Website Confidentiality Agreement
During your visit to this website and your use of the service through this
Site, how the information that we receive regarding you and the services you
request will be used and protected are subject to this ‘’Confidentiality
Agreement’’. You hereby accept the conditions stipulated in this
‘’Confidentiality Agreement’’ when you visit this website and request to use
the services we provide through this Site.
I. Purpose of personal data protection and processing policy
Until today, data and information about our customers or potential customers are
kept confidential and have never been shared with third parties by virtue of
the sensitivity of our business as Tekirova Turizm Yatırımları A.Ş.. Personal
Data protection is our essential policy. Even before any legal regulation, our
company and subsidiaries had attached a great importance to the confidentiality
of personal data, adopted as a working principle and gave working instructions
to the employees in compliance with this principle. As ‘’ Tekirova Turizm
Yatırımları A.Ş..’’, we undertake to adhere to all responsibilities of Privacy
Act. The principle of our companies to protect personal data also covers our
subsidiaries.
II. Scope and change of personal data protection and implementation
policy
This policy, prepared by our company, has been regulated in accordance with “Law
on Protection of Personal Data” no. 6698 (“KVKK”). The Law has entered into
force with all of its provisions as of today. The data received with your
consent or pursuant to the other regulations as per to the Law shall be used to
make our service more quality and to improve our services and quality policy.
Again, some of the data we obtain is removed from the scope of personal data
and anonymized. These data are used for statistical purposes and are not subject to
the enforcement of Law and our policy, “Personal Data Protection and
Implementation Policy of Tekirova Turizm Yatırımları A.Ş..” aims and regulates
the protection of the data which are automatically obtained from our customers,
potential customers, employees and the customers and employees of the companies
in cooperation with us for solution partnership and the other parties.
Our company reserves the right to change our Policy and Regulation – provided
to comply with the Law and protect the personal data in a better way.
III. General principles on processing of the personal data
a) Being in compliance with the law and good faith: “Tekirova Turizm
Yatırımları A.Ş..” questions the source of the data it collects or sent by
other companies and attaches importance to handling these in compliance with
the law and good faith. Within this framework, it warns and notifies the third
parties (agencies and other intermediary firms) that sell the services provided
by “Tekirova Turizm Yatırımları A.Ş..” to protect the personal data.
b) Being accurate and up to date, if necessary: “Tekirova Turizm Yatırımları
A.Ş..” attaches importance to the accuracy of all of the data kept within the
organization, to the fact that they don’t include any misinformation and that
personal data are updated only if the changes are notified.
c) Being processed for specified, explicit, and legitimate purposes: “Tekirova
Turizm Yatırımları A.Ş..” processes the data limited to the services and
purposes for which consent of the persons are taken during the services. It
shall not process, use and make use of the data out of business purposes.
d) Being relevant, limited and proportionate to the purposes for which data are
processed: “Tekirova Turizm Yatırımları A.Ş..” uses the data only for
processing purposes and to the extent what the service requires.
e) Being stored only for the time designated by relevant legislation or
necessitated by the purpose for which data are collected: “Tekirova Turizm
Yatırımları A.Ş..” keeps the contractual data as long as it’s required by the
commercial and taxation law as well as the periods of conflicts of law.
Nevertheless, it shall delete or anonymize the data in case the reasons
necessitating their processing cease to exist.
It’s crucial to state that whether “Tekirova Turizm Yatırımları A.Ş..” collects
or processes the data by one’s will or in compliance with the law, the
abovementioned provisions shall apply anyhow.
Maximum Savings Policy/Scrimping Policy
Pursuant to our policy called as maximum savings policy or scrimping policy,
the data received by “Tekirova Turizm Yatırımları A.Ş..” are processed into the
system as required. Thus, which data we will collect shall be determined
according to the purpose. Unnecessary data shall not be collected. Other data
submitted to our company are transferred to the information system of the
company in the same way. Redundant information is not stored in the system,
they are deleted or anonymized. These data may be used for statistical
purposes. Health data among the special quality data are only kept in the
system to provide better service to the customers and to protect their
health.
Deletion of personal Data
When the retention period necessitated by the Law expires, judicial procedures
are completed or other requirements no longer exists, these data shall be
deleted, removed or anonymized automatically, by the company or upon the
request of the relevant person.
Accuracy and Currency of Data
The data within the body of “Tekirova Turizm Yatırımları A.Ş..” are processed
as declared by the relevant persons as a rule. “Tekirova Turizm Yatırımları
A.Ş..” is not obliged to check up on the accuracy of the data declared by the
customers or the persons in touch with “Tekirova Turizm Yatırımları A.Ş..” and
it’s also contrary to the Laws and our working principles. The declared data
are regarded as correct and accurate. The principle of accuracy and currency of
personal data has also been adopted by “Tekirova Turizm Yatırımları A.Ş..”. The
personal data processed upon the request of the relevant person or from
official documents that are submitted to our company are updated. Necessary
precautions are taken for this purpose.
Confidentiality and data security
Personal data are confidential and “Tekirova Turizm Yatırımları A.Ş..” obeys
the rule of confidentiality. Only authorized persons shall access the personal
data. All necessary technical and administrative measures are taken to protect
the personal data collected by “Tekirova Turizm Yatırımları A.Ş..” and to
prevent the damage on our customers and potential customers. Within this
framework, it shall be ensured that the software complies with the standards,
third parties are selected with caution and data protection policy is observed
within the company.
IV. Purpose of data processing
Collection and processing of personal data by “Tekirova Turizm Yatırımları A.Ş..”
shall be executed in line with the purposes stipulated in the letter of
clarification. The data are collected and processed to draw up contracts and
provide better services to the customers.
V. Data of customer, potential customer and business and solution
partners
As “Tekirova Turizm Yatırımları A.Ş..”, we process your personal data in
the capacity of data supervisor within the scope of Personal Data Protection
Law no. 6698 and other relevant legislations.
In this sense, categories and explanations of personal data to be processed
are as follows:
· Identity Information: Name-surname,
name-surname of companying guest/guests; nationality, birth place and date,
T.R. Identity, driver’s license and passport numbers (including date and place
of issue).
· Contact Information: Address,
telephone number, e-mail address.
· Financial Information: Mobile
invoice information, bank account information, payment card information,
Loyalty Program memberships, information about purchased product or services.
· Customer reviews, feedbacks and complaints: Special preferences in accommodation, marketing and communication fields;
reviews, opinions or complaints about the brands and properties.
· Other: Reservation details, travel history;
information on participation in competitions, draws or marketing programs,
information of vehicles used to access the property; booked hotel, airline and
rental car packages; associated groups to stay in the properties,
frequent-flyers or Travel Partnership Program memberships and member numbers,
information provided during membership and account applications.
Collection and processing of data for contractual relationship
In case of a contractual relationship with our customers and potential
customers, the collected personal data may be used without the approval of the
customers. However, this use shall be for the purpose of the contract. The data
shall be used for better execution of the contract and as required by the
services and updated, if necessary, by contacting the customers. Nevertheless,
the data provided to us by our potential customers shall be processed to easier
and more quality services later. These data shall be deleted upon requests in
case of lack of any contractual relationship.
Data of Business and Solution Partners
“Tekirova Turizm Yatırımları A.Ş..” adopts as a principle to act in compliance
with the laws when exchanging the data both with business and solution
partners. The data are shared with the business and solution partners with the
understanding of data confidentiality and as required by the services and it’s
definitely ensured that these parties take measures regarding the data
security.
Processing data to manage, analyse and improve the services provided in the
properties
· Carrying out a questionnaire study with the aim of measuring the services
provided,
· Communicating with guests for marketing purposes in line with the
communication permits within the scope of miscellaneous laws,
· Exchanging internal correspondences with guests violating the property and
general codes of conduct during the accommodations at the hotel and preparing a
list in line with these information,
· Recording the comments of guests on social media, blogs, review portals
etc. into the system to analyse the feedback of the service provided,
· Carrying out Sales and Marketing activities to offer a tailor-made holiday
experience by processing the data of services provided to the guests.
Managing relations with guests before, during and after the
accommodation
· Calling guests before check-in,
· Customer Loyalty Program management,
· Answering questions of guests on Loyalty Program, card categories, how to
upgrade your card etc.,
· Doing segmentation by analysing the data about reservation history, travel
preferences and services purchased with the aim of correctly managing the
marketing activities,
· Managing allegations/complaints about our properties and services on review
portals, complaint pages, social media etc.,
· Keeping personal information of guests up-to-date and combining with data
to be obtained from third party sources for analytical purposes.
E-invoicing & E-Archive Invoice
Within the scope of this program, customer is automatically enrolled in
e-invoicing program and invoices are sent to the e-mail address he/she has
provided to the property. It’s the responsibility of the customer to
ensure that the e-mail address is accurate and preferred one for this
communication, which is provided during check-in or updated later. If a
reservation is made for another family member or other persons using this
e-mail address, e-invoice of the relevant invoice is sent to the
address of the e-mail address.
E-Invoice is an invoice that is issued in electronic environment, not
printed on the paper and sent to the receiver and/or vendor through the
servers. It has entered into force with TPL communique with order no. 397 of
Turkish Republic’s Tax Procedure Law and has been put into practice since March
5, 2010.
As per TPL, e-Invoice contains all information required to be present in an
invoice and mutual invoice submission between the receiver and vendor are
realized in electronic environment.
E-Archive Invoice is an implementation that ensures the invoice which must
be issued, kept and submitted on paper as per Tax Procedure Law is issued in
electronic environment and its secondary copy is kept and submitted in
electronic environment in compliance with General Communique on Tax Procedure
Law with order no. 433. In e-Archive Invoice, all invoices except for the
invoices issued for taxpayers registered in e-Invoice Implementation are
designated as e-Archive Invoice.
Data processing for advertisement purposes
Electronic messages for advertisement purposes can only be sent to the persons
with prior consent in compliance with the Law on the Regulation of E-Commerce
and the Law on Commercial Communication and Commercial Electronic Messages. An
explicit consent of the person is required to send advertisements. “Tekirova
Turizm Yatırımları A.Ş..” obeys the details of ‘’the consent’’ specified in the
same legislation. The consent to be obtained should cover all commercial
electronic messages that are sent to the electronic communication addresses of
the recipients to promote and market the goods and services of the company, to
promote the business or to increase the recognition level of the company with
contents including greetings and wishes. This consent may be obtained via any
electronic communication channel or at physical medium in written. The
important thing is to obtain the declaration of the recipient that he/she
accepts to receive commercial electronic messages and to have his/her full name
and electronic communication address.
Data processing due to legal obligations of the company or being stipulated
explicitly in the Law
Personal data may be processed without prior consent when it’s stipulated
explicitly in the relevant legislation or to fulfill a legal obligation
specified in the legislation. Type and scope of the data processes are required
for data processing activity that is permitted by the Laws and they should
comply with the relevant legal provisions.
Data processing of the company
Personal data may be processed pursuant to the legal purposes and the services
of the company. However, the data shall not be used for services contrary to
the laws under any circumstances.
Processing of special quality data
Pursuant to the Law, race, ethnic origin, political opinion, philosophical
belief, religion, sect or other beliefs, clothes, membership of association,
foundation or union, health, sexual choice, juridical sentence and data
regarding safety measures and biometric and genetic data are among the special
quality data. “Tekirova Turizm Yatırımları A.Ş.. ” also takes adequate measures
determined by the Board for the processing of special quality data.
“Tekirova Turizm Yatırımları A.Ş.. ” may process the special quality data only
for the corresponding purposes to provide better services.
Data processed with automatic systems
“Tekirova Turizm Yatırımları A.Ş..” acts in compliance with the Law for data
processed with automatic systems. The information obtained from these data
without the explicit consent of the persons shall not be used against the
person. However, “Tekirova Turizm Yatırımları A.Ş..” may take decisions
regarding the persons that it will perform process by using the data within the
system.
User Information and Internet
In case of the collection, processing and use of personal data on the websites
and other systems or applications belonging to Tekirova Turizm Yatırımları A.Ş..
the related persons shall be informed about the privacy statement and cookies
if needed. Users shall be informed about our applications on our websites.
Personal data shall be processed as per the law.
We kindly submit the below mentioned information about the cookies that we
use/will use on our pages when you visit our website.
Google (analytics, doubleclick)
Purpose of Use of Cookies : Measurement Advertisement In-site optimization
Type of Cookies : Functional and analytic cookies Commercial cookies
Facebook
Purpose of Use of Cookies : Advertisement
Type of Cookies : Commercial cookies
Insider
Purpose of Use of Cookies : Measurement Advertisement In-site optimization
Type of Cookies : Functional and analytic cookies Commercial cookies
Hotjar
Purpose of Use of Cookies : Measurement In-site optimization Functional and
analytic cookies
Type of Cookies : Commercial cookies
3rd party companies (criteo, rtbhouse)
Purpose of Use of Cookies : Advertisement
Type of Cookies : Functional and analytic cookies Commercial cookies
Functional and Analytic cookies
Cookies includes the data about
reminding your choices, using website effectively, optimizing the website so as
to answer the demands of the user and how the visitors use the website. By
qualification, these kinds of cookies may consist of personal information such
as user name.
Third Party Cookies
Websites/mobile applications/mobile websites belonging to Tekirova Turizm
Yatırımları A.Ş.. works with third party reliable and known advertisement
providers Third party service providers place their own cookies to offer
advertisements special to you. The cookies placed by third party collect,
process the surfing information of the visitors on the websites and analyze
them according to the ways of use.
Commercial cookies
Commercial cookies serve to offer the product/content with similar qualifications
and enhance your usage experience by providing a developed and customized
advertisement portfolio according to your fields of interest and choices. The
holdup time of the session, permanent, functional and analytic and commercial
cookies on the background is about 2 (two) months and the required settings can
be done by browser settings. The removal operation, one of the settings, can be
changed by means of the browser.
During your reservation process if your transaction is not completed due to
errors or failures in the system, our call center representative will contact
you.
How to clear cookies?
Many browsers are adjusted automatically to accept and use the cookies as of
the first installment of your computer. You are allowed to block the cookies or
to be warned about the cookies by using help or setting menus of your browser.
You can take advantage of the instruction or help option screens of your
browser to obtain further information about the various methods of managing
cookies or regulate the settings of your browser.
Purpose of Collecting and Processing Safety Data from Properties
Security footages taken due to your visit to Royal Diwa Tekirova Resort that act in the
capacity of data controller within the scope of Law no. 6698 are collected to
ensure security of both you and our company and to provide service to you
securely.
Your personal data are not used for the purposes other than stated and
processed based on the cause of action of the data controller for its
legitimate interests as per clause (f) of article 5/2 of The Law on Protection
of Personal Data. Collected personal data cannot be shared with any third
person or entity pursuant to the rules. However, they can be shared to meet the
demands of state institutions and organizations authorized by law to fulfil the
legal obligations stipulated in clause (ç) of article 5/2 of the Law.
When the purpose of collecting your data isn’t deemed valid anymore, your data
will be destroyed.
VI. Data of our employees
Processing of the data for business relations
Personal data of the employees may be processed without obtaining consent
to the extent of requirements of health insurance and business relations.
However, “Tekirova Turizm Yatırımları A.Ş..” hereby undertakes the protection
and confidentiality of the data of the employees.
Processing as per Legal Obligations
“Tekirova Turizm Yatırımları A.Ş..” may also processes the personal data of the
employees without obtaining a separate consent to fulfill a legal obligation
stipulated in the legislation or in case it’s explicitly specified in the
legislation. This case is limited to the obligations arising from the
Law.
Processing in Favor of the Employees
“Tekirova Turizm Yatırımları A.Ş..” may process the personal data without
obtaining the consent for the procedures in favor of company employees like
private health insurances. For the disputes arising from the business
relations, “Tekirova Turizm Yatırımları A.Ş..” may also process the data of the
employees.
Processing of special quality data
Pursuant to the Law, race, ethnic origin, political opinion, philosophical
belief, religion, sect or other beliefs, clothes, membership of association,
foundation or union, health, sexual choice, juridical sentence and data
regarding safety measures and biometric and genetic data are among the special
quality data. Besides the consent of the relevant person, “Tekirova Turizm
Yatırımları A.Ş..” also takes adequate measures determined by the Board for the
processing of special quality data. Special quality data may be processed
limited to and related to the cases permitted by the Law without the consent of
the person. The quality data obtained from the employees shall only be used for
the corresponding purpose to allow them to benefit from the insurance and health
services.
Data processed with automatic systems
The data processed regarding the employees with automatic systems may be used
for in-house promotions and performance assessments. The employees reserve the
right to appeal to the results against them and they should perform this
process in compliance with the internal procedures. Appeals of the employees
shall be evaluated again within the company.
Telecommunication and internet
The computers, telephone, e-mail and other applications allocated to the employees
within the company shall only be used for business purposes. The employee
cannot use any of these means allocated to himself/herself by the company for
private purposes or communication. The company may control and monitor the data
on these means. The employee undertakes not to keep any data or information
apart from the business purposes on the computer, telephones or other means
allocated to himself/herself as of his/her employment date.
VII. Transferring of the personal data domestically and internationally
Personal data may be shared with business,solution partners and subsidiaries
for the purpose of providing the services by “Tekirova Turizm Yatırımları A.Ş.”.
“Tekirova Turizm Yatırımları A.Ş.” will be entitled to transfer the personal
data for certain purposes to the following person and institutions;
» Business partners of “Tekirova Turizm Yatırımları A.Ş.” limited to the
purpose of execution of the aims of the establishment of the business
partnership,
» The suppliers of “Tekirova Turizm Yatırımları A.Ş.” to the extent of
providing the necessary services by our company to fulfill its commercial
activities and procured by the supplier as external sources,
» Solution partners of “Tekirova Turizm Yatırımları A.Ş.” limited to ensuring
the execution of the commercial activities which require the participation of
the affiliates of the company,
“Tekirova Turizm Yatırımları A.Ş. ‘’ is authorized to transfer the personal
data domestically and internationally within the conditions determined by the
Board and in compliance with the other provisions in the Law and depending on
the consent of the person.
VIII. Rights of the relevant person
“Tekirova Turizm Yatırımları A.Ş.” hereby agrees that the relevant person must
provide his/her consent before processing the data within the scope of the Law
and he/she reserves the right to determine the destiny of the data after the
data is processed.
Regarding the personal data, the relevant persons holds the right to do the
following by applying to our official announced on the web page by “Tekirova
Turizm Yatırımları A.Ş.”;
a) To be informed whether his/her personal data are processed or not,
b) To request information if the personal data are processed,
c) To learn the purpose of processing the personal data and whether the data
are used for the corresponding purposes,
ç) To get information on the third parties to whom the personal data are
transferred in the country and abroad,
d) In case the personal data are processed incompletely or inaccurately, to
request the correction,
e) To request that personal data are deleted or removed within the framework of
the conditions stipulated in article 7,
f) To request that the processes performed as per clause (d) and (e) are
notified to the third parties to whom the personal data are transferred,
g) To appeal to the negative results against himself/herself arising from the
analysis of the data processed exclusively through the automatic systems,
ğ) In case the personal data are damaged due to the processing of the data
contrary to the Law, to request that the damages are indemnified.
Nevertheless, the persons don’t reserve any right on the anonymized data within
the company. “Tekirova Turizm Yatırımları A.Ş.” may share the personal data as
required by a juridical function or governmental authority as per the business
and contractual relationship.
The owners of the personal data shall submit their requests regarding the
above-mentioned rights to the following contact address by completely filling
out and putting their wet signatures on the application form given at www.royaldiwa.com, the official website of the company, through registered letter with
return receipt with the copies of their identity cards (only front page for
birth certificate). The applications shall be replied within the shortest time
according to the content of the application ow within 30 days at the latest
after the delivery to the company. You need to apply with registered letter
with return receipt. Besides, only the questions about you shall be replied and
any applications made regarding your spouse, relative or friends shall not be
accepted. “Tekirova Turizm Yatırımları A.Ş.” can only request information and
document from the application holders.
IX. Confidentiality Principle
The data of the employees and other persons within “Tekirova Turizm Yatırımları
A.Ş.” are confidential. Nobody can use, copy, reproduce, transfer these data
for other purposes apart from the business purposes.
X. Process security
All necessary technical and administrative measures are taken to protect the
personal data received by “Tekirova Turizm Yatırımları A.Ş.” and to prevent the
retention of them by unauthorized persons and to prevent the damage on our
customers and potential customers. Within this framework, it’s ensured that the
software complies with the standards, third parties are selected with care and
data protection policy is followed within the company.
XI. Inspection
“Tekirova Turizm Yatırımları A.Ş.” carries out the internal and external
inspections for protection of the personal data.
XII. Notification of Violations
“Tekirova Turizm Yatırımları A.Ş.” shall immediately act to remedy the
violations in case a violation of personal data is notified. It shall mitigate
or indemnify the damage of the relevant person. In case the personal data are
obtained by the unauthorized persons, this case should be immediately notified
to the Board of Personal Data Protection.
Regarding the notification of the violations, you can also make an
application as per the procedures provided at http://www.royaldiwa.com/kvkk/en-US
Requests made pursuant to the Act on the Protection of Personal Data
As announced on http://www.royaldiwa.com/kvkk/en-US to put your application into process, please complete the form
on the websites, attach a copy of your identity card, and send it to the
address written on the form via registered mail.
The rights concerning personal data will only be used for one's own data.
Requests regarding the personal data of others will not be taken into
consideration. Forms without identity card photocopies will not be taken into
consideration. Please be informed that even if data deletion requests are
fulfilled, we are required to share data with the authorities if requested.
Click for application form
Changes to Be Made in Personal Data Protection and Privacy Policy:
“Tekirova Turizm Yatırımları A.Ş.” reserves the right to make changes on
the declarations here. In case of any significant change in the declaration, a
link will be attached on the homepage of the website to access the up-to-date
declaration. Guests registered for any of our products or services may be
informed regarding this issue through the communication channel he/she has
provided to the properties. When the last time this declaration was updated and
update number are given at the end of this text.
Each change made on the declaration becomes effective upon the publication
of the changed declaration on the website. By using the website or any of our
products and services following such changes, you accept the changed
declaration that is effective at that time.
Contact
You can contact us for further questions on the confidentiality agreement
by using the following contact information.
Tekirova Turizm Yatırımları A.Ş.
Satış ve Pazarlama Merkez Ofisi
Yeşilova Mah. Aspendos Bulv. No:168-C Muratpaşa / Antalya / Turkey
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