Personal Data and Privacy Policy

Personal Data and Privacy Policy

Website Privacy Policy

The way in which the information we obtain about you and the services you request will be used and protected during your visit to this website and benefiting from the services we provide through this site is subject to the conditions set forth in this "Privacy Policy". By visiting this website and requesting to benefit from the services we provide through this website, you accept the terms set forth in this "Privacy Policy".

I. Purpose of personal data protection and processing policy

As Bentley Hotel Old City ( Jupiter Telecom Turizm A.Ş.) to date, the data received from our customers or prospective customers have been kept confidential and never shared with third parties, due to the sensitivity of the work we are dealing with. Protection of personal data is the basic policy of our company. Even before there was any legal regulation, our companies and affiliates attached great importance to the privacy of personal data and adopted this as a working principle and gave their employees working instructions in line with this principle. "JUPITER TELECOM TURIZM A.Ş." as a commitment. The principles of our companies regarding the protection of personal data also cover our subsidiaries.

II. Scope and change of personal data protection and processing policy

This Policy, prepared by our company, has been prepared in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”). The law has entered into force with all its provisions as of today. The data obtained from you with your consent or in accordance with other laws listed in the Law will be used to improve the quality of the services we provide, to improve the services offered to you and our quality policy. Again, some of the data we have is depersonalized and anonymized. These data are used for statistical purposes and are not subject to Law enforcement and our Policy. “Bentley Hotel Old City”, “Personal Data Protection and Processing Policy” aims to protect the automatically obtained data of our customers, prospective customers, employees, customers and employees of companies working in solution partnership with us, or other persons, and includes regulations regarding these. Our company has the right to change our policy and our Regulation, provided that it is in compliance with the law and that personal data is better protected.

III. Basic rules regarding the processing of personal data

a) Compliance with the law and the rules of honesty: “Bentley Hotel Old City” questions the source of the data it collects or receives from other companies and attaches importance to obtaining them in accordance with the law and within the framework of good faith. In this context, it makes necessary warnings and notifications to third parties (agencies and other intermediary institutions) that sell the services offered by "Bentley Hotel Old City" in order to protect personal data. b) Being accurate and up-to-date when necessary: “Bentley Hotel Old City” attaches importance to the fact that all data within the institution are correct, not contain false information, and finally, if there is a change in personal data, they are updated if they are communicated to it. c) Processing for specific, clear and legitimate purposes: “Bentley Hotel Old City” processes data only for the purposes it offers and for which it receives approval from individuals during service. It does not process, use and make use of data other than for business purposes. d) Being connected, limited and measured for the purpose for which they are processed: “Bentley Hotel Old City” uses the data only for the purpose for which they are processed and to the extent required by the service. e) Retention for the period stipulated in the relevant legislation or required for the purpose for which they are processed: “Bentley Hotel Old City” retains contractual data as long as the conflict periods of the Law and the requirements of commercial and tax law. However, when these purposes disappear, it deletes or anonymizes the data. It should be emphasized that whether “Bentley Hotel Old City” has collected or processed the data with consent or in accordance with the law, these principles listed above still apply.

Maximum Savings Policy/Stinginess Policy

According to this policy, which is called the principle of maximum savings or the principle of stinginess, the data reaching “Bentley Hotel Old City” is processed into the system only as needed. Therefore, what data we collect is determined by the purpose. Unnecessary data is not collected. Other data transmitted to our company are transferred to company information systems in the same way. Redundant information is not recorded in the system, deleted or anonymized. These data can be used for statistical purposes. Health data is better for customers than private data. It is taken in order to serve and protect their health and is kept in the system with care.

Deletion of personal data

Personal data is deleted, destroyed or anonymized by our company, automatically or upon the request of the person concerned, when the periods required by law to be kept, the completion of judicial processes or other requirements are eliminated.

Accuracy and data timeliness

As a rule, the data within the body of “Bentley Hotel Old City” are processed as declared by the relevant persons. “Bentley Hotel Old City” does not have to investigate the accuracy of the data declared by customers or people who contact “Bentley Hotel Old City”, and this is not done legally and due to our working principles. The declared data is considered correct. The principle of accuracy and timeliness of personal data has also been adopted by “Bentley Hotel Old City”. It updates the personal data that our company has processed from the official documents it receives or upon the request of the person concerned. It takes the necessary measures for this.

Privacy and data security

Personal data is confidential and “Bentley Hotel Old City” also respects this confidentiality. Only authorized persons can access personal data within the company. All necessary technical and administrative measures are taken to protect the personal data collected by “Bentley Hotel Old City”, to prevent it from falling into the hands of unauthorized persons and to prevent our customers and prospective customers from being victims. In this framework, it is ensured that the software complies with the standards, that the third parties are carefully selected and that the data protection policy is complied with within the company. Employees are informed and trained on the law of protection of personal data and the processing of personal data in accordance with the law.

IV. Data processing purposes

The collection and processing of personal data by "Bentley Hotel Old City" will be carried out in line with the purposes specified in the clarification text. Data is collected and processed for the purpose of establishing the contract and providing better service to customers.

V. Customer, prospective customer and business and solution partners data

As “Bentley Hotel Old City”, we process your personal data as data controller within the scope of the Personal Data Protection Law No. 6698 and other relevant legislation. The categories and explanations of personal data to be processed in this context are as follows: – Identity Information: Name-surname, name-surname of accompanying guest/guests, nationality, place and date of birth; TR ID, driver's license and passport numbers (including the date and place of issue). – Contact Information: Address, phone number, e-mail address. – Financial Information: Mobile billing information, bank account information, payment card number and other payment information, Loyalty Program memberships, information about purchased products or services. – Customer comments, feedback and complaints data: specific preferences in accommodation, marketing and communication; reviews, opinions or complaints about brands and facilities. – Other: Information on reservations, travel history; participation in contests, lotteries or marketing programs, information on vehicles used to reach the facility; booked hotel, airline and rental car packages; groups to which it is affiliated to stay at the facilities, frequent flyer or Travel Partnership Program memberships and member numbers, information given in membership and account applications.

Collection and processing of data for the contractual relationship

If a contractual relationship is established with our customers and prospective customers, the collected personal data can be used without the customer's consent. However, this use takes place in line with the purpose of the contract. The data is used to the extent of better execution of the contract and the requirements of the service and updated when necessary by contacting the customers. On the other hand, the data left to us by our prospective customers (prospective customers) are processed in order to provide them with an easier and higher quality service afterwards. If this data has not turned into a contractual relationship upon request, it will be deleted.

Business and Solution Partners Data

“Bentley Hotel Old City” adopts the principle of acting in accordance with the law when sharing data with both business and solution partners. Data is shared with business and solution partners with the commitment of data confidentiality and only as much as the service requires, and these parties are compelled to take measures to ensure data security. Data processing to manage, analyze and improve the services offered at the facilities • Conducting surveys with the aim of measuring the services provided, • To communicate with guests for marketing purposes in line with the communication permissions granted within the framework of other laws, • Facility and general etiquette rules during hotel stays Making internal correspondence about guests who behave outside of the box and preparing a list in line with this information, • Social media, blog, comment portals etc. of the guests. recording the comments in the fields in the system in order to analyze the return of the service provided, • To carry out Sales and Marketing activities in order to provide a personalized holiday experience by processing the data of the services offered to the guests. Managing our relations with guests before, during and after their stay • Making phone calls before entering the facility, • Customer Loyalty Program management, • Answering guests' questions on Loyalty Program, card scales, transfer to the next card and similar issues, • Segmentation by processing data related to reservation history, travel preferences and services received in order to manage marketing activities correctly, • To manage claims/complaints about our facilities and services received on comment portals, complaint pages, social media channels, • Keeping guests' personal information data up-to-date and combining them with data from third-party sources for analytical purposes

E-invoice & E-Archive Invoice

Within the scope of this program; The customer is automatically registered in the system and an invoice is sent via e-mail to the facility. It is the customer's responsibility to ensure that the e-mail address given at the entrance to the facility or updated by reference is correct and is the preferred e-mail address for this communication. If a reservation is made for another family member or persons using this e-mail address, the e-invoice of the relevant invoice will be sent to the e-mail owner's address. E-Invoice; Invoices prepared electronically, not printed on paper and forwarded to the buyer and/or seller by the servers. The Tax Procedure Law of the Republic of Turkey was put into practice with the Communiqué of VUK numbered 397 and came into effect as of January 01, 2018. As per the VUK, e-Invoice contains all the information that should be included in an invoice, while the mutual invoice transmission between the buyer and the seller takes place electronically. E-Archive Invoice is an application that allows the invoice, which has to be prepared, preserved and submitted in paper form in accordance with the Tax Procedure Law, to be prepared electronically in accordance with the conditions in the General Communiqué of the Tax Procedure Law no. All invoices in the e-Archive Invoice, except the invoices created for the taxpayers registered in the e-Invoice Application, are called e-Archive Invoice.

Advertising data processing

About Regulation of E-Commerce About Commercial Communication and Commercial Electronic Messages by Law. In accordance with the regulation, electronic messages for advertising purposes can only be sent to people who have received prior approval. The explicit consent of the person to whom the advertisement is sent is essential. Again, "Bentley Hotel Old City" complies with the details of the "approval" determined in accordance with the same legislation. The approval to be obtained should cover all commercial electronic messages sent to the electronic communication addresses of the recipients in order to promote your company's goods and services, market it, promote its business or increase its recognition with content such as congratulations and wishes. This approval can be obtained in writing, in the physical environment or by any electronic means of communication. The important thing is that the buyer has a positive declaration of will, name and surname and electronic communication address that he accepts the sending of commercial electronic messages. Data transactions made due to the legal obligation of the company or expressly stipulated in the law Personal data may be processed without further approval in order to clearly state the processing in the relevant legislation or to fulfill a legal obligation determined by the legislation. The type and scope of data processing must be necessary for the legally permitted data processing and must comply with the relevant legal provisions. In this context, the e-mail sending permission given to us by our guests during their stay in our facilities, in accordance with the Regulation No. 30998 published in the Official Gazette dated 4 January 2020, allows Service Providers to store and manage different types of message permissions such as call, message and e-mail, and the permissions given by the recipients. It will be shared with İYS, which is the national database system where users can view and remove permissions, complain about unauthorized submissions, the public can view the message complaints and the status of the permission subject to the complaint, serve over the website, text message number and call center, record all permissions with time stamp and store them securely. . .

Company's data processing

Personal data may be processed in line with the service offered by the company and its legitimate purposes. However, the data cannot be used for illegal services in any way. z.

Processing of sensitive data

According to the Law, data related to the race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and dress, membership to associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data is personal data of special nature. “Bentley Hotel Old City” also takes adequate measures determined by the Board in the processing of sensitive personal data. “Bentley Hotel Old City” can only process sensitive data for the purpose for which they were collected, with the consent of the individuals, in order to provide better services.

Data processed by automated systems

“Bentley Hotel Old City” acts in accordance with the Law regarding the data processed through automatic systems. The information obtained from these data cannot be used against the person without the explicit consent of the people. However, “Bentley Hotel Old City” can make decisions regarding the people it will deal with using the data in its own system.

User information and internet

In case of collection, processing and use of personal data on websites and other systems or applications of “Bentley Hotel Old City”, the relevant persons are informed about the privacy statement and, if necessary, about cookies. People are informed about our practices on web pages. Personal data will be processed in accordance with the law. When you visit our website, we present the following information to your attention regarding the cookies we use/will use on our page.

Data processed by automated systems

Data processed by automated systems regarding employees can be used in internal promotions and performance appraisals. Our employees have the right to object to the result against them, and they do so by following internal procedures. The objections of the employees are also evaluated within the company.

VI. Data of our employees

Processing of data for business relationship Personal data of our employees can be processed without consent as far as necessary in terms of business relations and health insurance. However, “Bentley Hotel Old City” ensures the confidentiality and protection of the data of its employees. Data is obtained from the Kariyer.net system for job applications and candidate recruitment, and for the management of human resources, and the data is recorded in the system as part of the candidate evaluation process.

Processing by Legal Obligations

“Bentley Hotel Old City” may process the personal data of its employees without obtaining separate approval for the purpose of expressly stating the processing in the relevant legislation or fulfilling a legal obligation determined by the legislation. This issue is limited to the obligations arising from the law.

Processing of sensitive data

According to the Law, data related to the race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and dress, membership to associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data is personal data of special nature. “Bentley Hotel Old City” also takes adequate measures determined by the Board, in addition to the approval of the person concerned, in the processing of sensitive personal data. Special categories of personal data can be processed without the consent of the person, but only in relation to the cases permitted by the Law and in a limited manner. In order for our employees to benefit from insurance and health services, the qualified data obtained from them is used only for the purpose.

Telecommunications and internet

The computer, telephone, e-mail and other applications allocated to the employees within the company are allocated to the employee only for business purposes. The employee cannot use any of these means allocated to him by the company for his private purposes and communication. The company can control and audit all data on these vehicles. The employee undertakes that he/she will not keep any other data or information outside of work on the computer, phones or other tools allocated to him from the moment he/she starts the job.

VII. Transfer of personal data in and out of the country

“Bentley Hotel Old City” will be able to transfer personal data to the following individuals and institutions for certain purposes; » Limited to the business partners of “Bentley Hotel Old City” in order to ensure the fulfillment of the purposes of the establishment of the business partnership, » To the suppliers of “Bentley Hotel Old City”, limited to the purpose of providing our Company with the services that are outsourced by our company from the supplier and necessary to carry out the commercial activities of our Company, » Execution of our company's commercial activities that require the participation of affiliates Solution partners of “Bentley Hotel Old City” limited to ensuring that »“Bentley Hotel Old City” has the authority to transfer personal data within the scope of the conditions determined by the Board in the law, in accordance with the other conditions in the Law and subject to the consent of the person, within the country and abroad.

VIII. Rights of the person concerned

“Bentley Hotel Old City” accepts that the data subject has the right to obtain consent before the data is processed, and that it has the right to determine the fate of the data after the data is processed. Regarding personal data, by applying to our contact announced on our website by “Bentley Hotel Old City”; a) Learning whether their personal data is processed or not, b) If personal data has been processed, requesting information about it, c) Learning the purpose of processing personal data and whether they are used in accordance with its purpose, ç) To know the third parties to whom personal data is transferred in the country or abroad, d) Requesting correction of personal data in case of incomplete or incorrect processing, e) Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7, f) Requesting notification of the transactions made pursuant to subparagraphs (d) and (e) to third parties to whom personal data has been transferred, g) Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems, ğ) In case of loss due to unlawful processing of personal data, it has the right to demand the compensation of the damage. However, individuals do not have a right to anonymized data within the Company. “Bentley Hotel Old City” may share personal data with relevant institutions and organizations for the purpose of exercising the legal powers of a judicial duty or state authority in accordance with the business and contractual relationship. Personal data owners can submit their requests regarding the above-mentioned rights by filling in the application form on the Company's official website www.bentleyhotelbosphorus.com completely and signing it with a wet signature, to the contact address specified below, by registered letter with return receipt and photocopy of identity card (only the front side copy of the identity card). they can send it. Your applications will be answered as soon as possible depending on the content of your application or within 30 days at the latest after it reaches our company. You must submit your applications by registered letter with return receipt requested. In addition, only the part of your application will be answered, and an application about your spouse, relative or friend will not be accepted. “Bentley Hotel Old City” may request other relevant information and documents from the applicants.

IX. Privacy Policy

The data of employees or other persons at “Bentley Hotel Old City” is confidential. No one can use, copy, reproduce, transfer to others, use this data for any other purpose, except for business purposes, without compliance with the contract or the law.

X. Transaction security

All necessary technical and administrative measures are taken to protect the personal data collected by “Bentley Hotel Old City”, to prevent it from falling into the hands of unauthorized persons and to prevent our customers and prospective customers from being victims. In this framework, it is ensured that the software complies with the standards, that the third parties are carefully selected and that the data protection policy is complied with within the company. Safety measures are constantly being renewed and improved.

XI. Audit

“Bentley Hotel Old City” carries out the necessary internal and external audits regarding the protection of personal data.

XII. Notice of Violations

When “Bentley Hotel Old City” is notified of any breach of personal data, it immediately takes action to remedy the breach. It minimizes the harm of the concerned and compensates the damage. When personal data is obtained by unauthorized persons, it immediately notifies the Personal Data Protection Board. Applications can also be made according to the procedures specified at info@bentleybosphorushotel.com regarding the notification of violations. Regarding requests made in accordance with the Law on Protection of Personal Data All applications, as announced on info@bentleybosphorushotel.com pages, will be processed if the form on the page is filled in and a copy of the ID is attached to it, and sent to the address on the form by registered letter with return receipt requested. Rights regarding personal data can only be exercised about personal data. Requests regarding the data of people other than the person who filled out the form and whose ID photocopy is attached will not be considered. Forms without an ID photocopy will not be considered. Even when data deletion requests are fulfilled, If requested, we inform you that we are obliged to share the data with the official authorities. Changes to be made in the Protection of Personal Data and Privacy Policy: “Bentley Bosphorus Hotel” reserves the right to make changes on the statements herein. If a significant change is made in the statement, a link to the current statement is added to the home page of the website. Guests who register for any of our products or services can be informed about this issue through the communication channel given to the facilities. The last time the declaration was updated and the update number are indicated at the end of this text. Any changes made in the statement will become effective with the publication of the amended statement on the site. Using the site or any of our products and services following such changes indicates your acceptance of the then-current amended statement.