Personal Data Protection and Privacy Policy
Website Confidentiality Agreement
During your visit to this website and your use of the service through this Site, how the information that we receive regarding you and the services you request will be used and protected are subject to this ‘’Confidentiality Agreement’’. You hereby accept the conditions stipulated in this ‘’Confidentiality Agreement’’ when you visit this website and request to use the services we provide through this Site.
I. Purpose of personal data protection and processing policy
Until today, data and information of our customers or potential customers are kept confidential and have never been shared with third parties by virtue of the sensitivity of our business as Delita Grup Turizm İnşaat Gıda Sanayi ve Ticaret Ltd. Şti. (“Delita Grup”). Personal data protection is our essential policy. Even before any legal regulation, our company and subsidiaries had attached a great importance to the confidentiality of personal data, adopted as a working principle and gave working instructions to the employees in compliance with this principle. As “Delita Grup’’, we undertake to adhere to all responsibilities of Privacy Act. The principle of our companies to protect personal data also covers our subsidiaries.
II. Scope and change of personal data protection and implementation policy
This Policy prepared by our Company has been regulated in accordance with “Law on Protection of Personal Data” no. 6698 (“KVKK”). The Law has entered into force with all of its provisions as of today. The data received with your consent or pursuant to the other regulations as per to the Law shall be used to make our service more quality and to improve our services and quality policy. Again, some of the data we obtain are removed from the scope of personal data and anonymized. These data are used for statistical purposes and not subject to the enforcement of Law and our Policy. “Personal Data Protection and Implementation Policy of Delita Grup” aims and regulates the protection of the data which are automatically obtained from our customers, potential customers, employees and the customers and employees of the companies in cooperation with us for solution partnership and the other parties.
Our company reserves the right to change our Policy and Regulation – provided to comply with the Law and protect the personal data in a better way.
III. General principles on processing of the personal data
a) Being in compliance with the law and good faith: “Delita Grup” 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 “Delita Grup” to protect the personal data.
b) Being accurate and up to date, if necessary: “Delita Grup” 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: “Delita Grup” 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: “Delita Grup” 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: “Delita Grup” 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 “Delita Grup” collects or processes the data by one’s will or in compliance with the law, the abovementioned provisions shall apply anyhow.
Maximum Savings Policy/Scrimping Policy
Pursuant to our policy called as maximum savings policy or scrimping policy, the data received by “Delita Grup” 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 “Delita Grup” are processed as declared by the relevant persons as a rule. “Delita Grup” is not obliged to check up on the accuracy of the data declared by the customers or the persons in touch with “Delita Grup” 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 “Delita Grup”. 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.
Confidentiality and data security
Personal data are confidential and “Delita Grup” 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 “Delita Grup” 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.
IV. Purpose of data processing
Collection and processing of personal data by “Delita Grup” shall be executed in line with the purposes stipulated in the letter of clarification. The data are collected and processed to draw up contracts and provide better services to the customers.
V. Data of customer, potential customer and business and solution partners
As “Delita Grup”, we process your personal data in the capacity of data supervisor within the scope of Personal Data Protection Law no. 6698 and other relevant legislations.
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) and photocopies.
· Contact Information: Address, telephone number, e-mail address.
· Financial Information: Mobile invoice information, bank account information, payment card information, Loyalty Program memberships, information about purchased product or services.
· Customer reviews, feedbacks and complaints: Special preferences in accommodation, marketing and communication fields; reviews, opinions or complaints about the brands and properties.
· Other: Reservation details, travel history; information on participation in competitions, draws or marketing programs, 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 member numbers, 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. The data 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
“Delita Grup” 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,
· Exchanging internal correspondences with guests violating the property and general codes of conduct during the accommodations at the hotel and preparing a list in line with these information,
· Recording the comments of guests on social media, blogs, review portals etc. into the system to analyse the feedback of the service provided,
· Carrying out Sales and Marketing activities to offer a tailor-made holiday experience by processing the data of services 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.
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 updated 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 Turkish Republic’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 per Tax 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 invoices except for the invoices issued for taxpayers registered in e-Invoice Implementation are designated as e-Archive Invoice.
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. “Delita Grup” 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.
Data processing of the company
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.
Processing of special quality data
Pursuant to the Law, race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothes, 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. “Delita Grup” also takes adequate measures determined by the Board for the processing of special quality data.
“Delita Grup” may process the special quality data only for the corresponding purposes to provide better services.
Data processed with automatic systems
“Delita Grup” 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, “Delita Grup” may take decisions regarding the persons that it will perform process by using the data within the system.
User Information and Internet
In case of the collection, processing and use of personal data on the websites and other systems or applications belonging to Delita Grup Turizm İnşaat Gıda Sanayi ve Ticaret Ltd. Şti. the related persons shall be informed about the privacy statement and cookies if needed. Users shall be informed about our applications on our websites. Personal data shall be processed as per the law.
We kindly submit the below mentioned information about the cookies that we use/will use on our pages when you visit our website.
Google (analytics, doubleclick)
Purpose of Use of Cookies : Measurement Advertisement In-site optimization
Type of Cookies : Functional and analytic cookies Commercial cookies
Facebook
Purpose of Use of Cookies : Advertisement
Type of Cookies : Commercial cookies
Insider
Purpose of Use of Cookies : Measurement Advertisement In-site optimization
Type of Cookies : Functional and analytic cookies Commercial cookies
Hotjar
Purpose of Use of Cookies : Measurement In-site optimization Functional and analytic cookies
Type of Cookies : Commercial cookies
3rd party companies (criteo, rtbhouse)
Purpose of Use of Cookies : Advertisement
Type of Cookies : Functional and analytic cookies Commercial cookies
Functional and Analytic cookies
Cookies includes the data about reminding your choices, using website effectively, optimizing the website so as to answer the demands of the user and how the visitors use the website. By qualification, these kinds of cookies may consist of personal information such as user name.
Third Party Cookies
Websites/mobile applications/mobile websites belonging to Delita Grup Turizm İnşaat Gıda Sanayi ve Ticaret Ltd. Şti.works with third party reliable and known advertisement providers Third party service providers place their own cookies to offer advertisements special to you. The cookies placed by third party collect, process the surfing information of the visitors on the websites and analyze them according to the ways of use.
Commercial cookies
Commercial cookies serve to offer the product/content with similar qualifications and enhance your usage experience by providing a developed and customized advertisement portfolio according to your fields of interest and choices. The holdup time of the session, permanent, functional and analytic and commercial cookies on the background is about 2 (two) months and the required settings can be done by browser settings. The removal operation, one of the settings, can be changed by means of the browser.
During your reservation process if your transaction is not completed due to errors or failures in the system, our call center representative will contact you.
How to clear cookies?
Many browsers are adjusted automatically to accept and use the cookies as of the first installment of your computer. You are allowed to block the cookies or to be warned about the cookies by using help or setting menus of your browser. You can take advantage of the instruction or help option screens of your browser to obtain further information about the various methods of managing cookies or regulate the settings of your browser.
Purpose of Collecting and Processing Safety Data from Properties
Security footages taken due to your visit to Delita Hotels 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.
VI. Data of our employees
Processing of the data for business relations
Personal data of the employees may be processed without obtaining consent to the extent of requirements of health insurance and business relations. However, “Delita Grup” hereby undertakes the protection and confidentiality of the data of the employees.
Processing as per Legal Obligations
“Delita Grup” may also processes the personal data of the employees without obtaining a separate consent to fulfill a legal obligation stipulated in the legislation or in case it’s explicitly specified in the legislation. This case is limited to the obligations arising from the Law.
Processing in Favor of the Employees
“Delita Grup” may process the personal data without obtaining the consent for the procedures in favor of company employees like private health insurances. For the disputes arising from the business relations, “Delita Grup” may also process the data of the employees.
Processing of special quality data
Pursuant to the Law, race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothes, 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. Besides the consent of the relevant person, “Delita Grup” also takes adequate measures determined by the Board for the processing of special quality data. Special quality data may be processed limited to and related to the cases permitted by the Law without the consent of the person. The quality data obtained from the employees shall only be used for the corresponding purpose to allow them to benefit from the insurance and health services.
Data processed with automatic systems
The data processed regarding the employees with automatic systems may be used for in-house promotions and performance assessments. The employees reserve the right to appeal to the results against them and they should perform this process in compliance with the internal procedures. Appeals of the employees shall be evaluated again within the company.
Telecommunication and internet
The computers, telephone, e-mail and other applications allocated to the employees within the company shall only be used for business purposes. The employee cannot use any of these means allocated to himself/herself by the company for private purposes or communication. The company may control and monitor the data on these means. The employee undertakes not to keep any data or information apart from the business purposes on the computer, telephones or other means allocated to himself/herself as of his/her employment date.
VII. Transferring of the personal data domestically and internationally
Personal data may be shared with business and solution partners and “ETS” subsidiaries for the purpose of providing the services by “Delita Grup”.
“Delita Grup” will be entitled to transfer the personal data for certain purposes to the following person and institutions;
» Business partners of “Delita Grup” limited to the purpose of execution of the aims of the establishment of the business partnership,
» The suppliers of “Delita Grup” to the extent of providing the necessary services by our company to fulfill its commercial activities and procured by the supplier as external sources,
» Solution partners of “Delita Grup” limited to ensuring the execution of the commercial activities which require the participation of the affiliates of the company,
» Subsidiaries of “ETS”.
“Delita Grup” is authorized to transfer the personal data domestically and internationally within the conditions determined by the Board and in compliance with the other provisions in the Law and depending on the consent of the person.
VIII. Rights of the relevant person
“Delita Grup” hereby agrees that the relevant person must provide his/her consent before processing the data within the scope of the Law and he/she reserves the right to determine the destiny of the data after the data is processed.
Regarding the personal data, the relevant persons holds the right to do the following by applying to our official announced on the web page by “Delita Grup”;
a) To be informed whether his/her personal data are processed or not,
b) To request information if the personal data are processed,
c) To learn the purpose of processing the personal data and whether the data are used for the corresponding purposes,
ç) To get information on the third parties to whom the personal data are transferred in the country and abroad,
d) In case the personal data are processed incompletely or inaccurately, to request the correction,
e) To request that personal data are deleted or removed within the framework of the conditions stipulated in article 7,
f) To request that the processes performed as per clause (d) and (e) are notified to the third parties to whom the personal data are transferred,
g) To appeal to the negative results against himself/herself arising from the analysis of the data processed exclusively through the automatic systems,
ğ) In case the personal data are damaged due to the processing of the data contrary to the Law, to request that the damages are indemnified.
Nevertheless, the persons don’t reserve any right on the anonymized data within the company. “Delita Grup” may share the personal data as required by a juridical function or governmental authority as per the business and contractual relationship.
The owners of the personal data shall submit their requests regarding the above-mentioned rights to the following contact address by wrting an application and putting their wet on the application, through registered letter with return receipt with the copies of their identity cards (only front page for birth certificate). The applications shall be replied within the shortest time according to the content of the application ow within 30 days at the latest after the delivery to the company. You need to apply with registered letter with return receipt. Besides, only the questions about you shall be replied and any applications made regarding your spouse, relative or friends shall not be accepted. “Delita Grup” can only request information and document from the application holders.
IX. Confidentiality Principle
The data of the employees and other persons within “Delita Grup” are confidential. Nobody can use, copy, reproduce, transfer these data for other purposes apart from the business purposes.
X. Process security
All necessary technical and administrative measures are taken to protect the personal data received by “Delita Grup” 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.
XI. Inspection
“Delita Grup” carries out the internal and external inspections for protection of the personal data.
XII. Notification of Violations
“Delita Grup” 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.
Requests made pursuant to the Act on the Protection of Personal Data
As announced on website to put your application into process, please complete the application and 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:
“Delita Grup” reserves the right to make changes on the declarations here. In case of any significant change in the declaration, a link will be attached on the homepage of the website to access the up-to-date declaration. Guests registered for any of our products or services may be informed regarding this issue through the communication channel he/she has provided to the properties. When the last time this declaration was updated and update number are given at the end of this text.
Each change made on the declaration becomes effective upon the publication of the changed declaration on the website. 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.
Policy Update: 20.09.2019.KVKK Declaration-1
Contact
You can contact us for further questions on the confidentiality agreement by using the following contact information.
Delita Grup Turizm İnşaat Gıda Sanayi ve Ticaret Ltd. Şti.
Hrant Dink Sokak No:69 19 Mayıs Mahallesi
Şişli Istanbul