Personal Data Protection Law
Personal Data Protection Law PRIVACY AND DATA PROTECTION POLICY Website Privacy Agreement By visiting this website and utilizing the services provided through it, the use and protection of the information we obtain about you and the services you request are subject to the terms specified in this "Privacy Policy." By visiting this website and requesting to benefit from the services we offer through it, you accept the terms outlined in this "Privacy Policy."
I. PURPOSE OF THE PERSONAL DATA PROTECTION AND PROCESSING POLICY To date, due to the sensitive nature of the businesses conducted by Byt Peyzaj Hafriyat İnş Ve Tur.Yat.San.Tic.A.Ş and Cet Yatırım İzo.İnş.Tur.Taş.San.Tic.Ltd.Şti (“Byt Peyzaj and Cet Yatırım”), the data received from our customers or prospective customers has been kept confidential and never shared with third parties. The protection of personal data is a fundamental policy of our company. Even before any legal regulations, our company and its affiliates have placed great importance on the confidentiality of personal data, adopting this as a core principle and instructing employees to adhere to it. We, as “Byt Peyzaj and Cet Yatırım,” commit to complying with all responsibilities introduced by the Personal Data Protection Law. Our companies’ principles regarding the protection of personal data also encompass our affiliates.
II. SCOPE AND AMENDMENT OF THE PERSONAL DATA PROTECTION AND PROCESSING POLICY This Policy, prepared by our company, has been drafted in accordance with the Personal Data Protection Law No. 6698 (“PDPL”). The law has come into full effect as of today. Data obtained with your consent or in compliance with other legal grounds specified in the law will be used to enhance the quality of the services we provide and to improve our service and quality policies. Some of the data we hold is anonymized and stripped of its personal nature. Such data, used for statistical purposes, is not subject to the law or this Policy. The “Byt Peyzaj and Cet Yatırım” Personal Data Protection and Processing Policy aims to protect the automatically obtained data of our customers, prospective customers, employees, customers and employees of companies working with us as business partners, or other individuals, and includes provisions related to this. Our company reserves the right to amend this Policy and its regulations, provided it complies with the law and ensures better protection of personal data.
III. BASIC RULES REGARDING THE PROCESSING OF PERSONAL DATA a) Compliance with the Law and Principles of Integrity: “Byt Peyzaj and Cet Yatırım” verifies the source of the data it collects or receives from other companies, ensuring that such data is obtained lawfully and in accordance with principles of integrity. In this context, “Byt Peyzaj and Cet Yatırım” provides necessary warnings and notifications to third parties (such as agencies and other intermediaries) selling our services to ensure the protection of personal data. b) Accuracy and Up-to-Dateness When Necessary: “Byt Peyzaj and Cet Yatırım” ensures that all data held within the organization is accurate, free of incorrect information, and updated when changes to personal data are communicated. c) Processing for Specific, Explicit, and Legitimate Purposes: “Byt Peyzaj and Cet Yatırım” processes data only for the purposes for which consent has been obtained during the provision of services. Data is not processed, used, or allowed to be used outside of these purposes. d) Relevance, Limitation, and Proportionality to the Purpose: “Byt Peyzaj and Cet Yatırım” uses data only to the extent necessary for the purpose for which it was collected and in connection with that purpose. e) Retention for the Period Required by Relevant Legislation or Purpose: “Byt Peyzaj and Cet Yatırım” retains data derived from contracts for the duration of potential disputes, as required by commercial and tax laws. Once these purposes cease, the data is deleted or anonymized.
It is important to note that the principles listed above apply regardless of whether the data was collected with consent or in compliance with the law.
Maximum Savings Principle/Principle of Frugality Under our principle known as the maximum savings or frugality principle, data received by “Byt Peyzaj and Cet Yatırım” is processed into the system only to the extent necessary. Accordingly, the data we collect is determined based on the purpose. Unnecessary data is not collected. Other data transferred to our company is similarly entered into the company’s information systems. Excess information is not recorded in the system, is deleted, or anonymized. Such data may be used for statistical purposes. Health-related sensitive personal data is collected only to provide better service to customers and protect their health, and is carefully stored in the system.
Deletion of Personal Data When the legally required retention periods expire, judicial processes conclude, or other requirements cease, our company deletes, destroys, or anonymizes such data either automatically or upon the request of the data subject.
Accuracy and Data Up-to-Dateness Data held by “Byt Peyzaj and Cet Yatırım” is processed as declared by the relevant individuals. “Byt Peyzaj and Cet Yatırım” is not obliged to verify the accuracy of data provided by customers or individuals in contact with us, nor is this done due to legal or operational principles. Declared data is considered accurate. The principle of accuracy and up-to-dateness of personal data has also been adopted by “Byt Peyzaj and Cet Yatırım.” The company updates personal data based on official documents received or upon the request of the data subject, taking necessary measures to ensure this.
Confidentiality and Data Security Personal data is confidential, and “Byt Peyzaj and Cet Yatırım” adheres to this confidentiality. Only authorized personnel within the company can access personal data. All necessary technical and administrative measures are taken to ensure that personal data collected by “Byt Peyzaj and Cet Yatırım” is not accessed by unauthorized individuals and that our customers and prospective customers are not harmed. In this regard, we ensure that software complies with standards, third parties are carefully selected, and the data protection policy is adhered to within the company.
IV. PURPOSES OF DATA PROCESSING The collection and processing of personal data by “Byt Peyzaj and Cet Yatırım” will be carried out in accordance with the purposes specified in the disclosure text. Data is collected and processed to establish contracts and provide better services to customers.
V. DATA OF CUSTOMERS, PROSPECTIVE CUSTOMERS, AND BUSINESS AND SOLUTION PARTNERS As “Byt Peyzaj and Cet Yatırım,” we process your personal data as the data controller in accordance with the Personal Data Protection Law No. 6698 and other relevant legislation.
The categories and descriptions of personal data to be processed are as follows:
Identity Information: Name-surname, name-surname of accompanying guest(s), nationality, place and date of birth; Turkish ID number, driver’s license, and passport numbers (including date and place of issue).
Contact Information: Address, phone number, email address.
Financial Information: Mobile billing information, bank account details, payment card number, and other payment information.
Loyalty Program Memberships, information about purchased products or services.
Customer Comments, Feedback, and Complaint Data: Specific preferences in accommodation, marketing, and communication; evaluations, opinions, or complaints about brands and facilities.
Other: Reservation details, travel history; participation in contests, raffles, or marketing programs; information about vehicles used to reach the facility; reserved hotel, airline, and car rental packages; groups associated with the stay at the facilities, frequent flyer or travel partnership program memberships and member numbers, information provided in membership and account applications.
Data Collection and Processing for Contractual Relationships If a contractual relationship is established with our customers or prospective customers, the collected personal data may be used without requiring further consent. However, this use is limited to the purpose of the contract. Data is used to ensure better execution of the contract and service requirements, and is updated when necessary by contacting customers. Data provided voluntarily by prospective customers is processed to offer easier and higher-quality services in the future. If such data does not lead to a contractual relationship, it is deleted upon request.
Data of Business and Solution Partners “Byt Peyzaj and Cet Yatırım” adheres to lawful practices when sharing data with business and solution partners. Data is shared with business and solution partners under a commitment to data confidentiality and only to the extent necessary for the service, with these parties required to take measures to ensure data security.
Data Processing for Managing, Analyzing, and Improving Services at Facilities
- Conducting surveys to measure the services provided.
- Communicating with guests for marketing purposes in line with communication permissions granted under relevant laws.
- Preparing internal correspondence and lists regarding guests who behave contrary to facility and general conduct rules during stays.
- Recording guest comments on social media, blogs, review portals, etc., for analyzing feedback on services provided.
- Processing data related to services provided to guests to offer personalized vacation experiences through sales and marketing activities.
Managing Relationships with Guests Before, During, and After Stays
- Making phone calls prior to facility check-in.
- Managing the Customer Loyalty Program.
- Responding to guests’ questions regarding the Loyalty Program, card tiers, transitions to the next card, and similar matters.
- Processing data on reservation history, travel preferences, and services received for segmentation to manage marketing activities effectively.
- Managing claims/complaints about services and facilities on review portals, complaint pages, and social media platforms.
- Keeping guests’ personal information up-to-date and combining it with data from third-party sources for analytical purposes.
E-Invoicing Under the e-invoicing program, customers are automatically enrolled in the program, and invoices are sent via the email address provided to the facility. It is the customer’s responsibility to ensure that the email address provided at check-in or updated later is accurate and preferred for this communication. If a reservation is made for another family member or individual using this email address, the e-invoice will be sent to the email address owner.
Data Processing for Advertising Purposes Electronic messages for advertising purposes may only be sent to individuals who have given prior consent, in accordance with the Law on the Regulation of E-Commerce and the Regulation on Commercial Communication and Commercial Electronic Messages. Explicit consent from the recipient is required for sending advertisements. “Byt Peyzaj and Cet Yatırım” complies with the details of “consent” as specified in the relevant legislation. The obtained consent must cover all commercial electronic messages sent to recipients’ electronic communication addresses for the purpose of promoting, marketing, or enhancing the recognition of the company’s goods and services or sending greetings and wishes. Consent may be obtained in writing in physical form or through any electronic communication means. The key is that the recipient provides a clear affirmative declaration of consent, including their name, surname, and electronic communication address.
Data Processing Due to Legal Obligations or as Explicitly Stipulated by Law Personal data may be processed without further consent if the processing is explicitly required by law or to fulfill a legal obligation specified in the legislation. The type and scope of data processing must be necessary for the legally permitted data processing activity and comply with the relevant legal provisions.
Data Processing by the Company Personal data may be processed in line with the services provided by the company and its legitimate purposes. However, data cannot be used for unlawful services under any circumstances.
Processing of Sensitive Personal Data According to the law, data related to an individual’s race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, appearance and clothing, membership in associations, foundations, or unions, health, sexual life, criminal convictions, security measures, and biometric and genetic data are considered sensitive personal data. In addition to obtaining the individual’s consent, “Byt Peyzaj and Cet Yatırım” takes adequate measures as determined by the Board when processing sensitive personal data. Sensitive personal data is processed only for the purpose for which it was collected and with the individual’s consent.
Data Processed via Automated Systems “Byt Peyzaj and Cet Yatırım” acts in compliance with the law regarding data processed through automated systems. Information obtained from such data cannot be used against the individual without their explicit consent. However, “Byt Peyzaj and Cet Yatırım” may make decisions regarding individuals with whom it will transact using the data in its system.
User Information and Internet When personal data is collected, processed, and used on the websites, mobile applications, or other systems of Byt Peyzaj Hafriyat İnş Ve Tur.Yat.San.Tic.A.Ş and Cet Yatırım İzo.İnş.Tur.Taş.San.Tic.Ltd.Şti, the relevant individuals are informed through a privacy notice and, if necessary, about cookies. Individuals are also informed about our applications on webpages. Personal data is processed in accordance with the law.
Cookies Used When Visiting Our Website When you visit our website, we provide the following information regarding the cookies we use/will use:
Purpose and Type of Cookies Used:
- Google (Analytics, DoubleClick): Measurement, Advertising, On-site improvements (Functional and analytical cookies, Commercial cookies)
- Facebook: Advertising (Commercial cookies)
- Insider: Measurement, Advertising, On-site improvements (Functional and analytical cookies, Commercial cookies)
- Hotjar: Measurement, On-site improvements (Functional and analytical cookies, Commercial cookies)
- Third-Party Companies (Criteo, RTBHouse): Advertising (Functional and analytical cookies, Commercial cookies)
Functional and Analytical Cookies: These include remembering your preferences, enabling effective use of the website, optimizing the site to respond to user requests, and collecting data on how visitors use the site. By their nature, these cookies may contain personal information such as usernames.
Third-Party Cookies: The websites/mobile applications/mobile websites of Byt Peyzaj Hafriyat İnş Ve Tur.Yat.San.Tic.A.Ş and Cet Yatırım İzo.İnş.Tur.Taş.San.Tic.Ltd.Şti work with trusted, well-known third-party advertising providers. Third-party service providers place their own cookies to deliver personalized advertisements. Cookies placed by third parties collect, process, and analyze visitors’ browsing information on websites.
Commercial Cookies: These serve to offer products/content similar to your interests and choices, providing a more advanced, personalized advertising portfolio to enhance your user experience. The retention period for session, persistent, functional, analytical, and commercial cookies mentioned above is approximately two (2) months, and individuals can make necessary adjustments through their internet browser settings. The process for removing these settings may vary depending on the browser.
System Errors During Reservations: If your transaction is interrupted due to system errors or disruptions during the reservation process, our call center representative will reach out to you.
How Can I Delete Cookies? Many internet browsers are set to automatically accept and use cookies from their initial installation. You can use your browser’s help or settings menus to block cookies or receive a warning when cookies are sent to your device. To learn about different ways to manage cookies and detailed information on adjusting your browser’s settings, you can refer to your browser’s instructions or help options screen.
Purposes of Collecting and Processing Security Data at Facilities As the data controller under Law No. 6698, Vogue Hotel Supreme collects security camera footage during your visit to ensure both our company’s and your safety, enabling us to provide services securely. Your personal data is not used for purposes other than those listed and is processed based on the legitimate interest of the data controller as stipulated in Article 5/2(f) of the PDPL. The collected personal data is not shared with any third party or institution as a rule. However, it may be shared to fulfill legal obligations upon requests from legally authorized public institutions and organizations, as per Article 5/2(c) of the law. Once the purpose of collection ceases, your data is destroyed.
VI. EMPLOYEE DATA Processing Data for Employment Relationships Employees’ personal data may be processed without consent to the extent necessary for employment relationships and health insurance. However, “Byt Peyzaj and Cet Yatırım” ensures the confidentiality and protection of employee data.
Job Applications, Candidate Sourcing, and Human Resources Management: Data is obtained through the Kariyer.net system and recorded in the system for candidate evaluation processes.
Processing for Legal Obligations “Byt Peyzaj and Cet Yatırım” may process employees’ personal data without further consent if the processing is explicitly required by law or to fulfill a legal obligation specified in the legislation. This is limited to obligations arising from the law.
Processing for Employee Benefits “Byt Peyzaj and Cet Yatırım” may process personal data without consent for transactions benefiting employees, such as private health insurance. The company may also process employee data for disputes arising from employment relationships.
Processing of Sensitive Personal Data According to the law, data related to an individual’s race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, appearance and clothing, membership in associations, foundations, or unions, health, sexual life, criminal convictions, security measures, and biometric and genetic data are considered sensitive personal data. In addition to obtaining the individual’s consent, “Byt Peyzaj and Cet Yatırım” takes adequate measures as determined by the Board when processing sensitive personal data. Sensitive personal data may be processed without consent only in cases permitted by law and limited to those cases. Sensitive data collected from employees for insurance and health services is used solely for those purposes.
Data Processed via Automated Systems Data processed through automated systems related to employees may be used for internal promotions and performance evaluations. Employees have the right to object to unfavorable outcomes and can do so by following internal company procedures. Such objections are evaluated within the company.
Telecommunications and Internet Computers, phones, emails, and other applications allocated to employees within the company are provided solely for business purposes. Employees may not use these tools for personal purposes or communication. The company may monitor and audit all data on these tools. Employees undertake not to store any non-work-related data or information on the computers, phones, or other tools allocated to them from the start of their employment.
VII. TRANSFER OF PERSONAL DATA DOMESTICALLY AND INTERNATIONALLY Personal data may be shared by “Byt Peyzaj and Cet Yatırım” with business and solution partners and affiliates to provide services.
“Byt Peyzaj and Cet Yatırım” may transfer personal data to the following persons and entities for specific purposes:
- To business partners, limited to fulfilling the purposes of the business partnership.
- To suppliers, limited to providing the services necessary for the company’s commercial activities sourced externally.
- To solution partners, limited to ensuring the execution of commercial activities requiring the participation of the company’s affiliates.
- To the company’s affiliates.
“Byt Peyzaj and Cet Yatırım” has the authority to transfer personal data domestically and internationally in accordance with the conditions set by the Board in the law and subject to the individual’s consent, as per other provisions of the law.
VIII. RIGHTS OF THE DATA SUBJECT “Byt Peyzaj and Cet Yatırım” acknowledges that under the law, the data subject has the right to give consent before their data is processed and the right to determine the fate of their data after processing.
By applying to the contact person announced on our website, data subjects may: a) Learn whether their personal data is being processed, b) Request information about their processed personal data, c) Learn the purpose of the data processing and whether it is used in accordance with that purpose, d) Know the third parties to whom their personal data is transferred domestically or internationally, e) Request correction of incomplete or inaccurate personal data, f) Request the deletion or destruction of personal data under the conditions specified in Article 7, g) Request notification of the actions taken under (e) and (f) to third parties to whom the personal data has been transferred, h) Object to the emergence of an unfavorable result due to the analysis of processed data solely through automated systems, i) Demand compensation for damages incurred due to the unlawful processing of personal data.
However, individuals have no rights regarding anonymized data within the company. “Byt Peyzaj and Cet Yatırım” may share personal data with relevant institutions and organizations to fulfill judicial duties or exercise the legal powers of state authorities as required by law.
Data subjects may submit their requests regarding the above rights by completing the application form available at the company’s official website, www.voguehotelsupreme.com, signing it with a wet signature, and sending it to the communication address below via registered mail with return receipt, along with copies of their identity documents (only the front page of the ID card). Applications will be responded to as soon as possible, or within 30 days at the latest after receipt by the company. Applications must be sent via registered mail with return receipt. Only the parts of applications related to the applicant will be processed, and applications regarding spouses, relatives, or friends will not be accepted. “Byt Peyzaj and Cet Yatırım” may request additional relevant information and documents from applicants.
IX. CONFIDENTIALITY PRINCIPLE Data held by “Byt Peyzaj and Cet Yatırım,” whether belonging to employees or other individuals, is confidential. No one may use, copy, reproduce, transfer to others, or use this data for purposes other than business without contractual or legal compliance.
X. TRANSACTION SECURITY All necessary technical and administrative measures are taken to protect personal data collected by “Byt Peyzaj and Cet Yatırım,” prevent unauthorized access, and ensure that our customers and prospective customers are not harmed. In this regard, we ensure that software complies with standards, third parties are carefully selected, and the data protection policy is adhered to within the company. Security measures are continuously updated and improved.
XI. AUDIT “Byt Peyzaj and Cet Yatırım” conducts necessary internal and external audits regarding the protection of personal data.
XII. NOTIFICATION OF BREACHES When notified of any personal data breach, “Byt Peyzaj and Cet Yatırım” takes immediate action to address the breach. The company minimizes the damage to the data subject and compensates for any harm. If personal data is obtained by unauthorized persons, the situation is immediately reported to the Personal Data Protection Board.
Applications regarding breach notifications can also be made following the procedures specified at www.voguehotelsupreme.com/tr/kvkk.
Requests Under the Personal Data Protection Law All applications will be processed as announced at www.voguehotelsupreme.com/tr/kvkk by completing the form available on the page, attaching a copy of the identity document, and sending it to the address specified on the form via registered mail with return receipt.
Rights regarding personal data can only be exercised for the individual’s own data. Requests regarding the data of persons other than the individual who completes the form and attaches a copy of their identity document will not be considered. Forms without an attached copy of an identity document will not be processed. Please note that even when data deletion requests are fulfilled, we are obliged to share data with official authorities upon their request.
Application form: www.voguehotelsupreme.com/tr/kvkk/
XIII. CHANGES TO THE PERSONAL DATA PROTECTION AND PRIVACY POLICY “Byt Peyzaj and Cet Yatırım” reserves the right to make changes to the statements herein. If significant changes are made to the statement, a link to the updated statement will be added to the homepage of the website. Guests who register for any of our products or services may be informed about this matter through the communication channels provided to the facilities. The date of the last update and the update number are specified at the end of this document. Any changes to the statement take effect upon the publication of the revised statement on the website. Using the website or any of our products and services following such changes indicates your acceptance of the revised statement in effect at that time.
Policy Update: 20.09.2019, PDPL Statement-1
CONTACT For questions regarding the privacy agreement, you can reach us using the following contact information: Website: www.voguehotelsupreme.com
Data Subject Application Form Bodrum
Data Subject Application Procedures Bodrum
