Personal Data Processing and Protection Policy
Information Text Regarding Processing of Personal Data
A. Purpose of the Policy For Protection and Processing of Personal Data:
BHM Otelcilik A.S. (the “Company”) acting as the data controller, pay(s) utmost care and attention for the security of your personal data. Thanks to such awareness, we place great importance for ensuring that any and all kinds of personal data, owned by any person associated with our Company, including the individuals who benefit from our products and services, are processed, recorded, transferred, shared and stored in accordance with the Law Nr. 6698 on Protection of Personal Data ("LPPD").
Protection of personal data is among the fundamental policies of our Company, and since the time of its incorporation, our Company has at all times prioritized the confidentiality of personal data, and it has adopted such approach as a business principle and instructed its staff members as aligned with such principle, as well. Our Company acknowledges and warrants to comply with any and all liabilities as imposed by the LPPD. Being fully aware of such liability of us and acting as the Data Controller, we process, record, transfer, share and store your personal data as described herein below by us and in accordance with the limitations as prescribed by the statutory regulations.
Please feel free to contact us by making use of the contact details given herein below for your inquiries with respect to our Company's "Information Text Regarding Processing of Personal Data".
Application Address: Asmani Restaurant, Sirinyali Mah. Lara Cd. No:24 Muratpasa - Antalya / Turkey
E-mail for Application: firstname.lastname@example.org
Our Company shall be entitled to update this "Information Text Regarding Processing of Personal Data" at any time in accordance with the amendments that might be made with respect to the applicable statutory regulations.
B. Collection, Processing of Personal Data, and Purposes of Processing:
Our Company's policy for Protection and Confidentiality of Personal Data has been drawn up in accordance with the LPPD. Accordingly, your personal data may be collected verbally, in writing or electronically by means of automated or non-automated methods, offices, branches, call center, the website, social media channels, mobile applications and such other similar means, depending on the services, products or business operations provided by our Company. Your personal data may be processed upon being created and updated as long as you benefit from the products and services of our Company.
Also, your personal data may be processed if and when you;
a. Make use of our call center or website;
b. Visit our Company, facilities, units and any business at our facilities;
c. Visit our website or social media channels;
d. Participate in any training, seminar or organization held by our Company, for the purpose of benefiting from the products and services of our Company.
Your personal data, which has been obtained from you upon your consent or as per the legitimate causes as prescribed in the laws of the Republic of Turkey, may be processed by our Company and its affiliated Companies/subsidiaries and also by such other real and/or legal persons as indicated in the Section (E) herein below in accordance with the requirements and purposes for processing personal data as specified in Sections 5 and 6 of the LPPD for the purpose of;
a. performance of the activities, which are required for enabling you to benefit from the products and services offered by our Company, by our business units;
b. recommending and offering the products and services, which are provided by our Company, as being customized as based on your choices, habits of use and needs;
c. ensuring that the services offered by our Company are of higher quality and also enhancing our quality policy;
d. ensuring that you are informed about and benefit from the general and special campaign, promotion, publicity, discount and such other similar advantageous offers provided by our Company;
e. processing the data to be obtained together with your personal data, preferences, the processes you will have performed and the time you have spent on such medium while you log in with your user name and password for receiving service through any medium offered by our Company, for the purpose of providing you with the information and services you will have asked;
f. sending the notifications with respect to any and all kinds of loyalty cards, which are issued and/or will be issued by our Company and its affiliates/subsidiaries, and also the membership to the websites of our Company and its affiliates/subsidiaries (renewal, termination, etc.), and also notifying you of any and all kinds of communications that would be made to you, and also of any modification, new practice and such other similar matter with respect to the services and products, which would be offered newly, and also the personal data policies and the terms and conditions for membership;
g. ensuring the legal and business security of our Company and also the persons, which have a business relation with our Company (the administrative operations aimed at the communication carried out by our Company, and ensuring the physical security and supervision of the locations owned by the Companies, and the assessment processes, legal compliance process, financial affairs, etc. with respect to the business partners/customers/suppliers (their authorized persons or staff members);
h. administering the security operations, accidents or such other incidents related to health-insurance;
i. conducting Market Surveys and R&D (research and development) activities and also enhancing and improving our product range, services, stores, information technology systems and security systems;
j. ensuring the security of the individuals at our facilities by making use of the video camera (CCTV) images and assisting in the prevention, determination and prosecution of any criminal offense, accordingly, and establishing, exercising or defending our legal rights by taking into account the photographs, as well;
k. providing you with the information, you would ask from our Company, and also the information about the events and services;
l. determining and implementing the commercial and business strategies of our Company;
m. ensuring the implementation of the human resources policies of our Company; and
n. fulfillment of any statutory obligation if and when clearly specified in the applicable regulations or if and when so required; and
o. any Force Majeue event, including the infectious epidemics such as COVID-19
Our Company shall be entitled to modify and amend this information text. Please check the information text on a regular basis and at each time before providing any personal data through the website.
C. Method for Collection of Personal Data, and Legal Ground Thereto:
For the purpose of ensuring that our Company is able to provide our products and services in accordance with the statutory framework as set out, and accordingly, to fulfill its liabilities arising from the agreement or law in full and perfectly, your personal data shall be obtained either verbally, in writing or electronically in any manner whatsoever in line with the purposes as specified in the sections herein above. Your personal data, collected as based on such legal ground, shall be processed, recorded, transferred, shared and stored for the purposes as specified in section (B) hereof as part of the terms and conditions and purposes for processing personal data as specified in Sections 5 and 6 of the LPPD.
The website, you are visiting, is owned and run by the Company. By making use of our website, you hereby acknowledge that the use of any personal data, obtained and collected through our website, is within your knowledge and based on your consent.
Any personal data, you would share, shall be used for the following purposes:
- Sending press releases or notifications by e-mail;
- Sending printed publications or such other correspondences;
- Delivering any product you have purchased, or any award granted to you;
- Entering your booking requests and managing your account;
- Calculating the statistics with respect to your processes;
- Creating business statistics and analysis with respect to the use of the website; and
- Ensuring the security of the website and also that it runs effectively.
- Offering the restaurant products and services;
- Conducting the customer satisfaction activities; and
- Checking the guest list at the entrance for any party or event.
If you prefer to not to share your personal data in this website, then you will not be able to benefit from some rights such as accessing to certain sections of the website, asking for online newsletters, booking online, submitting a job application, providing feedback about our businesses or sending electronic mails to us.
Information about your computer such as your IP address (the number designated for your computer while making use of the Internet) and the type of the Web browser you use and also the operating system you use may also be collected and linked to your Personal Information.
This is necessary for enabling our website to offer the best experience to our visitors and also to make available effective information sources.
We take reasonable measures to ensure the security of your personal data. All identifiable personal data is subject to restricted access for the purpose of preventing unauthorized access, change or abuse thereof.
Any entity, which provides service to the Company, is obliged to keep such information confidential, and is not allowed to make use of any such information for any purpose other than the purpose of performance of the services it provides for the Company.
For the purpose of ensuring that sending of any information or documentation, which includes any personal data of any third party, and also any notification, message, photograph, etc.in breach of the LPPD, we establish the mechanisms to verify the accuracy of the contact details you have provided to us as per Section 12/f.1 of the LPPD.
E. LPPD and Cookies Policy
Cookies are the small data files that allow for collection and storage of an array of data, available in your desktop computer, laptop computer or mobile device, by our website. The Company may make use of "cookies" for the purpose of collecting the details such as the specific domains you have visited and our services, you have benefited, available in our website. We collect such details for the purpose of being able to change our products in which you are interested and which you need. Such "cookies" may also be used for enabling you to perform your processes quicker if and when you re-visit our website. For instance, our website may identify any personal data, you have provided, for the purpose of making use of such data and avoiding to asking you to provide such data once again. Many web browsers are preset for accepting a "cookie". Preferably, you can set your own web browser for rejecting the "cookies" or being warned in case any "cookie" is sent. Rejecting the "cookies" in the website you have entered may block browsing some domains of such website or receipt of the customized information when you visit such website.
We can measure the extent of effectiveness of the presence of our website by determining the time of your entrance to our website and the pages you browsed and the period of your stay. Website measurement statistics may be used not only for customizing your website experience but also for the creation and assessment of the statistics with respect to the use of our website, anonymously and holistically.
In addition to the cookies, we, as Barut Hotels Group, carry out advertising activities appropriate to your preferences and for the purpose of improvement of your user experience, as part of the services procured from the third parties such as Google and Facebook,
F. Processing of Sensitive Personal Data:
Some personal data, which pose the risk to give rise to grievance of the respective individual or to discrimination if and when processed unlawfully, are determined as "sensitive personal data" in Section 6 of the LPPD. Any data related to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and clothes, membership to any association, foundation or union, health, sexual life, criminal conviction and security measures, as well as any and all biometric and genetic data constitute sensitive personal data. In respect of processing of any sensitive personal data, our Company acts in compliance with
the provisions as prescribed in Section 6 of the LPPD, and it treats any such data responsibly and sensitively for protecting the same.
Our Company processes sensitive personal data in the following circumstances and in accordance with the LPPD, provided that the adequate measures to be determined by the Personal Data Protection Board shall have been taken:
a. If and when the personal data subject has granted her/his explicit consent; Our guests may share their circumstances with our Company and ask for service customized for them, and share their sensitive personal data for such purpose. (In case any of our guests shares her/his sensitive personal data and asks for a customized service, for example, asking for a thin pillow due to cervical disc hernia, or requesting for a room at the ground floor due to heart condition or asking us to prepare desserts with no dried nuts and fruits due to peanut allergy, etc.). For the purpose of being able to provide our guests with customized service for the requirements they have indicated by sharing their sensitive personal data and also to provide the same services to them by remembering their such requirements also in the future, our Company shall process the sensitive personal data of any individual only upon obtaining an explicit consent from such individual and if and when such processing serves for the purpose of collection.
b. If and when the personal data subject has not granted her/his explicit consent;
– The sensitive personal data, other than any such data related to her/his medical condition and sexual life, of such personal data subject shall be processed in the circumstances as prescribed by the laws; and
– Any sensitive personal data, which is related to her(his medical condition and sexual life, of such personal data subject, shall be processed only for the purpose of protecting the public health, performance of preventive medicine, medical diagnosis, treatment and health-care services, planning and management of the medical services and the financing thereof by the persons, who are bound by non-disclosure obligation or by the competent authorities and organizations.
G. Force Majeure
The personal and the sensitive personal data shall be processed in accordance with the measures, which are taken or required to be taken for any Force Majeure event such as COVID-19 or such other similar global or regional epidemics, infectious diseases, earthquake, flood, warfare or state of emergency.
H. Recipients of Such Processed Personal Data and Purposes of Such Transfer:
H. To whom and for what purpose the processed personal data may be transferred:
Your collected personal data may be transferred to the Akra Companies listed below to serve the purposes specified in Article (B);
• BHM Otelcilik A.Ş.
• BT Otelcilik A.Ş.
• Bartu Turizm Yatırımları A.Ş.
• Buket Yıkama Servis ve Tekstil San. Ticaret A.Ş.
• Sandu Yazılım ve Ticaret A.Ş.
and also to our shareholders, business partners, suppliers, consultants, service providers, financial institutions, the governmental authorities and natural persons authorized by the laws, in accordance with the terms and conditions of and the purposes for processing of personal data as specified in Sections 8 and 9 of the LPPD.
I. International Transfer of Personal Data:
Our Company shall be entitled to transfer any personal data internationally following the obtainment of the explicit consent of the respective individual for such purpose and in accordance with such other terms and conditions as prescribed by the law, as part of the terms and conditions as set out by the Personal Data Protection Board under the LPPD.
Personal data may be transferred internationally without seeking for the consent of the respective individual in case of existence of any of the requirements as specified in Section 5/f.2 and Section 6/f.3 of the LPPD and also availability of adequate protection at the foreign country to which the personal data will be transferred.
J. Rights of the Personal Data Subject As Listed in Section 11 of the LPPD:
We hereby acknowledge that the respective individual is entitled to be informed and asked to grant her/his consent before processing, recording, transferring, sharing and storage of her/his personal data, and also that s/he is entitled to dispose of her/his data following the processing, recording, transferring, sharing and storage of such data, as part of the LPPD. Accordingly, in the event that you, as being a personal data subject, submit your request regarding your rights to our Company by means of the methods as mentioned in the "Information Text Regarding Processing of Personal Data", as set out hereunder, then, our Company shall conclude any such request free of charge no later than a period of thirty days as based on the nature of such request.
In respect of your requests with respect to the rights, you have as being a personal data subject, as per the Communique Regarding the Procedures and Principles For Filing An Application With the Data Controller as promulgated by the Personal Data Protection Board;
i. No fee shall be collected up to ten pages, if and when your application would be replied in writing. A processing fee of 1 Turkish Lira may be collected for each page in excess of ten pages.
ii. In the event that the reply to such application is given in a recording medium such as CD, flash disk, etc., then the fee, which may be asked by our Company as being the data controller, may not exceed the cost of such recording medium. Accordingly, any personal data subject shall be entitled to;
a. Inquire whether her/his personal data has been processed, or not; and
b. Ask for information about her/his personal data, if it has been processed; and
c. Be informed about the purpose of processing of any personal data, and also about the fact that whether such personal data has been used appropriate to the purpose thereto; and
d. Be informed about any third party to which any personal data has been transferred either domestically or internationally; and
e. Ask for correction of any imperfect or inaccurate personal data, in case of any imperfect or inaccurate processing thereof, and to ask for providing information about the processes, performed for such purpose, to the third parties, to which such personal data has been transferred;
f. Ask for deletion, disposal or anonymization of any such personal data in accordance with the terms and conditions as prescribed in Section 7 of the LPPD, and also, accordingly, to ask for providing information regarding the processes, performed for such purpose, to the third parties to which any such personal data has been transferred; and
g. Raise an objection against the occurrence of any consequence to the detriment of the respective individual by analyzing any such data processed by means of exclusively automated systems; and
h. Claim for compensation of any damage and/or loss, s/he might have incurred in the event that any such personal data has been processed in breach of the law.
Nevertheless, the individuals shall not have any right in relation to any data anonymized internally by the Company. Our Company may share any personal data with the respective agencies and organizations for the purpose of exercise of its Statutory powers by any judicial function or governmental authority as per any business or contractual relationship.
K. Periods For Processing Your Personal Data:
Any of your personal data, processed for the purposes as specified in this "Information Text Regarding Processing of Personal Data", shall be deleted, disposed of or continued to be used by being anonymized by us upon the disappearance of the purpose, which requires the processing of such data as per Section 7/f.1 of the LPPD, and/or upon the elapse of the prescription period, for which we are obliged to process your data as per the applicable regulations, in accordance with the LPPD.
L. Circumstances in Which Our Company May Process Your Personal Data without Your Explicit Consent As Required By the Laws:
In the circumstances listed herein below, your personal data, which has been obtained lawfully by our Company without seeking for your explicit consent, may be processed by the Company as per the Section 5 of the LPPD:
If and when so prescribed clearly by the laws;
- If and when the processing of your personal data is required for the purpose of protecting the life or bodily integrity of you or of any other individual if and when you, as the data subject, are not able to state your consent due to any actual impossibility or in case your consent is not recognized in legal terms;
- If and when the processing of the personal data of the parties of such agreement is required, provided that such processing shall be directly related to entering into or performance of an agreement you have executed with our Company and its Affiliates/subsidiaries and any such other real and/or legal person as specified in Section (C) hereof;
- If and when it is required for enabling our Company to fulfill any statutory obligation imposed on it;
- If and when your personal data has been made publicly available;
- If and when such processing is required for establishment, exercise or protection of a right;
- If and when such processing is required for the lawful interests of our Company without prejudice to the fundamental rights and freedoms you have.
M. In Order For Submitting a Request As Per the Law on Protection of Personal Data:
As per the paragraph 1 of Section 13 of the LPPD, you can submit your request with respect to the exercise of any of your rights as listed herein above to our Company by means of the method(s), which has/have been determined/will be determined by the Personal Data Protection Board, in accordance with the provisions as prescribed in the LPPD and the applicable regulations thereto, or you can submit your request by filing an application by making use of any of the methods, as described herein below, by completing and signing the Application Form available on the address, https://www.baruthotels.com/KVKK.
i. You can personally deliver a signed copy of the form, which will include your statements with respect to the right you claim, to the address, i.e. Asmani Restaurant, Sirinyalı Mh. Lara Cd. No:24 Muratpasa - Antalya / Turkey, together with the official documents evidencing your identity (For example, national ID card, driving license, passport, etc.)
ii. You can send the form, you will have completed, and the official documents that will evidence your identity through the agency of a Notary Public, or
iii. You can forward the form, you will have completed, and the documents evidencing your identity, to our Company as being the Data Controller, electronically to the address, namely email@example.com, so as to bear a secure electronic signature or a mobile signature thereon, or
iv. You can forward the form, you will have completed, and the documents evidencing your identity, to our Company as being the Data Controller, by making use of the electronic mail address, you have indicated to our Company previously and which is recorded within the system of our Company.
Our Company shall ensure that the request will have been finalized no later than a period of 30 days, depending on the nature of such request.
The rights with respect to the personal data may be exercised only in respect of the data owned by the respective individual. Any request with respect to any data of any individual other than the one, who has completed the form and submitted the official documents evidencing your her/his identity as attached to such form, shall be disregarded. Any form, to which the official documents evidencing your identity are not attached, shall be disregarded. We hereby inform you that we shall remain obliged to share any such data with the governmental authorities if and when so requested by them, even in case of fulfillment of a request for deleting any data.