CLARIFICATION TEXT
ON THE PROTECTION OF PERSONAL DATA

 

 

1. Purpose and Scope of the Directive

Within the scope of Law No. 6698 on the Protection of Personal Data (“KVKK”), personal data refers to any information relating to an identified or identifiable natural person. According to the provisions of the KVKK, the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system is qualified as the data controller. Within the scope of the LPPD, your personal data regarding your transactions on the website www.fulyapension.com (“Website”) will be processed by Fulya Pension (“Fulya Pension”) as the data controller within the scope, purposes and legal reasons described below. In this Clarification Text document, the Website will be referred to as the “Environment”.

This Disclosure Text has been prepared in order to inform the real persons whose personal data are processed by Fulya Pension as the data controller within the framework of Article 10 of the KVKK and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Disclosure Obligation. Being transparent and accountable is important for Fulya Pension. In this context, the Disclosure Text includes information on the identity of the data controller and its representative, if any, the purpose for which personal data will be processed, to whom and for what purpose personal data may be transferred, the method and legal reason for collecting personal data, and other rights of the data subject listed in Article 11 of the LPPD.

Fulya Pension may update the Clarification Text in case of changes in the applicable legislation, decisions of the Personal Data Protection Board, judicial decisions, changes in the methods, purposes, reasons for processing and/or transferring personal data, or similar developments. If the Clarification Text is updated, the updated text will be published on the Medium. Fulya Pension may publish other clarification texts, rules, conditions or other explanations through the Medium within the framework of its activities regarding the processing and/or transfer of personal data. If you have any questions regarding the issues in this Clarification Text, we kindly ask you to contact us at [email protected] e-mail address.

2. Methods of Collecting Personal Data and Legal Basis

Ensuring the security of personal data is one of our primary goals. Your personal data is processed by Fulya Pansiyon in accordance with the provisions of the Constitution of the Republic of Turkey, the KVKK, the Law No. 6563 on the Regulation of Electronic Commerce, the Turkish Penal Code No. 5237 and the relevant legislation.

 

Fulya Pension processes personal data; through the Environment, authorized agencies, service providers, intermediary service providers, social media accounts, cookies, call center, correspondence (messaging) applications on the Environment, notifications from administrative and judicial authorities and other communication channels; visually, audibly, physically, electronically, verbally or in writing; for the purposes of establishing commercial relations, receiving job applications, making offers, establishing a contractual relationship, fulfilling its obligations arising from the law and/or within the framework of its legitimate interests; in accordance with the personal data processing conditions specified in the KVKK and in line with the legal reasons specified in this Clarification Text.

 

When you interact with Fulya Pension through Facebook, Twitter, Instagram and Youtube channels used by Fulya Pension as social media environment, your personal data you provide to the relevant social media environment can also be processed by Fulya Pension. However, we would like to point out that the use of social media environments, the content and features provided are subject to the relevant environment's own privacy and usage policies.

 

It uses “cookies” (cookies or cookies) to help you personalize your online experience and to enable you to log in to our services. Fulya Pension collects personal data for different purposes through cookies on the environment. Cookies are text files placed on visitors' computers by visited websites. Cookies are widely used in almost all websites in order for websites to work effectively and for the preferences of visitors and also to provide information to the administrators of the website. Cookies are used to determine the preferences of our visitors, to determine the requests for a featured page, to improve the experience of using the environment, to keep our services secure and to provide online behavioral advertising activities to our users.

 

Our Website uses Google Analytics, an analysis service of Google Inc. (“Google”). Google Analytics uses “cookies”, i.e. text files that are stored on your computer and that enable the analysis of your use of the website. The information generated by the cookies about your use of the website is transmitted to a Google server in the USA and stored there. On instructions from the operator of this website, Google will use this information to evaluate your use of this website and to compile reports in order to provide related services. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. If you do not want these cookies to be stored, you can set your browser accordingly.

 

In addition, AdWords and double-click cookies are used on our website for statistical purposes. We use third-party cookies and our own cookies to show you personalized advertisements on websites. This is called “retargeting” and aims to be based on the pages you have browsed on our Website, the products you have viewed and your clicks on the advertising space (banner) shown to you. We also use cookies as part of our online marketing campaigns to see how users interact with our Media after being shown online advertisements, including those on third party websites. You can delete these cookies from your browser at any time.

 

Many internet browsers are set to automatically accept cookies by default. If you do not want these tools to be used, you can disable them by setting them in your browser. However, we would like to point out that in this case you may not be able to use all functions on the Media to the full extent.

3. Processed Personal Data

Your processed personal data may vary depending on the nature of the legal relationship you have established with Fulya Pension. However, in general terms, the personal data we process are as follows:

Identity Information

Your personal data such as name, surname, identity information, date of birth, date of birth, driver's license information, passport number, nationality, etc. that you have provided when booking a hostel through the environment and similar services, in calls made through live support or call center and in all kinds of applications.

Contact Information

Your personal data such as e-mail address, telephone number, mobile phone number, social media contact information, address, etc. that you have provided when booking a hostel through the environment and similar services, in conversations via live support or call center and in all kinds of applications.

Customer (Including Guest, etc.) Information

Your personal data relating to name, surname, nationality, date of birth, Turkish ID number, passport number, driver's license, gender, reservation information, purchase information, billing information, delivery information, travel information, travel dates, accommodation information, location information, reservation information, customer transaction information, type and number of travel documents, start and end dates of validity and the country of issue; call center records, credit card statements, box office account documents, customer instructions, records recorded in channels for this purpose, etc. Your personal data, information and records collected within the scope of requests and complaints and their results, and the website password and password information you create while using our services offered in virtual environments.

Financial Information

Credit/debit card information, bank account information, IBAN information, balance information, receivable balance and other financial information.

Sensitive Data

Sensitive personal data such as necessary information regarding your health status, disability information, HES code, which may affect the service you receive, which is clearly stipulated in the legislation and processed upon your explicit consent and where necessary for our transactions.

Marketing Information

Authors showing the likes of the person to be used for marketing purposes, targeting information, cookie records, information derived from data enrichment activities, information and evaluations obtained as a result of surveys, campaigns and direct marketing activities.

Transaction Security Information

IP address information, password and password information, cookie information

Other Information

Information on family members and relatives (identity and contact information on children and spouses of the relevant persons), physical space security information (entry/exit records, visit information, photographs, camera and audio recordings), legal proceedings and compliance information (information requests from judicial and administrative authorities, etc.).

4. Purposes of Processing Personal Data

Pursuant to KVKK, personal data cannot be processed without the explicit consent of the person concerned. Fulya Pension processes your personal data when and to the extent permitted by the legislation.

Within this framework, the purposes of processing your personal data are as follows:

• Confirm the credentials of the person booking the hostel and the person on whose behalf the hostel is booked via the medium,

• Save the address and other necessary information for contact,

• Execution of processes for the establishment and performance of contracts,

• To communicate with our customers regarding the conditions, current status and updates of the contracts we have concluded under the relevant articles of the Distance Sales Contract and the Law on Consumer Protection, to provide the necessary information, to fulfill the obligations undertaken in accordance with the contracts we have concluded,

• To organize all records and documents that will be the basis of the transaction in electronic or paper environment,

• To be able to provide information to public officials on matters related to public security upon request and in accordance with the legislation,

• To provide a better service to our customers, to inform our customers about our products that our customers may be interested in, taking into account the interests of our customers, and to convey campaigns,

• To provide information to our customers via e-mail or text message within the framework of the Law on the Regulation of Electronic Commerce and the relevant legislation,

• To increase customer satisfaction, to recognize our customers from the Environment and to use them in customer environment analysis, to use them in various marketing and advertising activities and to organize surveys in electronic and/or physical environment through contracted organizations in this context,

• To be able to offer suggestions to our customers by our contracted institutions and solution partners and to inform our customers about our services,

• To evaluate customer complaints and suggestions regarding our services,

• To carry out goods and services production, operation and sales processes, financial and accounting activities and archive activities,

• Ensuring information security,

• To fulfill our legal obligations and to exercise our rights arising from applicable legislation.

In addition, the personal data of our employees may be processed without obtaining consent to the extent necessary for business relations. The terms and conditions specified in the Policy on the Protection and Processing of Personal Data of Employees apply to the processing of personal data of our employees.

5. Rights and Obligations of our Company Arising from the Law

Personal data are processed by our Company in accordance with Article 20 of the Constitution and Article 4 of the LPPD;

• In accordance with the law and good faith,

• Accurate and up to date,

• For specific, explicit and legitimate purposes,

• Linked to processing purposes,

• In a limited and measured way,

It is processed and transferred based on the conditions specified in Articles 5 and 6 of the KVKK, by being kept for the period stipulated in the laws or required by the purpose of personal data processing.

 

Personal data shared with Fulya Pension is under the supervision and control of Fulya Pension. Fulya Pansiyon has assumed the responsibility as the data controller to establish the necessary arrangements and take and adapt technical measures to protect the confidentiality and integrity of the information in accordance with the provisions of the relevant legislation in force. Being aware of our obligation in this regard, we would like to state that we have taken the following administrative and technical security measures. In this context, we would like to inform you that we always update our data processing policies.

 

Fulya Pension keeps the personal data it processes for the periods specified in the legislation, and if no additional period is specified in the legislation; personal data are stored for the period required to be processed in accordance with the practices and customs of Fulya Pension's practices and commercial life, depending on the services provided by Fulya Pension while processing the relevant personal data, and after this period, only for the periods required in practice to constitute evidence in possible legal disputes. After the expiration of the specified periods, the personal data in question are deleted, destroyed or anonymized.

6. Transferring Personal Data

The sharing of personal data with third parties is realized within the framework of the legislation in force and/or the explicit consent given by the data subjects. However, personal data is shared with courts and other public institutions due to and limited to our legal obligations.

 

In addition, personal data is transferred to third parties within the framework of a contractual relationship in order to provide the services we undertake and to audit the quality of the services provided. Necessary technical and administrative measures are taken to prevent data breaches during data transfer to third parties. For example, during data transfer; SSL and transport layer are used.

 

Your personal data may be shared with program partner institutions and organizations that we cooperate with in order to carry out our activities, with third parties who have the title of service provider and/or intermediary service provider, with our business partners who provide special integrator services, with third parties who provide independent auditing, with domestic persons and institutions that we receive data storage services in the cloud environment, with domestic organizations that we have contracted to send commercial electronic messages to our customers, with our financial advisors, with the Interbank Card Center, with our contracted banks, payment service providers and various agencies, advertising companies and survey companies in the country and other third parties in the country within the scope of various marketing activities in order to provide you with better service and customer satisfaction, and with our related business partners, shareholders and affiliates, and with third parties, lawyers, consultants and legally authorized public institutions and private law legal entities from which we receive services under a contractual relationship.

7. Rights of the Relevant Person

According to Article 11 of the LPPD, the data subject

• To learn whether personal data about him/her is being processed,

• Request information if personal data about him/her has been processed,

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

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

• To request correction of personal data in case of incomplete or incorrect processing,

• To request the deletion or destruction of personal data in the event that the reasons requiring its processing disappear, although it has been processed in accordance with the provisions of the Law and other relevant laws,

• To request notification of the transactions made as a result of correction, deletion and destruction requests to third parties to whom personal data are transferred,

• To object to the emergence of a result against the person himself/herself by analyzing the processed data exclusively through automated systems,

• In case of damage due to unlawful processing of personal data, it has the right to demand the compensation of the damage.

 

In order to exercise these rights, you may submit your request in this direction in accordance with Article 13 of the KVKK and in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller, to Fulya Pension's “Kale Mah. Cami Yanı Sok. No: 9 Eğirdir/ISPARTA” address, your name and surname and your signature, if you are a citizen of the Republic of Turkey, your T.R. If you are a citizen of the Republic of Turkey, your identity number, if you are not a citizen of the Republic of Turkey, your nationality, passport number or identification number, if any, your residential or workplace address for notification, your e-mail address and telephone number for notification, and the necessary information and documents to determine the subject of the request and your identity and/or by using the Application Document, you can apply in writing, via your e-mail address where your membership is confirmed, or if you do not have any membership, you can apply via e-mail to receive general information about KVKK.

Your application will be evaluated by Fulya Pension and finalized free of charge within thirty days. However, if the transaction requires an additional cost, the fee in the tariff determined by the Personal Data Protection Board may be requested.

 

Data Controller	:	Fulya Pension
VD / VKN	:	Eğirdir V.D. 0090232294
Address	:	Kale Mah. Cami Yanı Sok.No: 9 Eğirdir / ISPARTA
KEP address	:	[email protected]
Contact Phone	:	+90 542 241 72 13
Business License	:	27/08/2024 - 23480
Tradesman Registry No.	:	EĞİRDİR - 42/41365
Sustainability Certificate	:	RYL-V1-HI-00457
MERSİS
E-Mail address	:	[email protected] [email protected]