Clarification Text on Processing Personal Data

A. PURPOSE OF PERSONAL DATA PROTECTION AND PROCESSING POLICY:

As Billurcu Otelcilik Turizm ve Sanayi Anonim Şirketi (the “Company”), in accordance with the Law on the Protection of Personal Data No.6698 (“KVKK”), this “Information” letter, which we have prepared as a Data Controller, provides you with the “Data Supervisor” Within the framework of Article 10 titled “Obligation of Disclosure” and Article 11 titled “Rights of the Related Person”; For what purpose your personal data will be processed, to whom and for what purpose your processed personal data can be transferred, the method and legal reason for the collection of your personal data and your other rights listed in Article 11 of the KVKK: As a Data Controller, your personal data as we have explained below and We process, record, transmit, share and store within the limits ordered by official legislation. Our company reserves the right to update this “Information Text on Protection of Personal Data” at any time within the framework of the changes that can be made in the current official legislation.

B. COLLECTION, PROCESSING AND PROCESSING PURPOSES OF PERSONAL DATA:

Our company, which operates in the fields specified in detail in the Company’s Articles of Association, due to these activities; Your verbal, written or electronic personal data are collected and processed due to the regulations of the Tourism and Revenue Administration and other related institutions and the contracts we have concluded. This personal data will be used to provide services related to the fields of activity of our company and to increase the quality of these services, to fulfill our company’s sales, marketing and other activities, to comply with information storage, reporting and information obligations. In addition, your personal data can be used within the scope of activities such as CRM (Customer Relations Management) applications to be made for sales and marketing activities, as well as to increase the quality of our service we offer to you. Your personal data will not be used for purposes other than those stated above without your explicit consent, and will not be shared or transferred to third parties except for legal obligations and official institutions / organizations. Our company only collects your personal data; KVKK art, especially with the express consent of the customers or the legislation we are subject to. In other cases stipulated in 5 / f.2, in order to provide value-added services, opportunities and opportunities to our customers and to increase the service quality, we do not use this data with our domestic or foreign affiliates and directly or indirectly affiliated companies and joint ventures or as a legal requirement. with the public institutions or organizations authorized to request and with the institutions, suppliers, authorized dealers / dealers / business partners in the country or abroad as per our activities, provided that adequate measures are taken. Although your personal data may vary depending on the services, products or commercial activities provided by our Company; It can be collected verbally, in writing or electronically through offices, branches, dealers, call center, website, social media channels, mobile applications and similar tools, automatically or non-automatically. As long as you benefit from our company’s products and services, your personal data can be processed by creating and updating. Also, with the intention of using the services of our Company;

• When you use our call center or website,

• When you visit our company, website or social media channels / channels,

• Your personal data can be processed when you attend the training, seminars or organizations organized by our company.

your consent has been obtained from you or cause compliance with other legal requirements as expressed in the laws of the Republic of Turkey personal data; (i) Our business units can do the necessary work to benefit you from the products and services offered by our company; (ii) The products and services offered by our company are customized according to your tastes, usage habits and needs and recommended to you; Ensuring the legal and commercial security of our company and those who are in business relations with our company (administrative operations for communication carried out by our company, ensuring the physical security and control of the company’s locations, business partner / customer / supplier (authorized or employees) evaluation processes, legal compliance process, financial works etc. Improving the services offered by our company and improving our quality policy.to be informed and to benefit from promotions, discounts, promotion and similar advantages; (vi) To be able to process your personal data, your preferences, your transactions and the data obtained along with your browsing time, in order to provide you with the information and services you have requested when you log in with your username and password in order to receive services from the channels offered by our company; To be able to make notifications (renewal, termination, etc.) regarding the website memberships of our Company and its associated companies / organizations with any loyalty card issued and / or to be issued by our company and its associated companies / organizations, any communication that may be established with you, and the new service to be offered and to inform about changes, innovations and similar issues that may occur in products, personal data policies and membership conditions; To inform you about the information, activities and services you request from our company; Determination and implementation of our company’s commercial and business strategies; In order to ensure the execution of the human resources policies of our company and to fulfill a legal obligation specified in the legislation or if necessary, within the terms and purposes of personal data processing specified in Articles 5 and 6 of the KVK Law, our Company and its associated companies / organizations are ) Can be processed by other real and / or legal persons specified in the article.

C. METHOD AND LEGAL REASON OF COLLECTING PERSONAL DATA:

Your personal data is obtained in any verbal, written or electronic environment, in line with the purposes stated in the above articles, in order to provide our products and services within the determined legal framework and within this scope, our Company to fulfill its obligations arising from the contract and the law completely and correctly. Your personal data collected for this legal reason are processed, recorded, transferred, shared and stored for the purposes specified in article (B) of this text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVK Law.

D. PROCESSING SPECIAL QUALITY DATA:

According to the Law on the KVK, people’s race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, dress and dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures data and biometric and genetic data are personal data of special nature. Our company takes adequate measures in the processing of special quality data, as well as the measures determined by the Personal Data Protection Board. In order to provide better service, our company will only process personal data with the consent of the relevant person and only for the purpose of collection.

E. TO WHOM AND FOR WHICH PURPOSE THE PROCESSED PERSONAL DATA MAY BE TRANSFERRED:

Your collected personal data will be sent to Billurcu Otelcilik Turizm ve Sanayi A.Ş. to serve the purposes specified in Article (B). In addition, it can be transferred to our shareholders, business partners, suppliers, legally authorized public institutions and private persons within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVK Law.

F. TRANSFER OF PERSONAL DATA ABROAD: & nbsp;

Our company has the authority to transfer personal data abroad within the conditions determined by the Personal Data Protection Board in the KVK Law, in accordance with other conditions in the law and after obtaining the express consent of the person for this purpose.

G. RIGHTS OF THE PERSONAL DATA OWNER SET IN ARTICLE 11 OF THE KVK LAW:

Within the scope of the KVK Law, we acknowledge that the person concerned has the right to be informed and consented before the processing, recording, transfer, sharing and storage of his personal data, and that he has the right to determine the fate of his data after the data is processed, recorded, transferred, shared and stored. In this context, if you submit your requests regarding your rights as personal data owners to our Company with the methods set out below in this “Clarification Text on Processing Personal Data, our Company will finalize the request free of charge within thirty days at the latest, depending on the nature of the request. a) Pursuant to the Communiqué on Application Procedures and Principles to the Data Controller published by the Personal Data Protection Board, if your application will be answered in writing regarding your requests regarding your rights as personal data owners,

• Up to ten pages are not charged. A transaction fee of 1 Turkish Lira may be charged for each page above ten pages

• If the response to the application is given in a recording medium such as CD or flash memory, the fee recording medium that may be requested by our Company as the data controller can not exceed its cost. In this context, personal data owners;

• Learning whether personal data is being processed,

• Requesting information if personal data has been processed,

• Learning the purpose of processing personal data and whether they are used appropriately for their purpose,

• To know the third parties to whom personal data is transferred domestically or abroad

• To request correction of personal data in case of incomplete or incorrect processing and to request notification of the transaction made within this scope to third parties to whom personal data are transferred,

• To request the deletion, destruction or anonymization of personal data within the framework of the conditions stipulated in Article 7 of the KVK Law and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,

• Object to the occurrence of a result against the person himself by analyzing the processed data exclusively through automated systems,

• Has the right to demand the compensation of the damage in case of damage due to the processing of personal data illegally.

However, individuals do not have a right to anonymized data within the Company. Our company will be able to share personal data with relevant institutions and organizations in order to exercise the legal powers of a judicial duty or state authority in accordance with the business and contract relationship.

H. PERIOD WHERE YOUR PERSONAL DATA WILL BE PROCESSED:

In accordance with the KVK Law, your personal data processed for the purposes specified in this “Clarification Text on the Processing of Personal Data”, when the purpose required to be processed according to KVK Law article 7 / f.1. Your personal data will be deleted, destroyed or anonymized and continue to be used when the time-out periods we have imposed are over.

İ. SITUATIONS WHERE OUR COMPANY MAY PROCESS YOUR PERSONAL DATA REQUIRED BY LAW WITHOUT YOUR EXPRESS CONSENT:

Pursuant to Article 5 of the KVKK, our Company may process your personal data as stated above and received in accordance with the law, without seeking your express consent:

• If you are unable to disclose your consent as a data owner due to the actual impossibility, or in cases where your consent is not legally valid, it is compulsory to process your personal data for the protection of your own or someone else’s life or body integrity,

• It is necessary to process personal data belonging to the parties of the contract, provided that our company and its associated companies / organizations are directly related to the establishment or performance of a contract you have concluded with other real and / or legal persons specified in Article (C),

• It is mandatory for our company to fulfill a legal obligation,

• Your personal data are made public by you,

• Data processing is mandatory for the establishment, use or protection of a right,

• Data processing is mandatory for the legitimate interests of our Company, provided that it does not harm your fundamental rights and freedoms.

J. TO REQUEST ACCORDING TO THE PROTECTION OF PERSONAL DATA:

In accordance with the 1st paragraph of Article 13 of the KVK Law, you can submit your request to use your above-mentioned rights to our Company by the method (s) determined / determined by the Personal Data Protection Board. Alternatively, if you wish, you can submit your application in writing to our Company in accordance with the KVK Law. 6698 numbered Law Art. You can always contact us by sending an e-mail to contact [at] billurcu.com in order to use your rights stated in 11. Only this e-mail address should be used in matters related to your personal data, and requests and notifications from channels other than this address will not be taken into consideration. Rights regarding personal data can only be used for personal data. Requests for data of persons other than the person who filled out the form and have official documents identifying you in the attachment will not be taken into consideration. Forms that do not include official documents that identify your identity will not be taken into consideration. Even when data deletion requests are fulfilled, we inform you that we are obliged to share data with official authorities if requested by official authorities.