Onze Hotels
PERSONAL DATA PROCESSING INFORMATION NOTICE
Dear Guests,
As Ekkan İnşaat ve San. A.Ş. and İmamlar Otelcilik ve Tic. A.Ş. (the "Company"), we attach great importance to the protection of your personal data. In this respect, your personal data are processed by us, in our capacity as the data controller, in accordance with the Turkish Personal Data Protection Law No. 6698 ("KVKK") and within the framework of the principles and procedures set out below.
This Information Notice has been prepared to inform you about the categories of personal data processed, the purposes for which your personal data are processed, the legal grounds for processing, the parties to whom your personal data may be transferred, the applicable retention periods, and your rights under the KVKK.
1. Identity of the Data Controller
Company Name: Ekkan İnşaat ve San. A.Ş. (Side Star Elegance)
Address: Side Mah. Celal Bayar Bulvarı Sok. No: 3, 07330 Manavgat / Antalya, Türkiye
E-mail: elegance@sidestarhotels.com
Company Name: İmamlar Otelcilik ve Tic. A.Ş. (Side Star Resort)
Address: Gündoğdu Mah. Fesleğenli Cad. No: 11, 07330 Manavgat / Antalya, Türkiye
E-mail: resort@sidestarhotels.com
Company Name: İmamlar Otelcilik ve Tic. A.Ş. (Side Star Beach)
Address: Side Mah. Kiremithane Sk. No: 6, 07330 Manavgat / Antalya, Türkiye
E-mail: beach@sidestarhotels.com
Company Name: İmamlar Otelcilik ve Tic. A.Ş. (Side Star Park)
Address: Side Mah. Özal Cad. No: 17, 07330 Manavgat / Antalya, Türkiye
E-mail: park@sidestarhotels.com
2. Categories of Personal Data We Process
Within the scope of our accommodation and hospitality services, the following categories of personal data may be processed:
Identity Information: Full name, date of birth, Turkish Identity Number, passport number.
Contact Information: Address, postal code, e-mail address, telephone number, Registered Electronic Mail (KEP) address, and, where voluntarily provided by you, social media contact information.
Financial Information: E-invoice information, payment and expenditure records, and information relating to accounting and financial processes.
Health Information (Special Categories of Personal Data): Limited health information voluntarily provided by you, such as food allergies, special dietary requirements, or requests for special services related to your health condition, provided that your explicit consent has been obtained. Such data are not mandatory for the provision of accommodation services and are not processed without your explicit consent.
Visual Records: CCTV recordings collected for the purpose of ensuring the security of the premises, and photographs and video recordings taken for promotional purposes where your explicit consent has been obtained.
Physical Premises Security Information: Facility entry and exit records and CCTV footage.
Location Information: Travel and transfer information, together with limited information relating to transportation arrangements, for the purpose of organizing transfer and transportation services.
Transaction Security Information: IP address, log records, internet access and traffic information, and login records obtained through the use of the website and mobile applications, including records maintained pursuant to Law No. 5651.
Guest Reviews, Feedback, and Complaint Information: Evaluations, comments, complaints, satisfaction records, reservation details, and room number relating to the facilities and services.
Preference Information: Accommodation preferences, special requests, previous service requests, and information relating to your interests.
Marketing Information: Where your explicit consent has been obtained, accommodation history, cookie records, loyalty programme membership information, communication preferences, and special occasion information.
Other Information: Vehicle registration number, travel agency or company information, guest parcel acceptance records, written or electronic communications, signatures obtained during check-in procedures, signatures relating to room changes or upgrades, signatures for lost property deliveries, signatures confirming the receipt of personal deliveries or orders, occupation information, and information voluntarily provided by you within the scope of personal assistant services.
3. Purposes of Processing Personal Data
Your personal data are processed in accordance with Articles 5 and 6 of the Turkish Personal Data Protection Law No. 6698 for the following purposes:
· Conducting Reservation Processes and Providing Accommodation Services
Your personal data are processed for the purposes of creating, planning, and managing your reservations, providing accommodation services, completing online check-in procedures, verifying your identity, and delivering accommodation-related services upon your request.
Where voluntarily provided by you, information such as pillow preferences, room preferences, food allergies, or special dietary requirements is processed solely on the basis of your explicit consent and only to the extent necessary for providing the requested service. Providing such information is not mandatory for the provision of accommodation services.
· Provision of Personalized Services
Where requested by you, your accommodation preferences, special requests, previous service requests, and your name, surname, and room number are processed for the purpose of arranging reservations for à la carte restaurants, pavilions, and similar facilities.
Where children participate in Mini Club activities, the child's name, surname, room number, and the parent or guardian's contact information are processed solely for the safe organization of such activities.
Health information relating to children is processed only where explicit consent has been provided and only where necessary.
Information that has been made publicly available by you through public platforms may be taken into consideration only where relevant to the requested service and only to the extent necessary.
· Conducting Communication Activities
Your personal data are processed for the purpose of sending reservation information, providing accommodation-related notifications, offering personal assistant services upon request, and informing you about payment processes.
· Evaluation of Requests, Opinions, and Complaints
Your personal data are processed for the purposes of measuring, improving, and enhancing guest satisfaction, planning and carrying out guest relations processes, and receiving, evaluating, and resolving requests, suggestions, and complaints.
· Fulfilment of Legal Obligations
Your personal data are processed for the purpose of fulfilling obligations arising under applicable national and international legislation, responding to requests from competent public authorities, conducting legal proceedings, and responding to applications submitted by data subjects in accordance with applicable legislation.
· Conducting Accounting and Financial Processes
Your personal data are processed for carrying out accounting and financial operations, processing payments, managing invoicing procedures, and providing financial documents upon request.
· Ensuring Physical Premises Security
Your personal data are processed for ensuring the security of our facilities and premises, monitoring visitor entry and exit, and carrying out security activities through CCTV systems.
· Ensuring Transaction Security
Your personal data are processed to ensure transaction security during the use of the website, mobile applications, and wireless networks, to prevent unauthorized access, maintain log and traffic records, prevent fraud, and ensure information security.
· Management of VIP Club Membership Processes
Where you are a member of the VIP Club programme, your personal data are processed for enabling you to benefit from membership services, and for managing points accumulation and reward processes.
· Conducting Advertising and Marketing Activities
Your personal data are processed solely where you have provided your explicit consent for the purpose of informing you about our hotel and services, conducting promotional and marketing activities, and sending greetings and celebratory messages.
Where you do not provide explicit consent, no processing of your personal data for marketing purposes will be carried out.
Personal data processed for the above purposes are retained in physical archives and/or electronic information systems in accordance with applicable legislation, with appropriate administrative and technical safeguards in place.
5. To Whom and for What Purposes Your Personal Data May Be Transferred
Your personal data may be transferred, to the extent necessary and in accordance with the conditions set out in Articles 8 and 9 of the Turkish Personal Data Protection Law No. 6698, solely for the purposes specified below.
Transfer for the Fulfilment of Legal Obligations
In order to fulfil legal obligations arising from the legislation applicable to our hotel, your personal data may be shared with competent judicial authorities, the General Directorate of Security, other law enforcement authorities, and authorized public institutions and organizations pursuant to the Identity Notification Law, the Tax Procedure Law, and other applicable legislation.
· Sharing with Our Legal Advisors
Your personal data may be shared with our attorneys, limited to the extent necessary, for the purposes of fulfilling legal obligations, conducting legal proceedings, managing litigation and disputes, and obtaining legal consultancy services.
· Sharing with Group Companies
Where you are a member of the VIP Club programme, only the personal data necessary for the operation of the membership programme (such as loyalty point information) may be shared with Ekkan İnşaat ve San. A.Ş. and İmamlar Otelcilik ve Tic. A.Ş. for the purposes of managing membership benefits, reward programmes, and related services.
· Sharing with Business Partners and Suppliers
Within the scope of providing accommodation services, your personal data may be shared, where necessary and only for the relevant purpose, with:
· banks for payment and financial transactions;
· travel agencies for reservation and sales processes;
· transfer and transportation service providers;
· ticketing, CIP, and pre-flight hospitality service providers;
· concierge service providers;
· hotel management system and software service providers; and
· commercial units operating within the hotel premises.
· Sharing with Legal Representatives
Your personal data may be shared with your duly authorized legal representative upon a valid request and only to the extent of the authority granted.
· Information Technology Systems and Digital Service Providers
Your personal data may be shared with information technology service providers acting as data processors on behalf of our Company, website and application infrastructure providers, server hosting providers, and technical support service providers solely for the purposes of ensuring the operation, security, and continuity of our information systems.
Where cloud computing services are used, data transfers are carried out with the necessary administrative and technical safeguards in place.
· Transfer within the Scope of Audit and Compliance Processes
Your personal data may be shared with independent audit firms, information security service providers, and competent regulatory and supervisory authorities for the purposes of conducting internal and external audits, quality assurance activities, information security audits, and legal compliance reviews.
· Transfer for Promotional Activities
Where you have provided your explicit consent, photographs, video recordings, and limited personal data such as your name and surname may be used on our hotel's website, social media accounts, and at international trade fairs for the purpose of promoting our hotel and its projects.
Where explicit consent has not been provided, no such processing or transfer shall take place.
2. Method of Collection and Legal Grounds for Processing Your Personal Data
Your personal data are collected and processed in accordance with the KVKK, by automated or non-automated means, either verbally, in writing, or electronically, through physical or digital channels, for the purposes specified in Section 2 of this Information Notice.
The sources through which personal data may be collected include, but are not limited to:
· Legal Grounds
Your personal data collected through the methods described above are processed on the basis of the following legal grounds under the KVKK:
· Processing Through Security Cameras
Security camera systems are used throughout the hotel facilities and premises for the purposes of ensuring physical security, monitoring entry and exit points, and preventing potential security risks.
Camera recordings are processed pursuant to Article 5/2(ç) (legal obligation) and Article 5/2(f) (legitimate interest) of the KVKK.
No audio recordings are made through the security camera systems.
· Processing of Social Media Content
Photographs and videos relating to your stay that you have made publicly available on social media platforms and associated with our Company by tagging our official accounts may be processed pursuant to Article 5/2(d) of the KVKK, on the legal basis that the data have been manifestly made public by the data subject.
Such processing is limited exclusively to promotional and communication activities. No use beyond this scope shall be made.
· Processing of Special Categories of Personal Data (Health Data)
Special categories of personal data, including health information, are not required for the provision of accommodation services and are not requested as a condition for receiving such services.
However, where you voluntarily request personalized services (such as those relating to food allergies, special dietary requirements, or room or pillow preferences based on your health condition), your health data shall be processed only where you have provided your explicit consent and solely to the extent necessary for providing the requested service.
Failure to provide explicit consent shall not restrict or adversely affect your access to accommodation services.
Health data shall be erased, destroyed, or anonymized immediately upon withdrawal of your explicit consent or once the purpose of processing no longer exists.
6. Scope and Amendment of the Personal Data Protection and Processing Policy
This Information Notice has been prepared by the Data Controller in accordance with the Turkish Personal Data Protection Law No. 6698.
Ekkan İnşaat ve San. A.Ş. and İmamlar Otelcilik ve Tic. A.Ş. reserve the right to amend this Personal Data Processing Information Notice, provided that such amendments comply with the Law, the decisions of the Personal Data Protection Board, and serve the purpose of ensuring a higher level of protection for personal data.
7. Information Regarding Commercial Electronic Communications
Pursuant to the Law No. 6563 on the Regulation of Electronic Commerce and the Regulation on Commercial Communication and Commercial Electronic Messages, your personal data may be processed, only where you have provided your explicit consent, for the purposes of informing you about our services, promoting our products and services, conducting marketing activities, and notifying you about our campaigns.
In accordance with the applicable legislation, your commercial electronic communication consent must be recorded in the Message Management System (İYS).
The information to be transferred to the İYS is limited to:
If you do not provide consent to receive commercial electronic communications, no promotional or marketing communications will be sent to you. Your decision not to provide such consent will not affect your ability to benefit from accommodation services or any other core services.
Further information regarding the Message Management System (İYS) is available at https://iys.org.tr/ .
8. Your Rights Regarding the Protection of Your Personal Data
With respect to the personal data processed by Ekkan İnşaat ve San. A.Ş. and İmamlar Otelcilik ve Tic. A.Ş., you may at any time exercise the rights granted to you under Article 11 of the Turkish Personal Data Protection Law No. 6698.
Accordingly, you have the right to:
9. Application Procedure
You may submit your requests concerning your rights under Article 11 of the Turkish Personal Data Protection Law No. 6698 by completing the Application Form under the Turkish Personal Data Protection Law, available at:
https://www.sidestarhotels.com/hotels/en/page/pdpp
Your completed application may be submitted to our Company by one of the following methods:
Your application will be concluded free of charge as soon as possible and, in any event, within thirty (30) days, depending on the nature of your request.
However, where the processing of the application requires additional costs, a fee may be charged in accordance with the tariff determined by the Turkish Personal Data Protection Board.
Applications must be submitted in compliance with the procedures and principles set out in the Communiqué on the Principles and Procedures for Applications to the Data Controller.
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