 9 Taksim-Beyoğlu, Istanbul, by registered and reply paid letter, stating your request, together with the necessary information to identify your identity, and your right to use it, stating your claim regarding the use of your right as stipulated in Article 11 of the Corporate Tax Law or by signing with secure electronic signature within the scope of Electronic Signature Law numbered 5070, you can forward it to "’istanbulturizmveotelcilikas@hs01.kep.tr " mail address.


(Click for the form you can use for your applications)

© İstanbul Turizm ve Otelcilik Aş, 2016 This document can not be reproduced and distributed without the written consent of İstanbul Turizm ve Otelcilik Aş.
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