Personal Data Protection

PERSONAL DATA PROTECTION
CUSTOMER/GUEST INFORMATION TEXT

This Information Text relates to the processing of personal data from Customers/Guests, who are natural
persons, using the products and services provided by our Company Elit Turizm Yatırım A.Ş. that resides at
Kocatepe Mahallesi Şehit Muhtar Caddesi No:40 Beyoğlu Istanbul and acts in the capacity of Data
Controller. It is prepared by our Company to fulfill the obligation of disclosure under the applicable
legislation, particularly the Personal Data Protection Law No. 6698 (PDPL). Our company’s personal data
protection policies are available at the address www.eliteworldhotels.com.tr.
Processing is defined as any operation which is performed upon personal data such as recording, storage,
preservation, alteration, adaptation, disclosure, transfer, retrieval, making available for collection,
categorization pursuant to Article 3 of PDPL.

A. METHOD OF AND LEGAL GROUNDS FOR COLLECTING PERSONAL DATA

The personal data obtained by our Company during the performance of the contract from
Customers/Guests, who are natural persons and have purchased the products and services of our company,
to offer these products and services and the footages recorded on camera 24/7 as part of the performance
of the contract for security reasons in areas where our Company offers its services and products are
collected and processed as part of our Company’s legitimate interest and for the purpose of conducting the
necessary identity reporting through the Electronic Identification System of the General Directorate of
Security for our Company to carry out its activities in accordance with the legislation.

B. PURPOSES OF PERSONAL DATA PROCESSING

Your personal data will be processed by our Company under the terms of processing personal data
stipulated in Articles 5 and 6 of PDPL for the purposes noted below.
1. To provide the requested service,
2. To keep financial and accounting records,
3. To establish communication for Request and Complaint handling,
4. To present food according to the customer’s meal preferences,
5. To improve our Company’s Service Processes and enhance its service quality,
6. To ensure Customer Satisfaction,
7. To fulfil any legal action in case of the occurrence of a legal conflict,
8. To keep the Customers/Guests in the Consented Database informed of advertisements,
promotions, campaigns and promotions included in our Company’s portfolio,
9. To report any natural persons staying at our hotels to the General Directorate of Security of the
Turkish Ministry of Interior through the Electronic Identity Reporting system as per the applicable
legislation,
10. All other legal obligations.

C. TO WHOM PERSONAL DATA CAN BE TRANSFERRED AND FOR WHAT PURPOSES?

Our company takes utmost care to process personal data in line with the “need to know” and “need to use”
principles, with required data minimization, technical and executive safety measures in place. Personal data
is only transmitted to third persons in compulsory cases. Your personal data is processed by the relevant
units of our Company within the framework of the personal data processing terms and purposes stipulated
in Articles 8 and 9 of PDPL, and shared with third persons for the following purposes.
1. Legally competent public and private agencies and organizations such as Courts, Prosecution Offices, or
Police Departments, upon request, for the purpose of carrying out the related activities as per the applicable
legislation;
2. Our Company’s lawyers in the case of a legal dispute, and legally competent public and private agencies
and organizations such as Courts, Prosecution Offices, or Police Departments for the purpose of protecting
legal interests of our Company;
3. Our Company’s business partners providing marketing and advertising services for the purpose of
keeping customers in the consented database informed of the terms of marketing, advertising and
campaign, following such terms, and collecting and responding to complaints, and
4. For the purpose of reporting the identities of customers staying at the hotel to the General Directorate of
Security of the Turkish Ministry of Interior through the electronic identity reporting system pursuant to the
identity reporting law no. 1774.

D. PERSONAL DATA OWNER’S RIGHTS

Personal data owner “Related Person” may raise their following rights and requests under Article 11 of the
Personal Data Privacy Law, by duly filling in the Application Form available at the address
www.eliteworldhotels.com.tr.
Pursuant to Article 11 of the PDPL No. 6698, everyone acting as a data subject is entitled to file an
application to our Company for the following:
(1) Everyone can exercise the following rights by applying to the data controller:
a) To learn whether or not his/her personal data has been processed;
b) To request information as to processing if his/her personal data has been processed;
c) To learn the purpose of processing of the personal data and whether such data is used in accordance with
the intended purpose;
ç) To learn the third parties at home or abroad, to whom personal data has been transferred;
d) To request rectification in case personal data is processed incompletely or inaccurately;
e) To request deletion or destruction of personal data within the framework of the terms stipulated in
Article 7 of Law No. 6698;
f) To request notification of the third parties to whom personal data has been transferred, about the
operations performed as per sub-paragraphs (d) and (e);
g) To object to occurrence of any result that is to his/her detriment by means of analysis of the processed
data exclusively through automated systems;
ğ) To request compensation for the damages in case the person incurs damages due to unlawful processing
of personal data.