Personal Data Protection Law

KVKK POLICY

(Processing and Protection of Personal Data)

(ABSTRACT TEXT)

SCOPE AND PURPOSE

This Policy, within the scope of the KVK Law No. 6698 and the KVK Policy Book (PINE BEACH), TURKA OTELCİLİK TURİZM VE TİCARET A.Ş. and its customers, personnel and real or legal persons with whom it has communication and interaction, to make regulations regarding the processing of personal data obtained directly by PINE BEACH, to determine the conditions to be complied with, to declare and announce.

Lighting Obligation

Within the scope of KVKK (Personal Data Protection Law) numbered 6698, which entered into force on 07.04.2016, legal regulation of personal data processed during the relations of PINE BEACH with its employees, as well as with real or legal persons with whom it communicates and interacts, due to the obligations and requirements of the legislation. required.

PINE BEACH pays the utmost attention and care to the personal data security and privacy principles of the personnel and the persons with whom it communicates and interacts. During the performance of the services, the personal data security of the persons concerned is given priority.

All kinds of personal data (including sensitive personal data) that can be related to a real person in accordance with the provisions of the law mentioned above are considered as personal data within the scope of the KVK Law. These personal data are processed by PINE BEACH in the capacity of Data Controller, with the methods detailed below and within the limits ordered by the legislation.

"Personal Data Processing" means that this data is obtained, recorded, stored, preserved, changed, rearranged, disclosed, transferred, taken over, made available by fully or partially automatic or non-automatic means provided that it is a part of any data recording system. refers to all kinds of operations performed on data such as classification or prevention of use.

Purpose of Processing Personal Data and Legal Basis

Personal data is provided by PINE BEACH electronically or verbally, by means of automatic or non-automatic methods, such as registration to the platform, telephone, fax, e-mail, sms and other social media channels, mobile applications, in writing or verbally, including audio and video recording. can be collected in the physical environment.

Within the framework of Article 5 of KVKK No. 6698

a) Explicit consent of the data owner,

b) It is clearly stipulated in the laws,

c) It is compulsory for the protection of the life or physical integrity of the person or another person, who is unable to express his consent due to actual impossibility or whose consent is not legally recognized,

d) It is necessary to process the personal data of the parties to the contract, provided that it is directly related to the establishment or performance of the contract drawn up as a result of approval and/or signature with PINE BEACH,

e) It is mandatory for PINE BEACH to fulfill its legal obligation,

f) It has been made public by the person concerned,

g) Data processing is mandatory for the establishment, exercise or protection of a right,

h) Data processing is mandatory for the legitimate interests of PINE BEACH, provided that it does not harm the fundamental rights and freedoms of the person concerned.)

and again under Article 6

a) Explicit consent of the data owner,

b) It is processed in accordance with the personal data processing conditions and purposes specified in other cases stipulated in the laws.

Sharing and Transfer of Personal Data

Personal data of the person concerned; requested by official institutions and organizations when the legislation deems it necessary, domestic / foreign solution partners, project partners, program and cooperation partners, supplier company with which PINE BEACH has commercial, legal and economic relations as a requirement of its activities and responsibility, Electronic and physical security measures required by institutions and organizations, independent auditor organizations, banks and financial institutions, other companies, individuals and organizations that receive assistance and support, consultancy firms such as lawyers, financial advisors, legal, informatics, quality and finance consultants, and PINE BEACH can be shared. It can be transferred. These sharing and transfer processes are also valid for abroad.

PINE BEACH, the personal data of the person concerned, in Turkey or in other countries, mainly EU countries, USA, England, provided that necessary security measures are taken, storage, archiving, servers with information technology support, hosting companies, programs, cloud computing, etc. can transfer to electronic media, process and store.

Collection Method of Personal Data

Personal data of the person concerned; All agreements/information forms and other documents signed with approval and/or acceptance, approval, acceptance and notifications made with electronic approval and/or signature, PINE BEACH's administrative center, physical environments, call centers, websites, mobile applications, internet transactions, social media and other public areas, user interviews, scanning of forensic records, market research, Identity Sharing System, SMS, digital applications to websites, mobile applications, written/digital applications to sales teams, call center The data obtained in verbal, written, video, audio recording or electronic media that are contacted or that may be communicated in the future are collected fully or partially automatically or as a part of any data recording system and are stored taking into account the statute of limitations as per the relevant legislation.

Personal data collected by PINE BEACH for the above-mentioned legal reasons may be processed or transferred in line with the previously described purposes of this policy, taking into account the personal data processing conditions specified in Articles 5 and 6 of the Law on the Protection of Personal Data No. 6698.

User Rights

(According to Article 11 of the KVK Law No. 6698)

Related persons, regarding their personal data, PINE BEACH's personal data via the following e-mail address;

1) Learning whether it has been processed or not,

2) Requesting information if processed,

3) Learning the purpose of processing and whether it is used in accordance with its purpose,

4) To know the third persons transferred in the country or abroad,

5) Requesting correction if it is incomplete / incorrectly processed,

6) Requesting the deletion, destruction or anonymization of personal data in case the reasons requiring the processing of personal data disappear,

7) Requesting notification of the transactions made in accordance with paragraphs (5) and (6) above, against the third parties to whom it has been transferred,

8) Objecting to the emergence of a result against you due to the analysis exclusively by automated systems,

9) Demanding the compensation of the damage in case of loss due to unlawful processing

And has other rights written in the legislation.

Data Responsible for Application within the Scope of the Law

PINE BEACH Data Controller is the person registered in the VERBIS system at www.kvkk.gov.tr.

The person concerned, within the scope of the above-mentioned rights, can submit their requests, complaints and suggestions to the address below of PINE BEACH by applying in person or through a notary public or by specifying the e-mail address registered on the website and notified by the user at the time of account opening. can send to your address.

Applications must include name, surname, TR identity number, residential or workplace address for notification, mobile phone number, e-mail address and the subject of the request, and information and documents related to the request must be attached to the application.

The official language of correspondence with PINE BEACH is Turkish. For this reason, it is essential that all applications, correspondence, problems, complaints and suggestions are written and sent in Turkish.

If the application is sent in writing and physically, the signature must be wet signed.

As a rule, answers to requests, problems, suggestions and complaints are free of charge. However, if there is a cost, fee or other cost related to the answer to be given, PINE BEACH reserves the right to charge the fees in the tariff determined by the KVVK Regulations or other authorities.

For more detailed information or for your problems, requests, suggestions and complaints regarding the KVK Policy, please apply to kvkk@pinebeach.com.tr.

You can also obtain the KVK Policy book from PINE BEACH.

For your physical and written applications:

(PINE BEACH) TURKA OTELCİLİK TURİZM VE TİCARET A.Ş.