Scope and Purpose

This Policy has been prepared within the scope of Law No. 6698 on the Protection of Personal Data (KVKK) and the KVKK Policy Book, in order to regulate the processing of personal data obtained directly or arising from legal, commercial, or financial relationships entered into by SEASHELL HOTELS with its customers, employees, and natural or legal persons with whom it communicates and interacts. The aim is to set forth the conditions to be followed, to declare and announce them.

Obligation to Inform

Pursuant to Law No. 6698 on the Protection of Personal Data (KVKK), which entered into force on 07.04.2016, SEASHELL HOTELS is required to regulate the personal data processed during relationships with customers, employees, and other natural or legal persons with whom it communicates and interacts, due to the obligations and requirements imposed by the legislation.

SEASHELL HOTELS pays utmost attention and care to the principles of personal data security and confidentiality of customers, employees, and relevant third parties. During the provision of services, priority is given to ensuring the personal data security of relevant persons.

According to the provisions of the above-mentioned law, any information that identifies or makes a natural person identifiable (including special categories of personal data) is considered personal data within the scope of the KVKK. These personal data are processed by SEASHELL HOTELS as the Data Controller, using the methods explained below and within the limits prescribed by the legislation.

“Processing of Personal Data” refers to any operation performed on data, whether fully or partially automated, or by non-automated means as part of a data recording system, such as collecting, recording, storing, preserving, altering, reorganizing, disclosing, transferring, taking over, making available, classifying, or preventing their use.

Purpose and Legal Basis for Processing Personal Data

Personal data may be collected, in accordance with legal requirements, automatically or non-automatically, through means such as platform registration, telephone, fax, e-mail, SMS, other social media platforms, mobile applications, including audio and visual recordings, in writing or verbally, and processed by SEASHELL HOTELS in electronic or physical environments.

Pursuant to Article 5 of Law No. 6698, personal data may be processed if:

• The explicit consent of the data subject is obtained,

• It is clearly stipulated in the laws,

• It is necessary to protect the life or physical integrity of the data subject or another person, who is unable to give consent due to actual impossibility or whose consent is not legally valid,

• It is directly related to the conclusion or performance of a contract to which the data subject is a party,

• It is necessary for SEASHELL HOTELS to fulfill its legal obligations,

• The personal data have been made public by the data subject,

• It is necessary for the establishment, exercise, or protection of a right,

• It is necessary for the legitimate interests of SEASHELL HOTELS, provided that it does not harm the fundamental rights and freedoms of the data subject.

Additionally, under Article 6, special categories of personal data may also be processed with the explicit consent of the data subject or in other legally permitted cases.

Sharing and Transfer of Personal Data

Personal data of the data subject may be shared with or transferred to official institutions and organizations in cases required by law, and with domestic or foreign business partners, project partners, cooperation partners, suppliers, independent audit firms, banks and financial institutions, law firms, financial advisors, IT, quality, and financial consultants, and other companies, persons, and institutions from whom support and assistance are received, provided that the necessary electronic and physical security measures are taken by SEASHELL HOTELS.

This sharing and transfer may also apply to abroad, including countries such as EU member states, the USA, and the United Kingdom, as well as servers, hosting companies, programs, cloud computing services, and other electronic platforms located abroad.

Method of Collecting Personal Data

Personal data of the data subject may be collected through all contracts/information forms and other documents signed by approval and/or consent, electronic approvals and/or signatures, the administrative center of SEASHELL HOTELS, physical environments, call centers, websites, mobile applications, online transactions, social media and other public channels, user communications, judicial record scans, market research, the Identity Sharing System, SMS, online applications to websites, mobile applications, written/digital applications to sales teams, and call centers.

These data may be obtained verbally, in writing, visually, or through audio recordings, fully or partially automated, or as part of a data recording system, and are stored by taking into account the statute of limitations periods stipulated by the relevant legislation.

Rights of the Data Subject

(According to Article 11 of the KVKK)

The data subject may, by contacting SEASHELL HOTELS through the e-mail address provided below, request:

• To learn whether their personal data are being processed,

• To request information if processed,

• To learn the purpose of processing and whether they are used in accordance with this purpose,

• To know the third parties to whom personal data are transferred domestically or abroad,

• To request correction if the personal data are incomplete or inaccurate,

• To request deletion, destruction, or anonymization of personal data if the reasons for processing no longer exist,

• To request notification to third parties to whom the personal data have been transferred regarding the correction or deletion,

• To object to any outcome to their detriment arising from the analysis of personal data exclusively through automated systems,

• To request compensation for damages in case of unlawful processing.

Data Controller within the Scope of the Law

SEASHELL HOTELS is registered as the Data Controller in the VERBIS system at www.kvkk.gov.tr.

The data subject may submit requests, complaints, and suggestions in person, via notary, or by sending them to the e-mail address below, indicating their name, surname, T.R. ID number, address for notification, mobile phone number, e-mail address, and the subject of the request.

Written applications must be in Turkish and bear a wet signature if sent physically. Responses to requests are generally free of charge, except in cases where there are fees or other costs determined by the KVKK Regulations or other authorities.

Contact Address:
info@seashellhotels.com.tr

Physical Application Address:
SELGE TURISTIC INVESTMENTS AND ENTERPRISES CONSTRUCTION TRADE INC.
SEASHELL VEGA