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 Elantra Turizm Tekstil İnş. San. ve Tic.
Ltd. Şti. 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 ‘’ Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti.’’, 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 Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti.” 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: “Elantra Turizm Tekstil
İnş. San. ve Tic. Ltd. Şti.” 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 “Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti.” to protect the
personal data.
b) Being accurate and up to date, if necessary: “Elantra Turizm Tekstil İnş.
San. ve Tic. Ltd. Şti.” 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: “Elantra
Turizm Tekstil İnş. San. ve Tic. Ltd. Şti.” 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: “Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti.” 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: “Elantra Turizm
Tekstil İnş. San. ve Tic. Ltd. Şti.” 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 “Elantra Turizm Tekstil İnş. San. ve Tic.
Ltd. Şti.” 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 “Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti.” 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 “Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti.”
are processed as declared by the relevant persons as a rule. “Elantra Turizm
Tekstil İnş. San. ve Tic. Ltd. Şti.” is not obliged to check up on the accuracy
of the data declared by the customers or the persons in touch with “Elantra
Turizm Tekstil İnş. San. ve Tic. Ltd. Şti.” 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 “Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti.”. 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 “Elantra Turizm Tekstil İnş. San. ve Tic.
Ltd. Şti.” 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 “Elantra Turizm Tekstil
İnş. San. ve Tic. Ltd. Şti.” 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 “Elantra Turizm Tekstil İnş. San.
ve Tic. Ltd. Şti.” 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 “Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti.”,
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).
·
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
“Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti.” 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. “Elantra
Turizm Tekstil İnş. San. ve Tic. Ltd. Şti.” 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 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.
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. “Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti. ” also takes
adequate measures determined by the Board for the processing of special quality
data.
“Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti. ” may process the special
quality data only for the corresponding purposes to provide better
services.
Data processed with automatic systems
“Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti.” 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, “Elantra Turizm Tekstil İnş. San. ve Tic. Ltd.
Şti.” 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 Elantra Turizm Tekstil İnş. San.
ve Tic. 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 Elantra Turizm
Tekstil İnş. San. ve Tic. 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 Euphoria 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, “Elantra Turizm Tekstil İnş. San. ve Tic. Ltd.
Şti.” hereby undertakes the protection and confidentiality of the data of the
employees.
Processing as per Legal Obligations
“Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti.” 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
“Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti.” 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, “Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti.” 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, “Elantra Turizm Tekstil İnş.
San. ve Tic. Ltd. Şti.” 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,solution partners and subsidiaries
for the purpose of providing the services by “Elantra Turizm Tekstil İnş. San.
ve Tic. Ltd. Şti”.
“Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti” will be entitled to
transfer the personal data for certain purposes to the following person and
institutions;
» Business partners of “Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti”
limited to the purpose of execution of the aims of the establishment of the
business partnership,
» The suppliers of “Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti” 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 “Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti”
limited to ensuring the execution of the commercial activities which require
the participation of the affiliates of the company,
“Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti ‘’ 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
“Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti” 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 “Elantra
Turizm Tekstil İnş. San. ve Tic. Ltd. Şti”;
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. “Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti” 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 completely filling
out and putting their wet signatures on the application form given at www.euphoriahotels.com, the official website
of the company, 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. “Elantra
Turizm Tekstil İnş. San. ve Tic. Ltd. Şti” can only request information and
document from the application holders.
IX. Confidentiality Principle
The data of the employees and other persons within “Elantra Turizm Tekstil İnş.
San. ve Tic. Ltd. Şti” 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 “Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti”
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
“Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti” carries out the internal
and external inspections for protection of the personal data.
XII. Notification of Violations
“Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti” 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 http://www.euphoriahotels.com/kvkk/en-US
Requests made pursuant to the Act on the Protection of
Personal Data
As announced on http://www.euphoriahotels.com/kvkk/en-US 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.
Click for application form
Changes to Be Made in Personal Data Protection and
Privacy Policy:
“Elantra Turizm Tekstil İnş. San. ve Tic. Ltd. Şti”
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.
Contact
You can contact us for further questions on the
confidentiality agreement by using the following contact information.
Euphoria Hotels & Resorts
Satış ve Pazarlama Merkez Ofisi
Yeşilova Mah. Aspendos Bulv. No:168-C Muratpaşa / Antalya / Turkey