PERSONAL DATA PROTECTION AND PROCESSING POLICY
ingredients
CHAPTER 1 PURPOSE, SCOPE, DEFINITIONS AND BASIS
CHAPTER 2 GENERAL PRINCIPLES
SECTION: GENERAL INFORMATION AND BASIC PRINCIPLES
BULUM: MEASURES TAKEN FOR DATA SECURITY
III. SECTION: PROCESSING OF VIDEO RECORDINGS RECORDED USING A SECURITY CAMERA
SECTION: TRACKING OF GUEST ENTRANCES AND EXITS CARRIED OUT AT THE ENTRANCES AND ENTRANCES OF THE ASSOCIATION’S BUILDINGS AND BUSINESSES
SECTION: KEEPING RECORDS OF INTERNET ACCESS PROVIDED TO VISITORS IN COMPANY BUILDINGS and BUSINESSES
SECTION:ENFORCEMENT AND APPLICATION
CHAPTER 3 ROLES AND RESPONSIBILITIES
CHAPTER 4 EXECUTION
CHAPTER 5 Octobers
CHAPTER 1 PURPOSE, SCOPE, DEFINITIONS AND BASIS
Purpose
The Law on the Protection of Personal Data No. 6698 (“KVKK”) was published in the Official Gazette No. 29677 dated April 7, 2016. KVKK, personal data are processed real people protected by the Constitution, including fundamental rights and freedoms of natural persons, to protect privacy and personal data is real and legal persons who process held to determine the obligations.
“Astarte Hotel” (the“company”) to its customers, potential customers, employees, employee candidates, in cooperation with the institutions and their employees, stakeholders, business partners, shareholders and the authorities of third parties and the privacy and security of personal data is of utmost importance. Astarte Hotel aims to properly fulfill the requirements for compliance with the PDP and to establish a data protection and processing regulation at international standards through the ongoing studies. The main purpose of this regulation is to ensure transparency by informing the people whose personal data are processed by Ikamid, especially the people listed above.
Scope
The Personal Data Protection and Processing Policy (the ”Policy”) sets out the principles adopted by the Company for the protection and processing of personal data and which are taken into account in practice. The Policy also provides information about the purposes for which the COMPANY processes personal data, the method of collecting personal data, its legal purpose, the purposes for which data can be transferred to whom, and the rights of interested parties.
Within the scope of KVKK, the COMPANY is the “data controller” and the information and principles in this Policy apply to the COMPANY. The COMPANY has approved and adopted this Regulation, effective from October 7, 2016. Politics, www.astartehotel.com it is published on the website and made available to the relevant persons at the request of the personal data owners.
Definitions
Explicit Consent: It is the consent given to a specific subject, based on information and disclosed in free will, limited for the purpose of data processing.
Anonymization: This means that personal data cannot be associated with an identified or identifiable natural person under any circumstances, even by matching it with other data.
Personal Data Owner : A natural person whose personal data is processed. For example, customers, suppliers, visitors, employees and prospective employees.
Personal Data: Any kind of information that determines the identity of a real person or makes his identity identifiable. Therefore, the processing of information about legal entities is not covered by the Law. For example; first name, last name, TCKN, e-mail, address, date and place of birth, social security number, images, credit card number, bank account number, etc.
Personal Data of a Special Nature: This is information that, if found out, may cause the Owner of Personal Data to become a victim or be subject to discrimination. (Race, ethnicity, political opinion, philosophical belief, religion, sect, or other beliefs, dress, Association or trade union membership, health, sexual life, criminal convictions and security measures, biometric and genetic data is data with data on special.)
The processing of personal data : personal data will be fully or partially automated, with the record to be part of any data recording system or non-automatic means obtaining, recording, storage, preservation, alteration, rearrangement, disclosure, transfer, acquisition, can be obtained, making any classification such as the Prevention of the use or operation is performed on the data.
Data breaches: These are incidents where there are justified doubts about the unlawful seizure, collection, modification, copying, distribution or use of personal data.
Basis
This Policy has been established on the basis of KVKK and related legislation in order to protect and process personal data by the COMPANY.
CHAPTER 2 GENERAL PRINCIPLES
SECTION: GENERAL INFORMATION AND BASIC PRINCIPLES
The COMPANY processes personal data in the following way, within the limits provided for by the legislation.
1.1. Method of Collection of Personal Data:
The personal data processed may vary depending on the type and nature of the COMPANY’s products and services. Personal data can be collected orally, in writing or electronically by automated or non-automated methods, in factories, offices, call centers, websites, social media channels, institutions with which it has a business relationship, stakeholders and similar means.
As long as the COMPANY’s products and services are used or the COMPANY continues its production activities, personal data may be processed and updated as necessary to ensure the accuracy and up-to-date of the data. In addition, personal data may also be processed when the company’s office buildings, factories are physically visited or call centers are used, internet pages and /or other social and digital media are visited or activities such as events, seminars, organizations, trainings organized by the COMPANY are attended in order to benefit from the products and services.
1.2. Purposes and Procedures for Processing Personal Data:
The collection and processing of personal data, the company’s commercial and business strategies of development, implementation and execution of human resources policies to be reported during the acquisition of personal data for the purposes of other miscellaneous purposes for the processing of personal data specified in kvkk Article 5 and Article 6 for the purposes and conditions and will be held within the following purposes :
(i) Customer and business partners data;
Data processing for contractual relationship; Personal Data belonging to the Client (client and potential customers) or business partner (partner official if the business partner is a legal entity) can also be processed for the establishment, implementation and termination of a contract without obtaining consent. Personal data may be processed before the contract and at the stage of starting the contract in order to prepare an offer, prepare a purchase form or to meet the requests of the Personal Data Owner regarding the implementation of the contract.
Data processing carried out due to the Company’s legal obligation or as expressly provided for in the law; Personal data may be processed without further approval in order to clearly state the processing in the relevant legislation or to fulfill a legal obligation determined by the legislation. The type and scope of data processing must be necessary for the legally permitted data processing activity and must comply with the relevant legal provisions.
Data processing in accordance with the legitimate interest of the Company; Personal data can also be processed without prior approval when it is necessary for the legitimate interest of the Company. Legitimate interests are usually legal (eg. collection of receivables) or economic (eg. avoidance of contract violations) are benefits.
User information and the Internet; In case of collection, processing and use of personal data on websites or applications, the relevant persons should be informed of the privacy statement.
(ii) Personnel information;
Processing of Personal Data for a business relationship; In business relations, Personal Data is processed without prior approval, if necessary, for the establishment, implementation and termination of an employment contract. Personal Data of candidates are processed when starting a business relationship. If the candidate is rejected, the information about the candidate is stored until the appropriate data retention period for the candidate at a later stage of the election, at the end of which time it is deleted, destroyed or anonymized.
Data processing carried out as expressly provided for in the Law or due to the legal obligation of the Company; Personal Data belonging to the Employee may be processed without further approval in order to clearly state the processing in the relevant legislation or to fulfill a legal obligation determined by the legislation.
Processing of data in accordance with the legitimate interest; Personal Data belonging to the Employee may also be processed without prior approval if a legitimate interest of the Company is required. (eg. personal data is not processed for legitimate interest purposes in personal situations where it is necessary to file, enforce or defend legal rights or evaluate the company) Protect the interests of employees. It is determined whether there are interests that require protection before the data are processed. When processing data belonging to employees on the basis of the legitimate interests of the Company, it is examined whether the processing is measured. It is checked that the legitimate interest of the company in taking this control measure does not violate the right of the relevant employee to be protected, and it is applied only in moderation.
Data processed exclusively through automated systems; If Personal Data is processed exclusively through automated systems as part of a business relationship (for example, as part of the selection of personnel or as an assessment of their ability profile), the employee has the right to object to the occurrence of an outcome against him.
If it is the basis of a personal data processing activity, it may be only one of the following conditions, as well as more than one of these conditions may be the basis of the same personal data processing activity.
Obtaining the Explicit Consent of the Personal Data Owner