1. INTRODUCTION
As Erlüks Deri Sanayi ve Turizm Tic. A.Ş. (Bricks Hotel Istanbul), acting in the capacity of data controller, we wish to inform you pursuant to the Law on Protection of Personal Data (“KVKK”) numbered 6698 under Article 10 titled “Disclosure Obligation of Data Officers”.
1.1. DEFINITIONS
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| Personal Data |
All types of information on a natural person whose is identity is known or can be determined (name, ID no., parents’ names, birth date and place, nationality, passport no., driving licence, address, email, mobile number, credit card details, visual and sound records and other information)
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| Personal Data of Special Nature |
Personal data relating to the race, ethnic origin, political opinion, philosophical belief, religion, sect or other belief, clothing, membership to associations, foundations or trade-unions, health, sexual life, convictions and security measures, and the biometric and genetic data are deemed to be personal data of special nature. |
| Data Controller |
Data controller is the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data filing system. |
| Data Processor |
Natural or legal person who processes personal data on behalf data controller and by the authority granted by the data controller. |
| Explicit Consent |
Freely given, specific and informed consent. |
| Processing of Personal Data |
Any operation performed upon personal data such as collection, recording, storage, retention, alteration, re-organization, disclosure, transferring, taking over, making retrievable, classification or preventing the use thereof, fully or partially through automatic means or provided that the process is a part of any data registry system, through non-automatic means. |
| Erasure, destruction or anonymizing of personal data |
Personal data shall be erased, destructed or anonymized by the controller, ex officio or upon demand by the data subject, upon disappearance of reasons which require the process.
Rendering personal data impossible to be accessed, recovered or reused by anyone. |
2. PURPOSES OF PROCESSING PERSONAL DATA
As per Articles 4, 5 and 6 of the KVKK and the fundamental principles set forth in the KVKK, in order to allow relevant persons to benefit from the services our company provides, your personal data may be collected and processed for the activities explained below:
• Planning and conducting sales, financial, marketing, accounting, legal and judicial processes
• Maintaining customer satisfaction
• Informing authorized natural persons, public institutions and other authorized establishments
• Ensuring the safety of our employees, visitors to our facilities, visitors’ vehicles and providing WIFI service
• Using personal data during legal disputes to provide evidence
• Processing personal data within information technology processes and managing information security
• Maintaining business activities while complying with legal processes and regulations
• Conducting and completing internal processes of our company
• Complying with legal obligations
• Processing request and complaints
• Conducting audit and security activities
• Conducting storage and archive activities
3. METHODOLOGY OF OBTANING YOUR PERSONAL DATA
Your personal data is stored, archived in written, oral, visual and electronic formats through automated or partly automated systems or non-automated systems that are part of a data record system and collected via methods and sources such as:
• Our website
• During reservation, entry, registry and stay at our facilities through printed and electronics formats and other communication methods
• Camera footage at our facilities
• As part of our business activities: applications to us, written correspondence, documents, printed and electronic forms, proposed commercial offers, contracts we signed with you or the firm you are representing
• Documents and online records held by public agencies
• Research of open data on internet, media and other sources
• Visitor register books and software at the facilities of Erlüks
• Through our WIFI network used by visitors to access internet
• Written correspondence between you and our employees
• Third parties such as our company’s business contacts, travel agencies or firms supplying services and goods to us.
4. LEGAL REASONS FOR COLLECTING YOUR PERSONAL DATA
We collect your personal data in accordance with the procedures and rules stated by the law based on the following legal reasons:
• You give explicit consent,
• it is clearly provided for by the laws,
• it is mandatory for the protection of life or physical integrity of the person or of any other person who is bodily incapable of giving his consent or whose consent is not deemed legally valid,
• processing of personal data belonging to the parties of a contract, is necessary provided that it is directly related to the conclusion or fulfilment of that contract,
• it is mandatory for the controller to be able to perform his legal obligations,
• the data concerned is made available to the public by the data subject himself,
• data processing is mandatory for the establishment, exercise or protection of any right,
• it is mandatory for the legitimate interests of the controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.
We store all of the data that we process, while taking all necessary administrative and technical precautions, in accordance with the mandatory time periods under KVKK and other related regulations and in any case until legitimate purposes cease to exist.
5. TRANSFER OF PERSONAL DATA TO THIRD PARTIES
In order to carry out our company’s activities and continue business processes, if the legal reasons stated above are present and in accordance with the purposes stated, we may transfer your personal data to third parties below:
• Our domestic business partners who provide services to our company,
• Agencies we collaborate with, our suppliers and our business partners who provide online hotel reservation service
• Third party service providers who provide services within facilities,
• Banks and financial institutions,
• Consultancy firms advising us on legal, tax and similar issues,
• Company officials, shareholders and legally authorized public institutions and private persons,
• Service providers who process personal data on behalf of our company and support us in the areas of storage, archive, IT (server, hosting, software, etc.) within the country,
On the condition that KVKK provision are complied with. The data can be shared for the purposes stated in Art. 8 and Art. 9 of KVKK.
6. PROCESSING OF PERSONAL DATA OF SPECIAL NATURE
Personal data of special nature stated in Art. 6 of KVKK is processed with explicit consent of the data subject within the scope of conditions stated in the Law while applying principles of proportionality and necessity.
7. YOUR RIGHTS AS DATA SUBJECT
Pursuant to Article 11 of KVKK, your rights in regards to your personal data are to:
a) Learn whether or not your personal data have been processed;
b) Request information as to processing if your data have been processed;
c) Learn the purpose of processing of the personal data and whether data are used in accordance with their purpose;
d) Know the third parties in the country or abroad to whom personal data have been transferred;
e) Request rectification in case personal data are processed incompletely or inaccurately;
f) Request deletion or destruction of personal data within the framework of the conditions set forth under article 7 of KVKK;
g) Request notification of the operations made as per indents above to third parties to whom your personal data have been transferred;
h) Object to occurrence of any result that is to your detriment by means of analysis of personal data exclusively through automated systems;
i) Request compensation for the damages in case you incur damages due to unlawful processing of personal data
8. METHODS OF APPLICATIONS AND REQUESTS ON PERSONAL DATA
In the case of written application,
You can access the application form we share through the link below, fill it and
use it to send your requests to ‘Turgut Özal Millet Cad. No:189
Topkapı/Fatih/İSTANBUL’ personally with signature, information specifying
your identity (ID or driving licence copy with Turkish Identity number, but
religion, marriage status, blood type, disabiliy sections covered), or through an
attorney with notarized power of attorney document stating their right to make an
application in relation to your rights under Art. 11 via a notary or via mail with
return receipt requested.
In the case of electronic application,
You can sign the Data Subject Application Form using an electronic or mobile
signature that has the certificate of “secure electronic signature” stated in
Electronic Signature Law No. 5070 and send it to our registered email address
erluks@hs01.kep.tr or to kvkk@brickshotels.
Your requests will be responded to electronically or in printed format within the shortest period and latest within 30 days depending on the nature of your request. There is normally no fee for your requests, however, our company has the right to demand a fee under the fee scale pursuant to Art. 7 of the Notice on Procedure and Rules of Applications to Data Controller.
Click here to access our application form.
9. IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER
This privacy notice is created by the data controller for data subjects.
Business Title : Erlüks Deri Sanayi ve Turizm Tic. A.Ş.
Address : Zafer Mahallesi Dumlupınar Caddesi No:42 Bahçelievler/İSTANBUL
Central registartion system number: 0364000973600019
Telephone : +90212 916 16 19
Fax : +90212 916 16 29
Registered email address : erluks@hs01.kep.tr