Arcanus Hotels Sorgun

Disclosure Text

Disclosure Notice for Natural Persons Using Internet Access

Hotspot Users under Law No. 5651

You can find details of the explanations in this disclosure notice, which has been prepared in accordance with the KVKK Policy prepared and put into practice at this accommodation facility and at the establishments of the company named ASBETON İNŞAAT TAAH GIDA TUR.SAN. VE TİC.A.Ş. and/or its branches, the data controller (hereinafter referred to as "Arcanus Hotels Sorgun"), and with Law No. 6698 on the Protection of Personal Data (KVK Law), in the documents contained in the Data Controller's KVK Policy and its annexes. Accordingly;

This translation is provided for information only; in case of any discrepancy, the Turkish text prevails.

Your personal data processed

Identity and family information [name and surname, date of birth, room number]
Contact information [telephone number, e-mail address]
Transaction security information [IP address, hotspot records, password and passcode information, website login and logout information, log and digital traffic records]

Method of collecting your personal data and legal grounds

Your personal data are obtained and recorded in the systems while you connect to the internet access service (hotspot) offered at the facilities of the Data Controller:

By automated means (through the wireless network infrastructure, hotspot devices and logging software),
Digitally (through information such as the mobile phone number, e-mail and room number entered manually on the connection screen)

and are recorded in the systems.

Legal grounds

Your data are processed on the following legal grounds:

It being directly related to the establishment or performance of a contract (KVKK Art. 5/2-c)
The data controller's fulfilment of its legal obligations (KVKK Art. 5/2-ç) — in particular the obligation to keep connection logs under Law No. 5651
It being necessary for the establishment, exercise or protection of a right (KVKK Art. 5/2-e)
Processing being necessary for the legitimate interest of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject (KVKK Art. 5/2-f)

Situations requiring explicit consent

KVKK Art. 5/1: Based on your explicit consent, your mobile phone number and/or e-mail address may be processed by the Data Controller for the purpose of sending you campaign, promotion, satisfaction survey, advertising and information messages, and commercial electronic messages may be sent for this purpose through the Message Management System (İYS).

Purpose of processing your personal data

Your personal data are processed for the following purposes within the framework of Law No. 6698 on the Protection of Personal Data ("KVKK") and Law No. 5651:

Mandatory purposes (explicit consent not required)

Providing the internet access service
Keeping access logs under Law No. 5651
Identifying and verifying the connection holder
Ensuring access and transaction security
Preventing possible crimes, abuse and violations arising from connections
Providing information to the BTK, courts and other competent authorities
Ensuring physical premises security (checking hotspot locations)
Carrying out internal audit, information security and system management processes
Being able to use as evidence in legal disputes
Archiving records and presenting them for audit when necessary
Ensuring crisis and emergency management
Planning business continuity and operational activities
Auditing corporate operations and risk management

Purposes based on your explicit consent

Sending commercial electronic messages (campaigns, announcements, promotions)
Sending surveys aimed at guest satisfaction
Notifying corporate events, promotions and organizations
Offering loyalty programs and advantageous services
Marketing, analysis, segmentation and targeting activities

Transfer of your personal data

Your personal data may be transferred, in accordance with the data processing conditions specified in Articles 8 and 9 of Law No. 6698 on the Protection of Personal Data,

It being directly related to the establishment or performance of a contract,
The data controller's fulfilment of its legal obligations,
The establishment, exercise or protection of a right,
Data processing being necessary for the legitimate interests of the data controller,
It being expressly provided for in laws

on the basis of these legal grounds, or where you have given your explicit consent.

Recipients to whom your personal data may be transferred

Relevant public institutions and organizations (BTK, courts, law enforcement, etc.)
Group companies and affiliated subsidiaries
Solution partners and technical support companies providing hotspot infrastructure services
Business partners from whom consultancy services are obtained in audit or legal processes

Purposes of transfer

Your personal data may be shared for the following purposes:

Providing the internet service securely
Keeping access records under Law No. 5651 and presenting them to the competent authorities when necessary
Monitoring and controlling connection transactions
Ensuring internal audit and information systems security
Use as evidence in possible judicial processes
Notifying the competent institutions in order to fulfil legal obligations

Your rights as a data subject

Under Article 11 of Law No. 6698 on the Protection of Personal Data, as a data subject, you have the following rights by applying to the Data Controller:

Learning whether your personal data are being processed,
Requesting information if your personal data have been processed,
Learning the purpose of processing personal data and whether they are used in accordance with their purpose,
Knowing the third parties to whom your personal data are transferred, at home or abroad,
Requesting the correction of your personal data if they are incomplete or inaccurately processed,
Requesting the deletion or destruction of your personal data within the framework of Article 7 of the KVKK,
Requesting that the correction, deletion and destruction operations be notified to the third parties to whom personal data have been transferred,
Objecting to the occurrence of a result against you by analysis of your processed data exclusively through automated systems,
Requesting compensation for the damage if you suffer damage due to the unlawful processing of your personal data.

In order to exercise the right to complain that you have as a personal data owner, you must first apply to the data controller using the communication channels below. Without exhausting this route, it is not possible to resort to a complaint to the KVK Board.

Your request is answered by our company, as the data controller, according to the nature of the request, as soon as possible and within 30 days at the latest.

If your application is rejected, the response given is found insufficient, or your application is not answered in time, you may exercise the right to complain to the KVK Board or apply directly to the judicial route.

Application address and contact information

Company name: ASBETON İNŞAAT TAAH GIDA TUR.SAN. VE TİC.A.Ş.
Head office / branch name: Arcanus Hotels Sorgun
Company address: Sorgun Mevkii, Acısu Cd. No:8 07600 Manavgat/Antalya
Telephone: 0242 756 93 21
E-mail: [email protected]

Retention period of your personal data

In accordance with the relevant legislation, your personal data are retained in line with the purpose for which they are processed and for the relevant statutory periods, and at the end of these periods they are deleted, destroyed or anonymized. In this context;

In accordance with Law No. 5651 and the Regulation on Internet Mass Use Providers, internet access log records (IP address, MAC address, connection time information, etc.) are retained for a maximum of 2 (two) years.
If the telephone number and e-mail address are processed solely for the purpose of providing the connection, they are deleted, destroyed or anonymized within a maximum of 2 (two) years from the end of the connection.
Contact data processed on the basis of explicit consent (for example, the e-mail and telephone number collected for marketing and promotion purposes) are destroyed immediately if the explicit consent is withdrawn.

As the Data Controller, we retain your personal data for the periods determined within the framework of our Data Retention and Destruction Policy; when the retention period ends, they are destroyed in accordance with Article 7 of the KVKK and the provisions of the relevant regulation.

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