Clarification Text in the Scope of Personal Data Protection Law No. 6698

Delbab Hotel - İdris DOĞAN

As Delbab Hotel – İdris DOĞAN, we respect and value the privacy of personal life. Therefore, we would like to inform you about the use and protection of your data within the scope of Personal Data Protection Law No. 6698 (hereinafter referred to as “KVKK”) and your rights.

a) Data Controller

As Delbab Hotel – İdris DOĞAN, we hereby inform you that we process your personal data as a data controller following the Personal Data Protection Law No. 6698 (KVKK) and relevant legislation.

b) Processed Personal Data

Following KVKK and relevant legislation, the categories and explanations of personal data to be processed within the scope of this Clarification Text applied under Law No. 6698 on the Protection of Personal Data are as follows:

• Identity Information: Name, surname, place and date of birth, nationality, Republic of Turkey Identity Number, accompanying guest’s name, surname, and place and date of birth.
• Contact Information: Address, phone number, and email address.
• Financial Information: Bank account details.
• Special Categories of Personal Data: Photograph, health condition, and medication usage information.
• Other: Room number, vehicle plate information, smoking status, and allergen information.

c) Purposes of Processing Personal Data

Under legal grounds specified in Article 5 (2) of the KVKK, including the legal reasons of “a) Explicitly stipulated by laws,” “c) Being necessary for the establishment or performance of a contract, provided that it is directly related to the parties of the contract,” “ç) Being necessary for the data controller to fulfill its legal obligation,” “e) Being necessary for the establishment, exercise, or protection of a right,” your personal data will be processed for the following purposes:

• Execution of processes related to accommodation services.
• Recording in online software systems used by Delbab Hotel for the implementation of sales and marketing policies.
• Carrying out necessary transactions by our business units to provide you with Delbab Hotel’s products and services.
• Measuring and improving customer satisfaction.
• Collection and evaluation of complaints and suggestions regarding Delbab Hotel’s products and services.
• Recommendation of products and services offered by Delbab Hotel; planning and/or executing market research activities for the sale and marketing of products and services.
• Ensuring legal, technical, and commercial security of relevant persons with whom we maintain a business relationship.
• Tracking and execution of legal affairs.
• Execution of financial and/or accounting transactions.

d) Recipients and Purposes of Processed Personal Data

Without requiring the explicit consent of the relevant person, under Article 8(2)(a) of the Law on the Protection of Personal Data (KVKK), your personal data will be transferred for the purposes specified below:

• To ensure compliance with legal obligations arising from relevant legislation, it will be shared with the General Directorate of Security (Emniyet Genel Müdürlüğü).
• To conduct financial and/or accounting operations related to collecting fees for products and services; if necessary, it may be shared with notaries, enforcement offices, and/or courts.
• To fulfill legal obligations following relevant legislation, it may be shared with relevant public institutions and organizations, as necessary or upon request.
• To deliver lost and forgotten items at the hotel, it will be shared with a contracted courier company.
• To enable tracking legal processes, it may be shared with our lawyers to the extent required by the confidentiality policy.

e) Method and Legal Basis of Personal Data Collection

Following legal grounds specified in Articles 5(2) and 6(2) of the KVKK, your personal data is collected through automatic or non-automatic methods, verbally, in writing, or through electronic media to fulfill the purposes stated in paragraph (c) of this notice:

• By filling out forms, sending emails, making phone calls, visiting the website, and contacting through social media platforms by the relevant person.
• By sharing data through online sales platforms, tourism agencies, event organizing companies, business card exchanges during fairs or seminars, and through partner institutions or organizations.

f) Your Rights under Article 11 of the KVKK

Under Article 11 of the Law on the Protection of Personal Data (KVKK), you have rights as the data owner. After completing all the information specified in the Relevant Person Application Form, following Article 11 and Article 13(1) of the KVKK and the Statement on Application Procedures and Principles to Data Controller, you can submit your requests regarding your rights through the following methods:

• By personally visiting our Company at “Katip Kasım Mh. Langa Hisarı Sk. No: 20, Yenikapı / Fatih / Istanbul / TÜRKİYE”.
• By sending an email to our registered electronic post (KEP) address, ngtasarimotelcilik@hs02.kep.tr.
• By submitting a written request through a notary or by registered mail to ensure identification and prevent disclosure to unauthorized individuals.
• By sending an electronic mail to info@delbabhotel.com using a secure electronic signature or the electronic mail address you have previously provided to our Company and registered in our systems.

g) Retention Period of Personal Data

Delbab Hotel deletes, destroys, or anonymizes personal data when the purpose of processing ceases and follows mandatory retention periods determined by laws and relevant regulations.

h) Amendments and Updates

This Clarification Text has been prepared following Law No. 6698 on the Protection of Personal Data and other relevant legislation. Necessary changes may be applied to this Clarification Text following changes in the relevant legal regulations and/or Delbab Hotel’s personal data processing purposes and policies.