When you visit this website and use the services we offer through it, the use and protection of the information we obtain about you and the services you request shall be subject to the terms set forth in this “Privacy Policy.” By visiting this website and requesting to benefit from the services offered through it, you accept the terms of this “Privacy Policy.”
I. Purpose of the Personal Data Protection and Processing Policy
In accordance with the sensitive nature of our business, Demirci Turistik Tesisleri İşl. A.Ş. has always treated the data received from our customers and prospective customers as confidential and has never shared such data with third parties without a lawful basis. The protection of personal data is one of our company's fundamental principles. Even before the enactment of specific legislation, our company and its affiliates attached great importance to the confidentiality of personal data, adopted this principle as a standard of conduct, and instructed their employees to act accordingly.
As the owner and operator of TUI BLUE Xanthe, TUI BLUE Side, and The Sense De Luxe Hotel, Demirci Turistik Tesisleri İşletmeleri A.Ş. undertakes to comply with all obligations imposed by the Personal Data Protection Law. The principles adopted by our companies regarding the protection of personal data also apply to our affiliates.
II. Scope and Amendment of the Personal Data Protection and Processing Policy
This Policy has been prepared by our company in accordance with Personal Data Protection Law No. 6698 (“KVKK”). As of the date of this Policy, all provisions of the Law have entered into force.
The data obtained from you with your consent or on other lawful grounds specified in the Law shall be used to improve the quality of our services, enhance the services provided to you, and improve our quality policies. Certain data held by us may also be anonymised so that it no longer qualifies as personal data. Such data may be used for statistical purposes and shall not be subject to the Law or this Policy to the extent that it has been effectively anonymised in accordance with applicable legislation.
The “Demirci Turistik Tesisleri İşl. A.Ş. Personal Data Protection and Processing Policy” aims to protect automatically collected data relating to our customers, prospective customers, employees, customers and employees of companies with which we cooperate, and other individuals, and sets out the relevant principles and procedures.
Our company reserves the right to amend this Policy and its associated procedures, provided that such amendments comply with the Law and enhance the protection of personal data.
III. Fundamental Principles Regarding the Processing of Personal Data
**a) Compliance with the law and the principles of good faith:** Demirci Turistik Tesisleri İşl. A.Ş. verifies the source of the data it collects or receives from other companies and attaches importance to ensuring that such data is obtained lawfully and in accordance with the principles of good faith. In this context, the company provides the necessary warnings and notifications to third parties that sell or facilitate the sale of its services, including travel agencies and other intermediaries, regarding the protection of personal data.
**b) Accuracy and keeping data up to date where necessary:** Demirci Turistik Tesisleri İşl. A.Ş. ensures that the data held within the company is accurate and does not contain incorrect information. Where personal data changes, the company takes the necessary steps to update it upon being notified of such changes.
**c) Processing for specific, explicit and legitimate purposes:** Demirci Turistik Tesisleri İşl. A.Ş. processes data only for specific, explicit and legitimate purposes associated with the services it provides and in accordance with the applicable legal grounds and, where required, the consent obtained from the relevant individuals. Data shall not be processed, used or made available for purposes unrelated to the stated purposes.
**d) Processing in a manner that is relevant, limited and proportionate to the purpose:** Demirci Turistik Tesisleri İşl. A.Ş. uses personal data only to the extent necessary for the purpose for which it is processed and the requirements of the relevant service.
**e) Retention for the period stipulated by applicable legislation or required for the purpose of processing:** Demirci Turistik Tesisleri İşl. A.Ş. retains data arising from contractual relationships for the periods required by applicable limitation periods, commercial legislation, tax legislation and other relevant legal obligations. Once these purposes cease to apply and no other lawful retention ground remains, the data shall be deleted, destroyed or anonymised.
It is important to emphasise that these principles apply regardless of whether Demirci Turistik Tesisleri İşl. A.Ş. has collected or processed the data on the basis of consent or another lawful ground.
Under Article 11 of the Personal Data Protection Law, you have the rights listed below. To facilitate the exercise of these rights, Demirci Turistik Tesisleri İşl. A.Ş. has also prepared an application form.
Individuals whose personal data is processed may contact the relevant department through the channels announced on our website and exercise the following rights in relation to their personal data:
a) To learn whether their personal data is being processed;
b) To request information if their personal data has been processed;
c) To learn the purpose of processing their personal data and whether the data is being used in accordance with that purpose;
ç) To know the third parties, in Türkiye or abroad, to whom their personal data has been transferred;
d) To request the correction of incomplete or inaccurate personal data;
e) To request the deletion or destruction of personal data under the conditions stipulated by the Law;
f) To request notification of the correction or deletion of personal data to third parties to whom the data has been transferred;
g) To object to any adverse outcome arising from the analysis of their personal data exclusively through automated systems;
ğ) To claim compensation for damages incurred as a result of the unlawful processing of their personal data.
Demirci Turistik Tesisleri İşl. A.Ş. respects these rights.
Data Minimisation Principle
Under the principle of data minimisation, also referred to as the principle of data economy, Demirci Turistik Tesisleri İşl. A.Ş. records only the data necessary for the relevant purpose. The categories of data collected are therefore determined according to the intended purpose. Data that is not necessary is not collected.
Other data received by our company is handled in the same manner. Excessive or unnecessary information is not entered into our information systems and is deleted or anonymised where appropriate. Anonymised data may be used for statistical purposes.
Special-category personal data concerning health is collected only where necessary to provide better services to customers and protect their health, and is handled with appropriate care and security measures.
Deletion of Personal Data
When the statutory retention periods expire, judicial proceedings are concluded, or other requirements for retaining the data cease to exist, our company shall delete, destroy or anonymise the relevant personal data, either automatically or upon the request of the data subject, where legally permissible.
Accuracy and Updating of Data
As a general rule, the data held by Demirci Turistik Tesisleri İşl. A.Ş. is processed based on the declarations made by the relevant individuals.
Demirci Turistik Tesisleri İşl. A.Ş. does not ordinarily independently investigate the accuracy of the information declared by customers or other individuals who contact the company, subject to applicable legal obligations. Declared information is generally taken as accurate unless there is a legal or other valid reason to establish otherwise.
Our company also adopts the principle of accuracy and keeping personal data up to date. Personal data is updated when necessary based on official documents received by the company or upon a request from the relevant individual. The company takes the necessary measures to ensure such updates.
Confidentiality and Data Security
Personal data is confidential, and Demirci Turistik Tesisleri İşl. A.Ş. respects this confidentiality. Within the company, access to personal data is restricted to authorised personnel.
All necessary technical and administrative measures are taken to protect the personal data collected by Demirci Turistik Tesisleri İşl. A.Ş., prevent unauthorised access, and avoid harm to our customers and prospective customers. These measures include ensuring that software complies with applicable standards, carefully selecting third-party service providers, and enforcing compliance with the company's data protection policy.
IV. Purposes of Data Processing
The collection and processing of personal data by Demirci Turistik Tesisleri İşl. A.Ş. shall be carried out for the purposes specified in the relevant privacy notice and information notice.
Data is collected and processed for the establishment and performance of contracts and to provide better services to customers.
V. Data Relating to Customers, Prospective Customers, Business Partners and Solution Partners
Collection and Processing of Data for Contractual Relationships
Where a contractual relationship has been established with our customers or prospective customers, the personal data collected may be processed without obtaining additional consent where a lawful basis for processing exists. Such processing shall remain limited to the purposes of the contract.
Data shall be used to facilitate the proper performance of the contract and to the extent required by the relevant service. Where necessary, customers may be contacted to update their information.
Data provided voluntarily by prospective customers is processed to enable our company to provide more accessible and higher-quality services in the future. If no contractual relationship is established, such data shall be deleted upon request where no other lawful basis for retention or processing applies.
Data Relating to Business Partners and Solution Partners
Demirci Turistik Tesisleri İşl. A.Ş. adopts the principle of acting lawfully when sharing data with its business partners and solution partners.
Data is shared with such parties only to the extent necessary for the relevant service and subject to appropriate confidentiality commitments. These parties are required to implement the necessary measures to ensure data security.
Processing of Data for Advertising Purposes
In accordance with Law No. 6563 on the Regulation of Electronic Commerce and the Regulation on Commercial Communication and Commercial Electronic Messages, commercial electronic messages for advertising purposes may be sent only to recipients whose prior consent has been obtained where such consent is legally required.
The recipient's consent must be clearly established. Demirci Turistik Tesisleri İşl. A.Ş. complies with the requirements governing the scope and validity of such consent.
The consent obtained shall cover commercial electronic messages sent to recipients' electronic communication addresses for the purpose of promoting the company's goods and services, marketing its business, increasing awareness of its operations, or enhancing its visibility through celebratory or goodwill messages.
Consent may be obtained in writing in physical form or through any electronic communication channel. The essential requirement is a positive declaration of intent to receive commercial electronic messages, together with the recipient's name, surname and electronic communication address.
Processing Required by Legal Obligations or Expressly Provided for by Law
Personal data may be processed without obtaining separate consent where such processing is expressly provided for by applicable legislation or is necessary to fulfil a legal obligation imposed by law.
The type and scope of the data processed must be necessary for the legally permitted processing activity and must comply with the relevant legal provisions.
Data Processing by the Company
Personal data may be processed in accordance with the services provided by the company and its legitimate purposes. However, data shall under no circumstances be used for unlawful services or purposes.
Processing of Special Categories of Personal Data
Under the Law, special categories of personal data include data relating to an individual's race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, appearance and dress, membership of associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data.
Demirci Turistik Tesisleri İşl. A.Ş. also implements the adequate safeguards determined by the Personal Data Protection Board for the processing of special categories of personal data.
For the purpose of improving the services provided, the company may process special categories of personal data only for the purposes for which they were collected and in accordance with the applicable legal conditions, including obtaining consent where required.
Data Processed Through Automated Systems
Demirci Turistik Tesisleri İşl. A.Ş. complies with the Law regarding data processed through automated systems.
Information derived from such data shall not be used against individuals without their explicit consent where such consent is legally required. However, Demirci Turistik Tesisleri İşl. A.Ş. may make decisions concerning individuals with whom it conducts business by using data held within its own systems, subject to applicable legislation and the rights of the individuals concerned.
User Information and the Internet
Where personal data is collected, processed or used through websites, other systems or applications belonging to Demirci Turistik Tesisleri İşl. A.Ş., the relevant individuals shall be informed through a privacy notice and, where necessary, information regarding cookies.
Users shall be informed about the applications available on our websites. Personal data shall be processed in accordance with applicable legislation.
VI. Data Relating to Our Employees
Processing of Data for Employment Purposes
The personal data of our employees may be processed without obtaining consent where necessary for the employment relationship and the provision of health insurance benefits, provided that a lawful basis for processing exists.
Demirci Turistik Tesisleri İşl. A.Ş. ensures the confidentiality and protection of employee data.
Processing Required by Legal Obligations
Demirci Turistik Tesisleri İşl. A.Ş. may process employees' personal data without obtaining separate consent where the processing is expressly required by applicable legislation or is necessary to fulfil a legal obligation imposed by law.
Such processing shall be limited to the obligations arising from applicable legislation.
Processing for the Benefit of Employees
Demirci Turistik Tesisleri İşl. A.Ş. may process personal data without obtaining separate consent where a lawful basis exists, including for purposes that benefit employees, such as private health insurance.
The company may also process employee data where necessary to resolve disputes arising from employment relationships, in accordance with applicable legislation.
Processing of Special Categories of Personal Data
Under the Law, special categories of personal data include data relating to an individual's race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, appearance and dress, membership of associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data.
Demirci Turistik Tesisleri İşl. A.Ş. implements the adequate safeguards determined by the Personal Data Protection Board when processing special categories of personal data.
Special categories of personal data may be processed only in accordance with the conditions stipulated by law. The explicit consent of the relevant individual shall be obtained where required, and processing without consent shall be permitted only in cases authorised by law.
Special-category data obtained from employees to enable them to benefit from insurance and healthcare services shall be used exclusively for the specified purposes and in accordance with applicable legislation.
Data Processed Through Automated Systems
Data relating to employees and processed through automated systems may be used in internal promotion processes and performance evaluations.
Employees have the right to object to outcomes that are adverse to them and may exercise this right in accordance with the company's internal procedures. Such objections shall also be evaluated internally.
User Information and the Internet
Where personal data is collected, processed or used through websites, other systems or applications belonging to Demirci Turistik Tesisleri İşl. A.Ş., the relevant individuals shall be informed through a privacy notice and, where necessary, information regarding cookies.
Users shall be informed about the applications available on our websites. Personal data shall be processed in accordance with applicable legislation.
When you visit our website, we provide the following information regarding the cookies we use or may use.
**Google (Analytics, DoubleClick)**
- **Purpose of use:** Measurement, advertising and website optimisation
- **Cookie types:** Functional and analytical cookies; advertising cookies
**Facebook**
- **Purpose of use:** Advertising
- **Cookie types:** Advertising cookies
**Insider**
- **Purpose of use:** Measurement, advertising and website optimisation
- **Cookie types:** Functional and analytical cookies; advertising cookies
**Hotjar**
- **Purpose of use:** Measurement and website optimisation
- **Cookie types:** Functional and analytical cookies; advertising cookies
**Third-party companies**
- **Purpose of use:** Advertising
- **Cookie types:** Functional and analytical cookies; advertising cookies
### Functional and Analytical Cookies
Functional and analytical cookies contain information used to remember your preferences, enable the website to function effectively, optimise the website to respond to user requests, and analyse how visitors use the website.
Depending on their nature and configuration, these cookies may contain personal information, such as a username.
Third-Party Cookies
The websites, mobile applications and mobile websites of Demirci Turistik Tesisleri İşl. A.Ş. work with reputable third-party advertising providers.
Third-party service providers may place their own cookies to deliver personalised advertisements. Cookies placed by third parties collect and process information about visitors' browsing activities on websites and analyse how visitors use those websites.
Advertising Cookies
Advertising cookies help present products and content similar to those that match your interests and preferences. They aim to enhance your browsing experience by providing a more advanced and personalised advertising portfolio.
The retention period for session, persistent, functional, analytical and advertising cookies described above is approximately two (2) months. You may adjust or remove cookies through your internet browser settings. The procedures for managing or deleting cookies may vary depending on the browser you use.
How Can I Delete Cookies?
Most internet browsers are configured to accept and use cookies automatically when first installed on your computer or device.
You can use your internet browser's help or settings menu to block cookies or receive a notification whenever a cookie is sent to your device.
For detailed information about the different ways to manage cookies and adjust the settings of your browser, please refer to the instructions or help section provided by your browser.
Telecommunications and the Internet
Computers, telephones, email accounts and other applications provided to employees by the company are allocated exclusively for business purposes.
Employees may not use these tools for personal purposes or private communications. The company may monitor and inspect the data held on these tools, subject to applicable legislation.
From the commencement of their employment, employees undertake not to store any non-business-related data or information on computers, telephones or other equipment allocated to them by the company.
VII. Transfer of Personal Data Within Türkiye and Abroad
Personal data may be shared by Demirci Turistik Tesisleri İşl. A.Ş. with business partners and solution partners where necessary to provide the relevant services.
Demirci Turistik Tesisleri İşl. A.Ş. may transfer personal data to the following persons and entities for the specified purposes:
- Business partners: To the extent necessary to fulfil the purposes for which the business partnership was established.
- Suppliers: To the extent necessary to enable suppliers to provide services obtained by our company from external sources and required for the conduct of our commercial activities.
- Solution partners: To the extent necessary to carry out commercial activities that require the participation of our company's affiliates.
Demirci Turistik Tesisleri İşl. A.Ş. may transfer personal data within Türkiye or abroad in accordance with the conditions stipulated by the Law and the Personal Data Protection Board, as well as other applicable legal requirements, including obtaining the relevant individual's consent where required.
VIII. Rights of the Data Subject
Demirci Turistik Tesisleri İşl. A.Ş. recognises that individuals have the right to be informed about the processing of their personal data and, following processing, to exercise their rights concerning such data in accordance with the Law.
By contacting the relevant department through the channels announced on our website, individuals may exercise the following rights regarding their personal data:
a) To learn whether their personal data is being processed;
b) To request information if their personal data has been processed;
c) To learn the purpose of processing their personal data and whether the data is being used in accordance with that purpose;
ç) To know the third parties, in Türkiye or abroad, to whom their personal data has been transferred;
d) To request the correction of incomplete or inaccurate personal data;
e) To request the deletion or destruction of personal data under the conditions stipulated in Article 7 of the Law;
f) To request notification of the correction or deletion of personal data to third parties to whom the data has been transferred;
g) To object to any adverse outcome arising from the analysis of their personal data exclusively through automated systems;
ğ) To claim compensation for damages incurred as a result of the unlawful processing of their personal data.
Individuals do not have rights over data that has been effectively anonymised and no longer qualifies as personal data under applicable legislation.
Demirci Turistik Tesisleri İşl. A.Ş. may share personal data with relevant public institutions and organisations where necessary for contractual or business relationships, the performance of judicial duties, or the exercise of legally authorised powers by public authorities, in accordance with applicable legislation.
Individuals may exercise their rights listed above by completing the application form available on the company's official website at www.emirhotels.com, signing it by hand, and sending it by registered mail with return receipt requested, together with a copy of their identification document (only the front side of the national identity card is required), to the contact address specified below.
Applications shall be answered as soon as possible, and in any event within thirty (30) days of receipt, depending on the nature of the request and in accordance with applicable legislation.
Applications must be submitted by registered mail with return receipt requested. Responses will be limited to the personal data of the applicant. Applications concerning the personal data of a spouse, relative, friend or any other third party will not be accepted unless the applicant is legally authorised to act on that person's behalf.
Demirci Turistik Tesisleri İşl. A.Ş. reserves the right to request additional relevant information and documentation from applicants where necessary to process their applications.
## IX. Confidentiality Principle
The data of both employees and other individuals held by Demirci Turistik Tesisleri İşl. A.Ş. is confidential.
No person may use, copy, reproduce, transfer or otherwise disclose such data for any purpose other than its intended business purpose, unless authorised by a contract or applicable law.
## X. Information Security
Demirci Turistik Tesisleri İşl. A.Ş. takes all necessary technical and administrative measures to protect the personal data it collects, prevent unauthorised access, and avoid harm to customers and prospective customers.
These measures include ensuring that software complies with applicable standards, carefully selecting third-party service providers, and ensuring compliance with the company's data protection policy.
Security measures are regularly reviewed, updated and improved.
XI. Audits
Demirci Turistik Tesisleri İşl. A.Ş. carries out or arranges the necessary internal and external audits concerning the protection of personal data.
XII. Notification of Data Breaches
When Demirci Turistik Tesisleri İşl. A.Ş. becomes aware of a personal data breach, it shall promptly take action to address the breach, minimise any harm suffered by the relevant individuals, and take appropriate remedial measures.
Where personal data is obtained by unauthorised persons, the company shall notify the Personal Data Protection Board without undue delay, in accordance with applicable legislation.
Notifications regarding breaches may also be submitted in accordance with the procedures specified at:
https://www.emirhotels/kvkk
Applications Under the Personal Data Protection Law
As also announced on the following page, applications concerning personal data must be submitted by completing the form available on the website, attaching a copy of the applicant's identification document, and sending the documents by registered mail with return receipt requested to the address specified on the form:
https://www.emirhotels/kvkk
Rights relating to personal data may only be exercised in respect of the applicant's own personal data, unless the applicant is legally authorised to act on behalf of another person.
Applications submitted without a copy of the applicant's identification document will not be considered under the procedure described in this Policy.
Please note that, even after a request for deletion of personal data has been fulfilled, we may be legally obliged to disclose the relevant data to competent public authorities upon a lawful request.
**Click here to access the application form.**
Contact
For any questions regarding this Privacy Policy, please contact us using the information below.
Blacksmith Group
Manavgat / ANTALYA, TÜRKİYE
