PUBLIC DISCLOSURE TEXT

     (For Hotel Guests)

In this accommodation facility owned by SIDEM TURISTIK TESISI ISLETME VE KONAKLAMA TESISLERI A.S. (NASHIRA HOTEL) acting as the Data Controller, you can reach the details in this public disclosure text prepared in accordance with the KVKK Policy, which is prepared and put into practice, and the Law No. 6698 on Protection of Personal Data (KVK Law) from the documents regarding the KVKK Policy of the Data Controller and its annexes. According to this;

1.    Your personal data processed by us

 

1. Identity and family information [Name and surname, T.R. Identity no., passport no., date and place of birth, marital status, occupation, gender, name and number of children, their age and dates of birth, signature, voucher details and register card, room type and room number, flight number, accommodation hotel, dates of stay and paid amount]
2. Communication details [address, telephone no., e-mail address]
3. Location details [Accommodation and location details]
4. Customer transaction details [(License plate no., survey form, records for provision of products and services, requests, instructions, photographs, wedding, specific dates such as anniversaries, birthdays or other special days, call center records, bills, notes, check details, information provided in check-in documents, order details, request details]
5. Information on physical space security [Entry and exit information of employees and visitors, video and audio recordings]
6. Information on transaction security [IP address, hotspot records, password details, website login and logout details, log and digital traffic records]
7. Financial information [bank account number, IBAN, credit card no., CVC code, expiry date]
8. Visual and audio recordings and details [Voice recordings received through the call center, visual and audio recordings and details]
9. Health information [Information on the disability status, blood group,  chronic diseases,    suffered diseases, asthma, diabetes, heart and blood pressure diseases, personal health information, used devices and prostheses]

2.      Method for Collecting Your Personal Data and Legal Reasons

 

Pursuant to this public disclosure text, your personal data are collected through automated or non-automated methods provided that they are part of the data registration system by third parties with whom we have an agreement and provide service as a result of our activity with solution partners with whom we conduct a cooperation and have a contractual relationship and from information, documents or similar means which are submitted verbally, in writing or electronically by you.

In the presence of the following conditions, these data can be processed directly due to your explicit consent within the framework of Article no. 5 of KVK Law No. 6698 and in cases where your explicit consent is not required. According to this;

1. If it is expressly provided for by the laws;
2. If it is necessary for the protection of life or physical integrity of the person himself / herself 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;
3. If processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract;
4. Personal data have been made public by the data subject himself / herself;
5. If data processing is necessary for the establishment, exercise or protection of any right;
6. If processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.

Pursuant to the Article no. 6 of the KVKK Law no. 6698, your special personal data, except for data concerning health and sexual life, may be processed on the basis of your explicit consent or in cases stipulated by law in accordance with the provisions of the same article. Personal data concerning health and sexual life may only be processed, without seeking explicit consent of the data subject, by the persons subject to secrecy obligation or competent public institutions and organizations, for the purposes of protection of public health, operation of preventive medicine, medical diagnosis, treatment and nursing services, planning and management of health-care services as well as their financing.

3.       Purpose of Processing Your Personal Data

 

Your personal data are processed for the purposes shown below in accordance with the Article no. 4, 5 and 6 of the KVK Law no. 6698, considering the principles of being compliant with the law and honesty rules and being accurate and up-to-date when necessary, being processed for certain, clear and legitimate purposes, being relevant, limited and moderate for the intended purposes for which they are processed, and being compliant with the period foreseen in the relevant legislation or the time required for the purpose for which they are processed.

1. Execution of Emergency Management Processes
2. Execution of Information Security Processes
3. Execution of Processes such as selection and placement of Employee Candidates / Trainees / Students
4. Execution of the Application Process of Employee Candidates
5. Execution of Employee Satisfaction and Loyalty Processes
6. Fulfillment of Obligations Arising from Employment Contract and Legislation for Employees
7. Execution of Processes such as Vested Rights and Benefits for Employees
8. Execution of Audit / Ethical Activities
9. Planning and execution of events and activities such as education, seminars, congresses
10. Exercising Access Rights
11. Execution of Activities in Compliance with Legislation
12. Execution of Financial and Accounting Affairs
13. Execution of Loyalty Processes for Firms / Products / Services
14. Provision of Physical Space Security
15. Execution of Appointment Processes
16. Tracking And Execution of Legal Affairs
17. Conducting Internal Audit / Investigation / Intelligence Activities
18. Conducting Communication Activities
19. Planning Human Resources Processes
20. Execution / Control of Business Activities
21. Conducting Occupational Health / Safety Activities
22. Receiving and Evaluating Suggestions for Improving Business Processes
23. Conducting Activities relating to Ensuring Business Continuity
24. Execution of Logistics Activities
25. Execution of Purchasing Processes for Goods / Services
26. Execution of After Sales Support Services for Goods / Services
27. Execution of Sales Processes for Goods / Services
28. Execution of Production and Operation Processes for Goods / Services
29. Execution of Customer Relationship Management Processes
30. Conducting Activities for Customer, Guest Satisfaction, Service Quality
31. Organization and Event Management
32. Conducting Marketing Analysis Studies
33. Execution of Performance Evaluation Processes
34. Execution of Advertising / Campaign / Promotion Processes
35. Execution of Risk Management Processes
36. Execution of Storage and Archive Activities
37. Execution of Social Responsibility and Civil Society Activities
38. Execution of Contract Processes, Full and Accurate Fulfillment of the Obligations undertaken in connection with the Performance of Product and Service Conditions
39. Conducting Sponsorship Activities

40. Execution of Strategic Planning Activities

41. Requests / Complaints Tracking

42. 42. Ensuring the Security of Movable Goods and Resources
43. Execution of Supply Chain Management Processes
44. Execution of Wage Policy
45. Execution of Marketing Processes for Products / Services
46. Ensuring the Security of Operations performed by Data Controller
47. Work and Residence Permit Procedures for Foreign Staff
48. Execution of Investment Processes
49. Execution of Talent / Career Development Activities
50. 50. Providing Information to Authorized Persons, Institutions and Organizations
51. Execution of Management Activities
52. Creating and Tracking Visitor Records
53. Safe Accommodation, Reservation, Fulfillment of Holiday Sale Transactions
54. Using them in Surveys and Marketing and Advertising Activities by Sharing in Social Media and Other Media
55. Ensuring public safety of customers, employees and related third parties in the workplace
56. Applying first intervention, diagnosis and treatment methods in case of health problems
57. Execution of activities regarding business and business administration in accordance with the legislation, company policies and procedures
58. Planning and execution of special day events and activities such as celebrations, parties, birthdays, marriages, weddings, engagements and anniversaries.

Your personal data are not processed for purposes other than those shown above. All kinds of technical and administrative measures are taken by the business management to prevent personal data from being processed or accessed illegally.

4. Transfer of Your Personal Data

 

Pursuant to the Article no. 8 and 9 of the KVK Law no. 6698, your personal data may be transferred domestically or abroad, if the following conditions exist.

Upon the existence of one of the conditions referred to in the Article no. 5 of the KVK Law no. 6698 or by obtaining your explicit consent, personal data may be transferred to persons, institutions and companies with whom a cooperation is conducted, persons and institutions such as shareholders and suppliers with whom an interaction is established, and third parties to/from whom we receive/provide service for the purposes stated above and for the purpose of carrying out the activities mentioned above in accordance with the Article no. 8 and 9 of the Law.

Your personal data concerning health may only be transferred, without seeking your explicit consent, by the persons subject to secrecy obligation or competent public institutions and organizations, for the purposes of protection of public health, operation of preventive medicine, medical diagnosis, treatment and nursing services, planning and management of health-care services as well as their financing, provided that adequate precautions are taken.

1. Provided that adequate protection is provided, if adequate protection is not provided, upon the existence of commitment for adequate protection in writing by the data controllers in Turkey and in the relevant foreign country and authorization of the KVK Board, your personal data may, without your explicit consent, be transferred abroad by the personssubject to secrecy obligation or competent public institutions and organizations, in cases where it is expressly provided for by the laws, it is necessary for the protection of life or physical integrity of the person himself / herself 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 of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract, personal data have been made public by the data subject himself / herself, data processing is necessary for the establishment, exercise or protection of any right, processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject, and for the purposes of protection of public health, operation of preventive medicine, medical diagnosis, treatment and nursing services, planning and management of health-care services as well as their financing.

The KVK Board shall decide whether there is adequate protection in the foreign country and whether such transfer is permitted, by evaluating the international conventions to which Turkey is a party, the state of reciprocity relating to data transfer between the requesting country and Turkey, the nature of the data, the purpose and duration of processing regarding each concrete, individual case of data transfer, the relevant legislation and its implementation in the country to which the personal data are to be transferred, the measures committed by the data controller in the country to which the personal data are to be transferred, and by receiving the opinions of relevant institutions and organizations, where necessary. Without prejudice to the provisions of international agreements, in cases where interest of Turkey or the data subject will seriously get harmed, personal data, may only be transferred abroad upon the authorisation to be given by the Board after receiving the opinions of relevant public institutions and organizations.

In this regard, your personal data may be transferred to

a- To authorized public institutions and organizations

b- Company partners and officials,

c- Business and solution partners,

d- Supplier persons and companies,

e- Real or legal persons with whom we have an interaction,

for the following purposes:

1. Execution of Emergency Management Processes
2. Execution of Information Security Processes
3. Execution of Processes such as selection and placement of Employee Candidates / Trainees / Students
4. Execution of the Application Process of Employee Candidates
5. Execution of Employee Satisfaction and Loyalty Processes
6. Fulfillment of Obligations Arising from Employment Contract and Legislation for Employees
7. Execution of Processes such as Vested Rights and Benefits for Employees
8. Execution of Audit / Ethical Activities
9. Planning and execution of events and activities such as education, seminars, congresses
10. Exercising Access Rights
11. Execution of Activities in Compliance with Legislation
12. Execution of Financial and Accounting Affairs
13. Execution of Loyalty Processes for Firms / Products / Services
14. Provision of Physical Space Security
15. Execution of Appointment Processes

16. Tracking And Execution of Legal Affairs
17. Conducting Internal Audit / Investigation / Intelligence Activities
18. Conducting Communication Activities
19. Planning Human Resources Processes
20. Execution / Control of Business Activities
21. Conducting Occupational Health / Safety Activities
22. Receiving and Evaluating Suggestions for Improving Business Processes
23. Conducting Activities relating to Ensuring Business Continuity
24. Execution of Logistics Activities
25. Execution of Purchasing Processes for Goods / Services
26. Execution of After Sales Support Services for Goods / Services
27. Execution of Sales Processes for Goods / Services
28. Execution of Production and Operation Processes for Goods / Services
29. Execution of Customer Relationship Management Processes
30. Conducting Activities for Customer, Guest Satisfaction, Service Quality
31. Organization and Event Management
32. Conducting Marketing Analysis Studies
33. Execution of Performance Evaluation Processes
34. Execution of Advertising / Campaign / Promotion Processes
35. Execution of Risk Management Processes
36. Execution of Storage and Archive Activities
37. Execution of Social Responsibility and Civil Society Activities
38. Execution of Contract Processes, Full and Accurate Fulfillment of the Obligations undertaken in connection with the Performance of Product and Service Conditions
39. Conducting Sponsorship Activities
40. Execution of Strategic Planning Activities
41. Requests / Complaints Tracking
42. Ensuring the Security of Movable Goods and Resources
43. Execution of Supply Chain Management Processes
44. Execution of Wage Policy
45. Execution of Marketing Processes for Products / Services
46. Ensuring the Security of Operations performed by Data Controller
47. Work and Residence Permit Procedures for Foreign Staff
48. Execution of Investment Processes
49. Execution of Talent / Career Development Activities
50. 50. Providing Information to Authorized Persons, Institutions and Organizations
51. Execution of Management Activities
52. Creating and Tracking Visitor Records
53. Safe Accommodation, Reservation, Fulfillment of Holiday Sale Transactions
54. Using them in Surveys and Marketing and Advertising Activities by Sharing in Social Media and Other Media
55. Ensuring public safety of customers, employees and related third parties in the workplace
56. Applying first intervention, diagnosis and treatment methods in case of health problems
57. Execution of activities regarding business and business administration in accordance with the legislation, company policies and procedures
58. Planning and execution of special day events and activities such as celebrations, parties, birthdays, marriages, weddings, engagements and anniversaries.

5. Your Rights as Personal Data Owner

Pursuant to the law, the relevant person, i.e. data subject is entitled to

1. Learn whether the personal data was processed,
2. Request information in this regard if their personal data was processed,
3. Learn the purpose of the processing of the personal data and learn whether they were used for intended purpose,
4. Learn about the third persons to whom the personal data was transferred inside or outside the country,
5. Request the correction of the personal data which was processed missing or inaccurately
6. Request the deletion or destruction of the personal data in compliance with the provisions of Article no. 7 of the KVKK
7. Ask reporting to third persons to whom personal data which were processed incorrectly and requested to be corrected as well as were requested to be destructed were transferred,
8. Reject the emergence of a consequence against them by the exclusive analysis of the processed data by automatic systems,
9. Request indemnification in case they suffer loss due to the processing of the personal data against the law.

In order to use the complaint rights you have as a personal data owner, you must first apply to the personal data controller by using the communication channels below. No complaints can be sent to the KVK Board before this remedy is exhausted.

Your request is answered by our company acting as data controller as soon as possible and within 30 days at the latest depending on the nature of the request.

In case your application is rejected or the answer given is insufficient or your application is not answered in time, you can use the right to complain to the KVK Board or apply directly to the judicial remedy.

Application Address and Contact Information:

 

SIDEM TURISTIK TESISI ISLETME VE KONAKLAMA TESISLERI A.S. (NASHIRA RESORT HOTEL & AQUA-SPA)

SORGUN MAH. TITREYENGOL MEVKII No:26 MANAVGAT TELEPHONE : 242 756 90 50

E-MAIL: sidem@hotmail.hs05.kep.tr

6. Retention Period of Your Personal Data

 

Your personal data that are required to be processed in accordance with the above mentioned methods and purposes are stored for the period specified in the data inventory, taking into account the statute of limitation and period of prescription specified in the law. In the event that the reasons for the processing of personal data no longer exist or periods stipulated for processing your personal data in accordance with the legislation expire, personal data shall be erased, destructed or anonymized by our Company (i.e. Data Controller), ex officio no later than a period of six months or no later than thirty days upon the request of the data subject.

Erasure of your personal data is the process of making it inaccessible and unusable for the concerned users.

The destruction of your personal data is the process of making the personal data in no way accessible, retrieved and reusable by anyone.

Anonymizing your personal data refers to making them impossible to associate with an identified or identifiable natural person, despite of the use of appropriate techniques.

Transactions regarding the deletion, destruction and anonymization of your personal data are recorded in minutes. These minutes are kept for 5 years for public requirements.

Kindly submitted for your information

7. The Identity of Data Controller

BUSINESS NAME / TITLE: SIDEM TURISTIK TESISI ISLETME VE KONAKLAMA TESISLERI A.S. (NASHIRA RESORT HOTEL & AQUA-SPA)

ADDRESS           :  SORGUN MAH. TITREYENGOL MEVKII No: 26 MANAVGAT

MERSIS NO:   0770001171100016

TAX OFFICE / NO                        :   ANTALYA KURUMLAR – 770 00117 11

DECLARATION OF EXPLICIT CONSENT FOR ACCOMMODATION CERTIFICATE

(Declaration of Explicit Consent to be submitted by the Hotel Customer by filling Hotel Accommodation Certificate)

I hereby accept, declare and undertake that my personal data in the public disclosure text attached to this declaration of consent issued by Data Controller, SIDEM TURISTIK TESISI ISLETME VE KONAKLAMA TESISLERI A.S. (NASHIRA HOTEL) which include my identity data such as name-surname, T.R. Identity Number, Passport Number, date and place of birth, marital status, gender etc., contact details such as occupation, address, telephone number, e-mail address etc., financial information such as bank account number, IBAN, Credit card, voucher (travel card) information and accommodation information such as register card (accommodation card), vehicle license plate, IP address, location information, survey information entered in digital / printed media, my information such as name & surname, voucher number etc. which is, in connection with my accommodation, transferred domestically or internationally via invoice, closed circuit camera images recorded for safety purposes in the workplace in addition to photos, videos and interviews, as well as my sensitive personal data such as disability and allergen status, nationality, chronic diseases and diseases I suffered before for the purpose of first intervention, diagnosis and treatment in case of occurrence of any health problem, are processed, recorded, stored, shared, transferred in Turkey or to abroad, I was informed in detail about KVKK Policy prepared by the data officer and any other subjects on personal data, table, inventory and graphics included in the annexes thereto, as well as about my right, where necessary, to request the deletion, destruction or anonymization of this personal data, I have read and understood this declaration of consent and the KVKK Policy mentioned in the relevant declaration, informative text and its annexes, I give consent to the processing, recording, transfer, sharing and storage of all my personal data listed above, including my sensitive personal data, I have been informed that no more personal data than required are collected from me and personal data are not used out of purpose, I have no objection to the processing or storage of my personal data listed above, I have no claim for copyright or any kind of fee regarding photos, videos and interviews among my personal data, and I expressly consent to these matters without any influence, in order to ensure guest satisfaction, increase the service quality, secure accommodation, reservation, holiday sales and fulfilment of legal obligations.