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Reception at CVK Hotels & Resorts in Istanbul

Privacy Policy

PREAMBLE

Personal Data Protection is a very important topic for CVK Park Bosphorus Hotel. We are committed to diligently store data pertaining to everyone who submit their personal data by contacting us through any means. We have taken all precautions necessary to ensure the security of such data.  You may make any transaction with CVK Park Bosphorus Hotel with a peace of mind with respect to security of your personal data. We are committed to respect your rights as regards to your data assured by either Constitution or Laws of Republic of Turkey.   We are sharing below with you the Privacy Policy which is implemented in our company.
Please rest assured that we will show our due diligence to your improvement suggestions, applications as well as potential complaints. You may apply to us if you have any doubts with regard to your personal data.  We will exercise the same care and diligence in protection of your personal data just as we exercise in all our services.
 
Respectfully yours,
CVK Park Bosphorus Hotel Istanbul
CVK Maden İşletmeleri A.Ş.


1. Purpose

At CVK Park Bosphorus Hotel (hereinafter, “CVK”), we have always kept secret, and never shared with third parties for purposes other than intended purposes, the personal data collected by us in line with the sensitivity that nature of our business requires.    Protection of personal data is the basic policy of our company. We also placed a great importance on the privacy of the personal data and adopted it as a business principle even before the enactment of relevant laws and regulations. As CVK, we undertake to respect all responsibilities imposed upon us by the Personal Data Protection Law.


2. Scope and Amendment

This Policy drawn by our Company is prepared in line with Personal Data Protection Law No 6698 (“PDPL”).  As of today, Law, together with all provisions, entered into force.
Data collected from you, with your consent or as legally allowed by the Law will be used in order to improve quality of our services that we provide to you as well as improve our quality policy.  And some data in our possession are subjected to data anonymization.  Such data are used for statistical purposes and not subject to application of the Law and our Policy. 
CVK Privacy Policy aims at protecting and contains regulations related with the automatically collected data of our customers, prospective customers and our employees as well as customers and employees of our solution partners or other persons.
Our company reserves the right to amend our Policy and our Regulation/Directive provided that it is in line with the Law and provided higher levels of protection on the personal data. 


3. Basic Principles Relating to the Processing of Personal Data

1. Lawfulness and fairness: CVK questions the source of the data collected by himself or received from other companies and place importance on collection of such data under the rules of lawfulness and fairness.

2. Accuracy and, when necessary, being up-to-date: CVK places importance on accuracy and correctness of all the data internally kept and also updating any changes to personal data which is notified to us. 

3. Processing for specific, explicit and legitimate purposes: CVK processes data as limited to the purposes for which the consent of relevant individuals is taken during the provision of the service.   CVK shall not process or use or allow to use of data other than purposes of the business in question.

4. Relevancy, limited with the purposes for which they are processed:   CVK uses data only for the purposes for which they are processed and to the extent required by the service.

5. Storage for the duration prescribed by the applicable legislation or the purpose for which they are processed: CVK internally stores contractual data for such dispute periods under the Law and requirements of the commercial and tax law.  Accordingly, he deletes or anonymizes the data when such purposes cease to exist.  He deletes or destroys such data according to Personal Data Deletion Directive.

Please importantly note that the principles above apply to the data collected or processed by CVK either on the basis of consent or legal grounds.


4. Rights of Personal Data Subject under Article 11 of Personal Data Protection Law

According to Art. 11 of PDPL, you have following rights.  An application form is also prepared by CVK and presented to you on the website for your interest to make such rights easier to exercise.  
By applying to our contact person published by CVK on our website, Persons whose personal data is processed have rights to;  

1. get information if their personal data is processed or not,

2. if their personal data is processed, request relevant information,

3. get information about the purpose of processing of their personal data, whether they are used in line with intended purpose,

4. get information about third parties, foreign or local, to which their personal data is transferred,

5. if their personal data are processed in part or inaccurately, then submit a request to correct them as well as get information about operations in this respect and the third parties to which their personal data is transferred,

6. request to have their data, which are already processed, be deleted when the reasons which require such processing cease to exist and to inform third parties to which their personal data is transferred about the actions taken in this respect in accordance with the provisions of Law No 7 and other laws,

7. object against occurrence of any results that are against their interests after their data processed are analyzed via exclusive automatic systems,

8. claim any damages be compensated if they incur damages as a result of illegal processing of their personal data. As CVK, we respect these rights listed above.


5. Principle of Data Minimization
According to principle of data minimization, data collected by CVK are processed in the system to extent required. Therefore type of data we will collect is determined according to intended purpose. Data that are unnecessary are not collected. Data transferred to our company are transferred in IT systems of our company in the same manner. Excessive data are not recorded in the system, they are deleted or anonymized. Such data can be used for statistical purposes.

6. Deletion of Personal Data
Personal data are deleted, destroyed or anonymized by our company automatically or upon request of the relevant individual when legal storage durations are expired, when legal proceedings are finalized or other requirements cease to exist.

7. Accuracy and Data Update
Data in the possession of CVK is, as a rule, processed as submitted by relevant individual upon their submission. CVK is not required to and also is prohibited under laws and our business principles to search the accuracy of the data submitted by customers or persons who contacted with CVK. Data submitted as such are deemed to be accurate. Principle of personnel data accuracy is also adopted by CVK.  We update personal data processed by using official documents received by our company or upon the request of the data subject. Our company takes necessary precautions to do so.

8. Confidentiality and Data Security
Personal data are confidential and CVK respects such privacy. Personal data can only be accessed by our authorized staff member. All technical and administrative precautions are taken necessary to protect personal data collected by CVK and prevent unauthorized people to access them and not to cause data subject to suffer from such breaches.  In this respects, software we use conform to standards, third parties are screened carefully and we ensure that our staff members respect the Privacy Policy. Also companies with whom we legally share personal data are demanded to protect such data.

9. Purposes of Data Processing
The purposes of personal data processing by our company is set forth in the text of Information about Processing of Personal Data.  

10. Data of Customer, Prospective Customer and Business and Solution Partnersa.      Collection and Processing of Data for a Contractual Relationship
If a contractual relationship is established with our customers and prospective customers, personal data collected can be used without requiring further consent of our customers. However, such use is in line with the purpose of the contract. Data are used to the extent required for better performance of the Contract and requirements of the service and updated when necessary after having contacted with customers.

b.      Data of Business and Solution Partners
CVK adopts lawfulness as its principle while sharing data with business and solution partners. Data are shared with business and solution partners only upon they guarantee the data confidentiality and to the extent required by the service and they are strictly required to take necessary precautions to ensure data security.

11. Data Processing for Advertisement Purposes
Electronic mails can only be sent for advertisement purposes to the persons whose consent is taken in advance in accordance with the E-Commerce Law as well as Regulation on Business Communication and Electronic Mails For Commercial Purposes.   The consent of recipient of the advertisement must explicitly have been taken in advance.
Also, CVK respects the “consent” details as prescribed by the same legislation. The consent to be taken must cover all commercial electronic mails delivered to the electronic mail addresses of the recipients in order to introduce, promote, market the goods and services of a company as well as improve the recognition with contents such as celebration and wishes.  Such consent can be taken in writing in the physical environment or via any kind of electronic communication means. What is important is to have the affirmative will declaration of the recipient that he/she consented to receive commercial electronic messages as well as his/her name and surname and electronic contact address.

12. Data Procedures Due to Legal Obligation of the Company or as Explicitly Required by the Law  
Personal data may be processed without an explicit consent if such processing is explicitly required by the legislation or in order to fulfill a legal obligation as prescribed by the applicable legislation. Type and scope of data procedures must absolutely be necessary for such legally permitted data processing and respect the applicable legal provisions.

13. Data Processing by Company
Personal data may be processed in line with the services provided by company and its legitimate purposes. However, data is strictly prohibited to be used for illegal services.

14. Processing Data of Special Nature
CVK also takes all of the adequate precautions as determined by the Board in processing of personal data of special nature. At our company, we process personal data of special nature according to the “Policy of Protection and Processing of Personal Data of Special Nature”.

15. Data Processed via Automatic Systems
CVK respects the applicable Law for data processed via automatic systems. Information derived from such data without explicit consent of persons cannot be used against person. However, CVK may take decisions with respect to the persons by using the data stored in his own system.

16. User Information and Internet
If personal data are collected, processed and used through websites and other systems or applications owned by CVK, relevant persons are informed via privacy notification and if necessary about cookies. 
Individuals are informed about our applications on the websites.  Personal data will be processed in accordance with the laws.

17. Data of Our Employees
a. Data Processing for Business Relationship
Personal data of our employees may be processed without consent to the extent required for business relationship and medical insurance. However, CVK ensures that data pertaining to his employees remain confidential and protected.
b. Processing as Required by Legal Obligations
CVK may process personal data of his employees without an explicit consent if such processing is explicitly required by the legislation or in order to fulfill a legal obligation as prescribed by the applicable legislation. Such processing is limited with the obligations arising out the law.
c. Processing in favor of Employees
CVK may process personal data without consent for the actions in favor of the company employees, such as private medical insurances.  CVK may process data owned by his employee for the disputes arising out of the business relationships.
d. Processing Data of Special Nature
According to the Law, data of special nature include personal data related with the race, ethnicity, political ideas, philosophical belief, religion, sect or other beliefs, dressing, membership in foundation, association or union, health, sexual life, criminal conviction and security measurements as well as biometrics and genetics. 
CVK also takes all of the adequate precautions as determined by the Board, besides the consent of data subject, in processing of personal data of special nature. Personal data of special nature may only be processed if they are relevant to and limited to conditions as permitted under Law.
e. Data Processed via Automatic Systems
Data of employees processed via automatic systems can be used in internal promotions and performance assessments. Our employees are entitled to object against the results that are against them and handle such objections in accordance with internal procedures.  Objections of our employees are also evaluated internally.
f. Telecommunication and Internet
Computer, phone, e-mail and other applications internally allocated to employees are only allocated for business purposes. Employee may not use any of such means allocated by the company for private purposes and communication. Company can inspect and audit all data stored on such means. By virtue of the job contract, employees undertake not to store any data and information other than those required for business purposes on the computers, phones or other means allocated to him/her.

18. Local or Overseas Transfer of Personal Data
Personal data may be transferred to controlling shareholder as well as business and solution partners in order to enable CVK to provide the services. 
CVK may transfer personal data to CVK’s suppliers provided that the same is limited to enable CVK to receive external services from suppliers that are required for CVK to carry out his business activities. 
CVK is authorized to transfer the personal data locally or overseas under the requirements of the Boards in accordance with the other requirements under Law.

19. Rights of Data Subject
CVK acknowledges that data subject has right to consent before data processing and after data processing has right to determine the fate of his/her data under the Law. 
Upon applying to our officer who is announced on our website, Data Subject, with respect to personal data, has right to 
a) get information if their personal data is processed or not,
b) if their personal data is processed, request relevant information,
c) get information about the purpose of processing of their personal data, whether they are used in line with intended purpose,
d) get information about third parties, foreign or local, to which their personal data is transferred,
e) if their personal data are processed in part or inaccurately, then submit a request to correct them,
f) to request their personal data deleted or destroyed under the conditions as prescribed under Article 7,
g) to request  to notify third parties to which personal data is transferred about the actions taken pursuant to sub-paragraph (d) and (e),
(h) object against occurrence of any results that are against their interests after their data processed are analyzed via exclusive automatic systems,
(i) claim any damages be compensated if they incur damages as a result of illegal processing of their personal data.
On the other hand,
Data subject do not have any rights with respect to the internally anonymized data. CVK may disclose personal data to authorities, if required by the business and contractual relationship, in order to enable an authority, judicial or governmental, to exercise his legal authorities. 
Data subjects may deliver Company their requests related with the rights aforementioned by filling completely and signing with their wet-ink signature the application form, which they can receive physically at our hotel or via official website of our Company, and then sending it, together with copy of their ID Card (for Birth Certificate, only copy of front face), to the address of our hotel via registered mail.    You applications will be answered, depending on contents of your application, in the shortest time possible or at latest 30 days following the receipt by our company.  You are required to make your applications via registered mail. In addition, only the part of your application related with you will be answered and any applications made on behalf of your spouse, relative or friend will be rejected. 
CVK may require applicants to submit any additional information and document.     
      
20. Principle of Confidentiality
Data stored by CVK of either employees or other persons are confidential. Nobody can use, reproduce, copy and transfer to others for purposes other than contractual or legal purposes, as well as use them for purposes other than business purposes.  

21. Security of Data Processing  
All technical and administrative precautions are taken necessary to protect personal data collected by CVK and prevent unauthorized people to access them and not to cause our customers and prospective customers to suffer from such breaches. In this respects, software we use conform to standards, third parties are screened carefully and we ensure that our staff members respect the Privacy Policy. Precautions with respect to security are continuously renewed and upgraded.

22. Audit
CVK has internal and external audits made, necessary for the protection of the personal data. 

23. Breach Notification
In case of breach notification received with respect to personal data, CVK immediately takes action in order to eliminate said breach.  CVK minimizes and compensate the damage suffered by data subject. CVK immediately notifies Personal Data Protection Board about the cases where personal data is captured by external unauthorized persons.
 

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