KARAHAN PENSION PERSONAL DATA PROTECTION AND PRIVACY POLICY
Karahan Pension (Karahan ) process your personal data in accordance with the Personal Data Protection Law No. 6698 (“KVKK”) and relevant legislation. When you visit our website and benefit from our services, your personal data is collected and used only based on legal grounds and for specific purposes. These purposes include improving service quality, responding to requests, fulfilling legal obligations, and providing notifications where necessary.
Your data may be collected based on your explicit consent or on other legal bases defined in the KVKK, and may be shared with third parties only where permitted by law and under appropriate security measures. Our company implements all necessary technical and administrative measures to ensure the protection of personal data.
In addition, certain data may be anonymized so that it is no longer associated with your identity and used solely for statistical analysis. Such data falls outside the scope of the KVKK, as it no longer qualifies as personal data.
This policy applies to the personal data processing principles concerning guests, employees, business partners, and individuals associated with these parties. Our company reserves the right to update this policy to comply with legal regulations and to enhance the protection of personal data.
GENERAL PRINCIPLES ON PROCESSING OF THE PERSONAL DATA
- a) Being in compliance with the law and good faith: “Karahan” 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 “Karahan” to protect the personal data.
b) Being accurate and up to date, if necessary: “Karahan” 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.
c) Being processed for specified, explicit, and legitimate purposes: “Karahan” 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.
d) Being relevant, limited and proportionate to the purposes for which data are processed: “Karahan” uses the data only for processing purposes and to the extent what the service requires.
e) Being stored only for the time designated by relevant legislation or necessitated by the purpose for which data are collected: “Karahan” 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 “Karahan ” collects or processes the data by one’s will or in compliance with the law, the above mentioned provisions shall apply anyhow.You shall have the following rights pursuant to Article 11 of Law on Protection of Personal Data. A separate application shall be prepared by “Karahan” for you to facilitate your related rights.
Maximum Savings Policy/Scrimping Policy
Pursuant to our policy called as maximum savings policy or scrimping policy, the data received by “Karahan” 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 “Karahan Pension” are processed as declared by the relevant persons as a rule. “Karahan Pension” is not obliged to check up on the accuracy of the data declared by the customers or the persons in touch with “Karahan Pension” 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 “Karahan Pension”. 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: info@karahanpension.com
(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 “Karahan Pension” 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 “Karahan Pension” 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 Karahan Pension we process your personal data with the capacity of data controller in the shared database as per the Law on Personal Data Protection no. 6698 and the other relevant legislation.
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, LoyaltyProgram memberships, information about purchased product or services.
– When subscribing to the email newsletter or asking a question regarding your loyalty card, your IP address is processed in a masked form in accordance with Article 5, paragraph 2 (d) and (f) of Law No. 6698 on the Protection of Personal Data (KVKK) to prevent misuse, ensure system security, and prevent fraudulent registrations. This process is carried out specifically to prevent the creation of fake accounts, the deliberate manipulation of the system, and attempts to misuse the system. Your IP address is processed solely for these purposes and is automatically and permanently deleted after being stored for 2 months.
– Customer reviews, feedbacks and complaints: Special preferences in accommodation, marketing and communicationfields; reviews, opinions or complaints about the brands and properties.
– Other: Reservation details, travel history; information on participation in competitions, draws or marketingprograms, 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 membernumbers, 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. Thedata 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
“Karahan Pension” 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 thefeedbackof the service provided,
– Carrying out Sales and Marketing activities to offer a tailor-made holiday experience by processing the dataofservices provided to the guests.
Managing relations with guests before, during and after the accommodation
– Calling guests before check-in,
– Customer Loyalty Program management,
– Answering questions of guests on Loyalty Program, card categories, how to upgrade your card etc.,
– 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.
-To manage the reservations for the á la carte, golf and spa services.
-Feedback and requests (Information such as your feedback and requests (provided through surveys, e-mails and WhatsApp)).
-Special service requests (Information such as illness, disability, allergy and special dietary needs as well as special vehicle transfer requirement and supporting documents you provide us so that we can meet your needs before, during and after your stay upon your request or confirmation).
-Information for preventing fraud (Device ID, device names, installation ID, IP address, location data, login date and browser type).
-Kids’ Club smartwatch GPS tracking: Children at the kids’ club of Karahan Pension. A can be equipped with a smartwatch with the consent of their parents. The GPS tracking feature on this watch aims to ensure that the children remain within the club’s boundaries and to know their location if necessary. The data is monitored in real-time and no records are stored.
-To enhance guest satisfaction, evaluate service quality, and ensure that any potential service-related disputes can be clarified properly if necessary, telephone conversations made to our call center for reservation and information purposes are recorded. (These recordings can only be accessed by authorized personnel, are securely stored on company servers, are not transferred abroad, and are not shared with third parties. The call records are stored in accordance with KVKK and relevant legislation for a period of 3 years from the date of the conversation and are securely deleted at the end of this period.)
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-invoicing & 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 up dated 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 TurkishRepublic’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 perTax 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 in voices except for the invoices issued for taxpayers registered in e-Invoice Implementation are designated as e-ArchiveInvoice.
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 on the Regulation of E-Commerce and the Law on Commercial Communication and Commercial Electronic Messages. An explicit consent of the person is required to send advertisements. “Karahan Pension” obeys the details of ‘’the consent’’ specified in the same legislation. The consent to be obtained should cover all commercial electronic messages that are sent to the electronic communication addresses of the recipients to promote and market the goods and services of the company, to promote the business or to increase the recognition level of the company with contents including greetings and wishes. This consent may be obtained via any electronic communication channel or at physical medium in written. The important thing is to obtain the declaration of the recipient that he/she accepts to receive commercial electronic messages and to have his/her full name and electronic communication address.
Company Data Processing
Personal data will be processed in accordance with the service offered by the company and its legitimate purposes; however, the data will never be used for illegal services. The WhatsApp group which servers are set abroad will be created for you in our facility will be used to evaluate the quality of the service we provide during your stay and the service provided by our staff. Your contact information, correspondence, and conversations with your assistant in the WhatsApp group will be stored for 3 years in a separate and secure system for potential conflicts, and all correspondence and conversations will be deleted once the processing period has expired.
Data processing due to legal obligations of the company or being stipulated explicitly in the Law
Personal data may be processed without prior consent when it’s stipulated explicitly in the relevant legislation or to fulfill a legal obligation specified in the legislation. Type and scope of the data processes are required for data processing activity that is permitted by the Laws and they should comply with the relevant legal provisions.
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.
WhatsApp group which will be created for you is used to measuring the services we provide and the staff’s service quality during your stay. It shall be deleted once the processing purpose disappears.At Maxx Royal Kemer Resort your contact information, messages, and phone calls with Maxxassist within the group shall be retained in a separate and secure system for 3 years for possible disputes and all messages and dialogues shall be deleted at the end of the processing time.
Processing special categories of personal data
In order to provide better services, Karahan Pension may, with the consent of the individuals, process special data exclusively for the purpose for which it was collected. In accordance with the circulars issued under Covid-19 and statutory provisions, our hotel facilities may request certain personal data, including special personal data such as health data from you and your relatives. These personal data can be passed on to authorities and health facilities if required.
Pursuant to the Law, race, ethnic origin, political opinion, philosophical belief, religion, sect or other belief sclothes, membership of association, foundation or union, health, sexual choice, juridical sentence and data regarding safety measures and biometric and genetic data are among the special quality data. “Karahan Pension” also takes adequate measures determined by the Board for the processing special categories of personal data. “Karahan Pension” may process the special quality data only for the corresponding purposes to provide better services.
Data processed with automatic systems
“Karahan Pension” 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, “Karahan Pension” 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 Karahan Pension 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.
Use of Thermal Imaging Camera
At the entrance to our property, a Thermal Imaging Camera/Thermometer is used to measure the body temperature and the relevant information is not used for purposes other than the protection of Public Health.
DOMESTIC AND INTERNATIONAL TRANSFER OF PERSONAL DATA
Your personal data may be shared with business and solution partners by Karahan Pension for the purpose of offering accommodation, transfer, ticketing, invoicing, surveys, marketing notifications, and loyalty card sending services.
Your personal data may be transferred to foreign countries (“Countries with Adequate Protection”) declared to have sufficient protection by the Personal Data Protection Board. In the absence of adequate protection, your personal data may be transferred to foreign countries (“Adequate Countries with Data Controllers Committing Adequate Protection”), where data controllers in Türkiye and the relevant foreign country have committed to providing sufficient protection in writing and have obtained permission from the Board. The transfers will be carried out meticulously, ensuring that the data security commitments in the respective country are thoroughly examined, using only the necessary information and up-to-date data protection methods.
Karahan Pension may transfer personal data to the individuals and institutions listed below for specific purposes:
a)Karahan Pension’s business partners, within the scope of the established business partnership, for the purpose of offering services (transfer planning, ticketing, pre-flight hospitality services).
b) Karahan Pension’s suppliers, to offer services necessary for the company’s commercial activities that are sourced externally from the supplier (server, storage, archiving, GSM services, hosting, IT support, legal and similar consultancy firms),
c) Karahan Pension, and other solution partners, limited to ensure the execution of our company’s commercial activities requiring the participation of subsidiaries (loyalty card discounts, ticketing, transfer, guide services).
d) The potential employers requesting references or requesting information within the scope of occupational health and safety, with the consent of our former employees limited to sharing the necessary documents within the scope of relevant legislation,
e) Institutions or organizations established in compliance with specific conditions determined by the relevant legislation and continuing their activities within the framework defined by the law (independent audit firms, international accredited institutions).
Karahan Pension ensure full compliance with the Personal Data Protection Law No. 6698 and related legislation when transferring your data domestically and internationally. Additionally, your Personal Data may be transferred to state institutions, judicial bodies, and foreign missions established by international
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 info@karahanpension.com
RIGHT TO APPLY AS A PERSONAL DATA SUBJECT
In accordance with Article 11 of the Law on the Protection of Personal Data No. 6698, personal data subjects have the right to:
– Learn whether their personal data is being processed,
– Request information regarding the processing of their data,
– Learn the purpose of the processing and whether their data is being used appropriately,
– Know the third parties to whom their data is transferred domestically or abroad.
Individuals who wish to exercise their rights as personal data subjects may submit their requests through one of the following methods:
– By completing the “Data Subject Application Form” available on our official website www.karahanpension.com accurately and completely, signing it with a wet signature, and sending it together with a copy of the front side of a valid identity document (such as a passport or national ID card) via registered mail with return receipt to the contact address provided below.
– The request can be submitted from the personal email address you shared with us during your stay at our hotels and which is registered in our system.(Applications submitted from other email addresses will not be processed. In such cases, the application must be submitted by completing the “Data Subject Application Form” available on www.karahanpension.com signing it with a wet signature, and sending it along with a copy of a valid identity document via registered mail with return receipt.)
Applications are concluded free of charge as soon as possible and within no later than 30 days, depending on the nature of the request. (However, if the process requires additional cost and/or if the Personal Data Protection Board determines a fee, charges may apply.)
Important Notes:
– Rights regarding personal data can only be exercised by the data subject personally.
– Applications submitted on behalf of someone else will not be processed unless legal representation is documented.
– Applications without an identity document copy will not be evaluated.
– Even if a data deletion request is fulfilled, relevant data may still be shared with official authorities upon request, in accordance with legal obligations.
CONFIDENTIALITY PRINCIPLE
The data of the employees and other persons within “Karahan Pension ” are confidential. Nobody can use, copy, reproduce, transfer these data for other purposes apart from the business purposes.
PROCESS SECURITY
All necessary technical and administrative measures are taken to protect the personal data received by “Karahan Pension” 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.
COOKIES
This site uses cookies – small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymized tracking data to third party applications like Google Analytics. Cookies generally exist to make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the help section of your browser.
INSPECTION
“Karahan Pension ” carries out the internal and external inspections for protection of the personal data.
NOTIFICATION OF VIOLATIONS
“Karahan Pension ” 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 https://karahanpension.com/privacy-policy/
Requests made pursuant to the Act on the Protection of Personal DataAs announced on https://karahanpension.com/privacy-policy/ 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.
CHANGES TO BE MADE IN PERSONAL DATA PROTECTION AND PRIVACY POLICY:
Karahan Pension 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.
The final additions in the updated policy are indicated in italic font italic font.
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.
CONTACT
You can contact us for further questions on the confidentiality agreement by using the following contact information.
Karahan Pension
Sales and Marketing Head Office
Altıparmak (Barhal) Köyü, Yusufeli – Artvin 08800, TÜRKİYE