CAJA LIVING (MRA TURIZM VE OTEL ISLETMECILIĞI A.S.)

PERSONAL DATA PROTECTION AND PRIVACY POLICY

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.

PURPOSE OF PERSONAL DATA PROTECTION AND PROCESSING POLICY

Until today, data and information of 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 MRA Turizm. 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 ‘’MRA Turizm’’, we undertake to adhere to all responsibilities of Privacy Act. The principle of our companies to protect personal data also covers our subsidiaries.

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 are removed from the scope of personal data and anonymized. These data are used for statistical purposes and not subject to the enforcement of Law and our Policy. “Personal Data Protection and Implementation Policy of MRA Turizm” 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.

PURPOSE OF DATA PROCESSING

Collection and processing of personal data by “MRA Turizm” 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.

GENERAL PRINCIPLES ON PROCESSING OF THE PERSONAL DATA

  1. a) Being in compliance with the law and good faith: “MRA Turizm” 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 “MRA Turizm” to protect the personal data.
  2. b) Being accurate and up to date, if necessary: “MRA Turizm” 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.
  3. c) Being processed for specified, explicit, and legitimate purposes: “MRA Turizm” 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.
  4. d) Being relevant, limited and proportionate to the purposes for which data are processed: “MRA Turizm” uses the data only for processing purposes and to the extent what the service requires.
  5. e) Being stored only for the time designated by relevant legislation or necessitated by the purpose for which data are collected: “MRA Turizm” 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 ‘’MRA Turizm’’ 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 “MRA Turizm” 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 “MRA Turizm” are processed as declared by the relevant persons as a rule. “MRA Turizm” is not obliged to check up on the accuracy of the data declared by the customers or the persons in touch with “MRA Turizm” 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 “MRA Turizm”. 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.

The company is obliged to keep your personal data accurate and up-to-date in accordance with the Law.

If your data is not correct or is changed in any way, we kindly ask you to update them by contacting us via the email you’ve provided to the hotel.

Application e-mail: [email protected]

(If your e-mail is not registered in our system, we won’t reply within the scope of the Laws. In that case, please fill out the application form on our website.)

Confidentiality and data security

Personal data are confidential and “MRA Turizm” 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 “MRA Turizm” 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.

DATA OF CUSTOMER, POTENTIAL CUSTOMER AND BUSINESS AND SOLUTION PARTNERS

As “MRA Turizm”, 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

“MRA Turizm” 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,

– During the stays at the hotel; making internal correspondence regarding guests who act against the Regulation on the Relations of Tourism Enterprises with the Ministry, Each Other and Their Customers, property rules and general rules of etiquette and preparing a list in line with this 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,

– 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.

SURVEY DELIVERY AND DATA PROCESSED WITH THIS FORM

Survey deliveries are made within the framework of ARTICLE 6 – (1) of the Law on the Regulation of Electronic Commerce No. 6563, regarding the commercial electronic message transmission clause.

Your valuable opinions will be processed in order to increase our existing service quality, collect plannings and insights regarding new services and enable property officials to evaluate the services they provide from your perspective. Your information, limited only to the e-mail address, will be shared with Related Marketing Cloud (RMC) and QuestionPro Survey Software companies in order to enable survey delivery.

In addition, our guests accept and undertake that they write their reviews according to their own experience, they are their own sincere opinions about the hotel, they have no personal or commercial ties to the property and no material/moral incentive or payment is offered to write such review.

E-INVOICE & 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 no. 6563 on the Regulation of E-Commerce and the Regulation on Commercial Communications and Commercial Electronic Messages. MRA Turizm complies with the details of ‘’the consent’’ specified in the same legislation. The consent for communication can be obtained in written in physical environment or via any kind of electronic communication channel. Some and/or all of information like Name, Surname, Activity, Agency, Loyalty card details, City, Country and E-mail address are shared in compliance with the service provider Related Marketing Cloud (RMC) and Law no. 6698 on Protection of Personal Data.

DATA PROCESSING DUE TO LEGAL OBLIGATIONS OF THE COMPANY OR BEING STIPULATED EXPLICITLY IN THE LAW

Personal data may be processed without obtaining separate approval for the purpose of explicitly stating the processing in the relevant legislation or fulfilling a legal obligation determined by the legislation. The type and scope of data processing must be necessary for the legally permitted data processing and must comply with the relevant legal provisions.

In this context, the consent that our guests has given to us to send e-mail will be shared with IYS which is the national database system where Service Providers can store and manage different types of message submissions like call, message and e-mails, the receivers can view and remove permissions, complain about unauthorized submissions, the public can view the message complaints and the status of the permission subject to the complaint, provide service over the website, short message number and call center, record all permissions with the stamp and store them securely in accordance with the Regulation no. 30998 published in the Official Gazette dated January 2020. If you wish, you can visit the IYS website via https://iys.org.tr for more detailed information on the subject.

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 PERSONAL DATA OF SPECIAL NATURE

According to the relevant laws, the following are considered personal data of a special nature: race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, attire and dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures, biometric and genetic data. ‘’MRA Turizm’’ takes the adequate measures determined by the Commission for the Processing of Personal Data of Special Nature.

MRA Turizm may only process data of special nature for the purpose for which it was collected and with the consent of the individual, in order to provide better services.

DATA PROCESSED WITH AUTOMATIC SYSTEMS

“MRA Turizm” 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, “MRA Turizm” may take decisions regarding the persons that it will perform process by using the data within the system.

PURPOSE OF COLLECTING AND PROCESSING SAFETY DATA FROM PROPERTIES

Security footages taken due to your visit to MRA Turizm 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.

DELETION, DESTRUCTION OR ANONYMIZATION OF PERSONAL DATA

Personal data obtained directly or indirectly in accordance with the data processing conditions in the Law are kept by the Company as per the law and good faith for the period stipulated by the relevant legislation or required by the purpose of processing.

The deletion, destruction or anonymization of personal data is regulated in Article 7 of the Law on Protection of Personal Data and according to this; data controller is liable to delete, destroy or anonymize the personal data in cases where the reasons for the processing no longer apply. The application of the relevant person is not required for this. However, in case of negligence of the data controller, the relevant person has the right to request the destruction or deletion of their personal data.

For further questions about our policy, you can contact us at [email protected]

TRANSFERRING OF THE PERSONAL DATA DOMESTICALLY AND INTERNATIONALLY

Personal data may be shared with business and solution partners and “ETS Ersoy Turistik Servisleri A.S. and VOYAG Turizm” subsidiaries for the purpose of providing the services by “MRA Turizm”.

“MRA Turizm” will be entitled to transfer the personal data for certain purposes to the following person and institutions;

» Business partners of “MRA Turizm” limited to the purpose of execution of the aims of the establishment of the business partnership,

» The suppliers of “MRA Turizm” to the extent of providing the necessary services by our company to fulfil its commercial activities and procured by the supplier as external sources,

» Solution partners of “MRA Turizm” limited to ensuring the execution of the commercial activities which require the participation of the affiliates of the company,

» Subsidiaries of “Ets Ersoy Turistik Servisleri A.S.”

» Subsidiaries of “Voyag Turizm”.

“MRA Turizm” 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.

RIGHTS OF THE RELEVANT PERSON

“MRA Turizm” 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 “MRA Turizm”;

  1. a) To be informed whether his/her personal data are processed or not,
  2. b) To request information if the personal data are processed,
  3. 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,

  1. d) In case the personal data are processed incompletely or inaccurately, to request the correction,
  2. e) To request that personal data are deleted or removed within the framework of the conditions stipulated in article 7,
  3. 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,
  4. 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. “MRA Turizm” 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.cajaliving.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. “MRA Turizm” can only request information and document from the application holders.

CONFIDENTIALITY PRINCIPLE

The data of the employees and other persons within “MRA Turizm” are confidential. Nobody can use, copy, reproduce, transfer these data for other purposes apart from the business purposes without the compliance with the contract or the law.

PROCESS SECURITY

All necessary technical and administrative measures are taken to protect the personal data received by “MRA Turizm” 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. Measures related with the security are constantly renewed and developed.

NOTIFICATION OF VIOLATIONS

“MRA Turizm” 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 www.cajaliving.com/en/kvkk

Requests made pursuant to the Act on the Protection of Personal Data

As announced on www.cajaliving.com/en/kvkk 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:

MRA Turizm reserves the right to make changes on the declarations here.

There is a link attached on the homepage of the website to access the up-to-date ‘Personal Data Protection and Privacy Policy’.

When the last time this Policy was updated and update number are given at the end of this text.

Each change made on the Policy 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.

Policy Update: Aug 9, 2022 Rev.1.1

CONTACT

You can contact us for further questions on the confidentiality agreement by using the following contact information.

Maxx Royal Resorts & Voyage Hotels

Central Sales and Marketing Office

Güzeloba Mah. 2134 Sokak No:30/101

07230 Muratpasa / Antalya

TURKEY