CLARIFICATION TEXT FOR THE WEBSITE WITHIN THE SCOPE OF THE LAW NO. 6698 ON THE PROTECTION OF PERSONAL DATA

Purpose and Scope of the Clarification Text

As Akropol Turizm Yatırımları İnşaat Ve Dış Ticaret Anonim Şirketi (Phokaia Hotel), we take measures to protect your personal data within the scope of the Law No. 6698 on the Protection of Personal Data (“GDPR” or “Law”). We process your Personal Data within the scope of GDPR and related legislation and in our capacity as “data controller” for the reasons and methods described below.

Akropol Turizm Yatırımları İnşaat Ve Dış Ticaret Anonim Şirketi Clarification Text on the Processing of Personal Data has been prepared in accordance with the article titled “Data Controller’s Obligation to Inform” in Article 10 of the GDPR; in order to inform you in the most transparent way about the identity of the data controller, the method and legal reason for collecting your personal data, the purpose for which this data will be processed, to whom and for what purpose it can be transferred, the duration of data processing and your rights listed in Article 11 of the GDPR. The explanations made for “Your Personal Data” in the clarification text also cover “Your Personal Data of Special Nature”.

Data Controller

Company Title: Akropol Turizm Yatırımları İnşaat Ve Dış Ticaret Anonim Şirketi

Address: İsmetpaşa Mahallesi 354 Sk. No: 2 Foça/İZMİR

(referred to as “Company or Phokaia Hotel” within the scope of Clarification Text)

Method and Legal Reason for Collecting Your Personal Data

Your personal data may be collected verbally, in writing or electronically by automatic or non-automatic methods, the Company’s affiliated units, website, social media channels, call centre, mobile applications and similar means. Your personal data may be processed by creating and updating as long as your relationship with the Company continues and may be kept in both digital and physical environment.

Your personal data may be processed and transferred in line with the purposes set out in the heading “Your Personal Data Processed and Purposes of Processing” and within the scope of the personal data processing conditions and purposes specified in the clauses “a, ç, e and f” in accordance with paragraph 1 of Article 5 of Law No. 6698 or paragraph 2 of Article 5.

Your Processed Personal Data and Purposes of Processing

Your Personal Data is processed securely and in accordance with the Law on the Protection of Personal Data in accordance with legal obligations or in order to provide a more appropriate service in company business and transactions.

In this context, the data in the table are collected as personal data.

Identity Data: It is the data group containing information about the identity of the person (Name, surname, ID No, place of birth, date of birth, gender, tax number, nationality).

Contact Data: It is the data group that can be used to reach the person (Telephone, address, e-mail).

Transaction Security Data: This data category refers to data types such as IP address information, website login and exit information, password and password information.

Your personal data collected;

– Real and/or legal third persons, institutions and organisations (employees, visitors, patients, suppliers, business partners, etc.) who have a relationship with the Company can benefit from the products and services of our Company,

– Fulfilment of legal and regulatory requirements arising/may arise from all relevant laws and secondary regulations and taking necessary measures in this context,

– Carrying out auditing and/or regulatory duties to be carried out by the competent and authorised public institutions and organisations and professional organisations in the nature of public institutions,

– Fulfilment of information and document requests by judicial bodies and/or administrative authorities,

– To carry out listing, reporting, verification and analysis studies on the use of the products and services offered in our company and all centres and units affiliated to the company, to produce statistical and scientific information in this regard, to improve our products and services accordingly, to increase satisfaction with our products and services and to make customisations regarding the user in this context,

– To be able to carry out market research, promotion and necessary information about our products and services, to evaluate complaints and suggestions and to contact you directly through the communication channels shared with the Company,

– Fulfilment of risk management and quality improvement activities,

– Taking all necessary technical and administrative measures for systems and applications within the scope of data security purposes, within the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698.

To whom and for which purpose your processed personal data can be transferred

By ensuring that all necessary technical and administrative measures are taken to ensure the appropriate level of security in accordance with the KVKK and the relevant legislation, your Personal Data / Personal Data for the purposes stated above;

-Persons/institutions and organisations permitted by the provisions of other relevant legislation,

-Private insurance companies, banks,

-Our direct/indirect domestic/international shareholders,

-Our subsidiaries and/or affiliates,

-Counsellors

-Business partners,

-It may be transferred within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the GDPR Law with domestic/foreign organisations that we contractually receive and/or provide services to carry out our activities and with which we cooperate.

Data Processing Period and Storage Period

Your personal data, limited to the purposes specified in this Clarification Text; It will be processed by complying with the data processing and limitation periods in all relevant laws and other legal legislation to which our company is subject. In case of changes in the laws regarding data processing periods, the new periods determined will be taken as basis.

As a requirement of the principle of limitation of purpose, your personal data are processed limited to the time required for the fulfilment of the purposes described in this Clarification Text and in any case in accordance with the practices of the Company and the customs of commercial life, and after the expiration of the periods, they are deleted, destroyed or anonymised.

Rights of the Related Person and Utilisation of These Rights

As the data subject, you may use your requests within the scope of Article 11 of the Law regulating the rights of the data subject in accordance with the ” Communique on the Procedures and Principles of Application to the Data Controller ” in writing to “İsmetpaşa Mahallesi 354 Sk. No: 2 Foça/İZMİR” in writing or by sending an e-mail to … e-mail address. More comprehensive regulation on this subject is made in the “Personal Data Application and Response Procedure” and “Personal Data Protection and Processing Policy”.