CLUB HOTEL PHASELIS ROSE - SELÇUKLU TURİZM VE İNŞAAT A.Ş.

EXPLANATORY NOTE ON PERSONAL DATA PROCESSING

Club Hotel Phaselis Rose-Selçuklu Turizm ve İnşaat A.Ş. ("Phaselis Rose" for short) attaches importance to the security of your personal data and pays utmost attention and care to the processing of the personal data of its visitors, customers, suppliers and relevant persons with whom it cooperates in accordance with Personal Data Protection Law No. 6698 ("KVKK") and relevant legislation. Acting in the capacity of a data controller, we inform you with this explanatory note about the legal basis of our operations and transactions rated as personal data processing activities and about the rights / obligations of the parties.

1. Purposes of personal data processing

Your personal data are processed for fulfilling legal obligations of Phaselis Rose as well as of real and legal entities who are in business relations with Phaselis Rose; informing about legal changes and updates; making and executing contracts and reminding of / fulfilling legal obligations; following contract processes and / or legal claims; informing about changes in legislation and internal policies of the company as well as making other notifications with regard to the customers; ensuring the security and control of all electronic and physical media; investigating, preventing and reporting violations of legislation and contract breaches to competent authorities; fulfilling obligations related to the retention, reporting and notification of information stipulated in legislation and by legal authorities; executing / following financial, accounting and legal affairs; carrying out advertising, marketing and promotional activities; following / responding to your requests, complaints and questions; planning customer loyalty and satisfaction activities and taking opinions by conducting surveys / polls in this regard; determining products, projects and services suitable for our customers and customizing / developing them; providing effective customer communication / service; sending messages related to special occasions, birthdays, congratulations, greetings, wishes, drawings, competitions, sponsorships, promotions, product introductions and campaigns; ensuring participation in drawings or competitions; carrying out gift-giving, promotion and campaign activities; organizing various events, arrangements and invitations in order to support and develop customer relations and to increase awareness in this regard; informing via e-mail, SMS and fax; informing our customers about promotions, product introductions and campaigns; sending printed bulletins, magazines and messages/information on campaigns to our customers; determining visitor profiles and conducting human resources policies of Phaselis Rose.

2. Method and legal basis for personal data collection

Your personal data are collected on physical and electronic media by automatic and / or non-automatic methods for the purposes stated above and in accordance with the basic principles of KVKK.

The legal reasons for personal data processing activities carried out by Phaselis Rose are as follows: if it is explicitly stipulated in the laws; if it is necessary to process the personal data of the contracting parties provided that it is directly related to the execution or performance of the contract; if it is mandatory in order for Phaselis Rose to fulfil its legal obligations; if such personal data have been made public by the related person; if an explicit consent by the related person has been given; if data processing is mandatory for the establishment, use or protection of rights; if it is required or made mandatory by legal regulations in order to fulfil the demands of public institutions and organizations; if it is obligatory for the legitimate interests of Phaselis Rose, provided that the fundamental rights and freedoms of the related person are not damaged.

3. Who has access to personal data and to whom such data are transferred?

Only authorized persons have access to records, camera records and other processed data recorded and stored on physical and / or digital media. In line with the principles and procedures specified in the law and in accordance with the Policy on the Protection and Processing of Personal Data, the records and processed personal data recorded and stored on physical and / or digital media are shared with judicial bodies, legally authorized public institutions and organizations and authorized third parties.

Phaselis Rose processes personal data in accordance with articles 8 and 9 of KVKK and within the framework of the data processing purposes stated above. In this context, the personal data is transferred to our business partners, company officials, shareholders, group companies, legally authorized public institutions and private persons in order to ensure that the activities carried out by Phaselis Rose are carried out in accordance with the relevant legislation and company procedures and in order to carry out necessary operational activities by our business units. Personal data transfer can be transferred to third parties in the country and abroad, limited to and in accordance with the purposes specified in KVKK and in the Policy on the Protection and Processing of Personal Data.

4. Maintaining the security and storage of personal data

The security of personal data received in the result of personal data processing carried out by Phaselis Rose is provided in accordance with Article 12 of KVKK and necessary technical and administrative measures are taken in this regard. The authorized persons with access to the records of Phaselis Rose declare and undertake that they will protect the confidentiality of the accessed data. The personal data received in the result of personal data processing are stored for a reasonable period in accordance with legislation.

During the retention period, your personal data can be transferred to judicial bodies and authorized public institutions and organizations in order to contribute to the resolution of disputes, fulfil legal obligations and in line with the legitimate interests of Phaselis Rose.

5. Rights of relevant persons whose personal data are processed

In accordance with Article 11 of KVKK, each person concerned has the following rights regarding his/her personal data: to learn whether her/her personal data are processed by Phaselis Rose or not; to request relevant information if his/her personal data have been processed; to learn the purpose of processing his/her personal data and whether his/her data are used for such purpose or not; to know the third parties to whom his/her personal data have been transferred; to demand data correction if his/her personal data are incomplete or incorrectly processed; to request the deletion or destruction of his/her personal data in accordance with legislation; to object to negative results against the person concerned in the result of personal data analysis, to demand the compensation of damages incurred due to the processing of personal data in violation of the law.

In order to use the above-stated rights, fill in the form at http://www.phaselisrose.com/kvkk-3.html and send your request containing your name, surname, signature (for written applications), T.R. ID number (for Turkish citizens), nationality and passport or identification number, if any (for foreigners), place of residence or workplace for notifications, e-mail address for notifications (if any), phone and fax number, subject of the request, explanations about the right you want to use and necessary documents (if any) to the following address: Kuşbakışı Cad. No:37 Altunizade Üsküdar / Istanbul in person or via notary or send a signed copy of the form to the following e-mail address: info@phaselisrose.com using the registered electronic mail (KEP), secure electronic signature, mobile signature or e-mail address previously notified to Phaselis Rose and registered in the system of Phaselis Rose.

Faithfully yours,

Club Hotel Phaselis Rose- Selçuklu Turizm ve İnşaat A.Ş.