Protection of Personal Data

Informing Text within the Scope of the Law on the Protection of Personal Data

Dear Customers,
Tutis Turizm Ticaret Seyahat Anonim Şirketi (“LETOONIA”) located at Karagözler Mahallesi Fevzi Çakmak Caddesi, No.82 Fethiye Muğla aims by this Informing Text to give you information on

• Which personal data are collected and processed,
• The purpose of collection and processing of your personal data
• The retention period of your personal data,
• With whom your personal data are shared,
• Whether your personal data are transferred outside of Turkey,
• How your personal data are kept and protected,
• Whether your personal data are processed by means of automated decision-making processes,and
• Your rights related to your personal data

Related to the collection, processing, and transfer of your personal data under the Law on the Protection of Personal Data (KVKK) numbered 6698.

Collection and Processing of Personal Data and the Purposes of Processing

1.1 Your Processed Personal Data and the Purposes of Processing. LETOONIA processes the following personal data of you and your children under the age of 18 accompanying you during your stay, in a limited and proportionate manner to provide accommodation services and provide the service that suits your preferences during the stay in our hotel.

• Your identity card information: Name, last name, T.R. identity number, date of birth, gender, nationality
• Your civil registration information: Mother’s name, father’s name
• Contact information: E-mail address, mobile phone number
• Your check-in and check-out dates
• Your preferences and field of interests (for example smoking/non-smoking room, choice of floor, type of bedding, type of newspaper/magazine, sport, cultural field of interests)
• Your questions and comments during or after your stay at our hotel
• Financial information: Credit card information, invoice details
• Camera recordings
• IP address
• Your health data in case of any health problem during your stay
• Collection. LETOONIA collects the personal data of you and your children under the age of 18 during hotel booking, check-in, and payment directly through call center, staff at the hotel reception, online booking platforms, online booking on LETOONIA website, LETOONIA accounts in social networks before and during your stay at our hotel. In addition, your personal data are collected and processed through your connections to LETOONIA websites, tour operators, and travel agencies during your participation in hotel activities or your use of hotel services during your stay.

Automated decision-making systems are not used.

Legal Basis for Processing

2.1 Processing Based on Reasons of Compliance with Law. Your personal data, except your health data are based on reasons of compliance with law in the paragraphs (a), (c), (ç), (d) and (f) of the article 5/2 of KVKK with the purposes to

• Fulfill our obligations to our customers,
• Manage booking and accommodation requests,
• Provide accommodation services and track your use of services (e.g., telephone, bar, pay-tv),
• Manage access to rooms,
• Perform payment transaction,
• Create and store legal documents in accordance with accounting standards, and
• Provide security.

Within this scope, your personal data is processed as the reasons for compliance with law in accordance with the relevant legislations based on the fact that data processing is compulsory for LETOONIA’s legitimate interests as the data controller, as it is directly related to the establishment and execution of the contract and is compulsory for the data controller to process personal data in order to fulfill legal obligations, it is publicized by you for the purpose of purchase of goods and services, and in the manner not to harm your fundamental rights and freedoms.

The processing of this data is not subject to your consent. In this respect, we state that you do not have the right to request the erasure or destruction of your personal data until the end of the retention period required by the work and law.

• Your Health Data. LETOONIA’s doctor collects and processes your health data with your request or in cases where immediate treatment is necessary, in case you encounter any health problem during your stay at LETOONIA. Your health data is processed by LETOONIA’s doctor in accordance with KVKK article 6/3 with the purpose of medical diagnosis and treatment without seeking your explicit consent.
• Processing Based on Explicit Consent. Based on your explicit consent, your photos and/or videos may be taken during your stay at LETOONIA while using the hotel areas and/or continuing your activities in the hotel to be used on LETOONIA website and/or in social media accounts for the purposes of promoting and advertising the Hotel. Your visual and audio recordings are only processed in case of the existence of your explicit consent in accordance with the article 5/1 of KVKK.

You can always withdraw your explicit consent on processing of your personal data to be used in LETOONIA’s advertisement materials. However, the process which took place until the date you withdrew your consent will be considered lawful.

• Processing by anonymizing. LETOONIA may also process your personal data by anonymizing to collect statistical information.

Transfer of Personal Data to Third Parties.

• 3.1 Transfer without Explicit Consent.LETOONIA may transfer your Personal Data except health data to hotel employees in order to fulfill the accommodation services you requested; transfer service providers you requested during your stay; payment institutions and banks for payment transactions; law enforcers and security forces due to LETOONIA’s legal responsibilities and obligations; judicial institutions and Turkish Statistical Institute and related state institutions and organizations; law firms and lawyers in case of legal disputes; public accountants, certified public accountants, and public accountant and auditing companies to fulfill financial auditing and legal obligations.

Your health data, on the other hand, may be transferred to doctors and health institutions you are referred to, in case required for your diagnosis and treatment being limited to this purpose and in a proportional manner. This transfer is made for medical diagnosis and treatment without seeking your explicit consent based on KVKK article 8/2(b) in accordance with the KVKK article 6/3.

Your personal data are transferred to third parties in the country without seeking explicit consent in the manner of being relevant with, limited to, and proportionate to the purposes for which they are processed, in case it is mandatory by law and/or mandatory in terms of the execution of the contract and/or to fulfill legal obligations based on KVKK article 8/2(a).

• 3.2 Transfer Based on Explicit Consent. Based on your explicit consent, your personal data related to your name, last name, contact information, preferences, and field of interests are transferred to the suppliers providing advertising and marketing services during LETOONIA activities, in accordance with KVKK article 8/1. You can always withdraw your explicit consent related to the transfer of your personal data to LETOONIA suppliers for marketing purposes.

Transfer of Personal Data Abroad

LETOONIA does not transfer your personal data to the data processors and/or third parties located abroad.

In case you do not have explicit consent, your personal data can only be transferred abroad in the presence of conditions specified in KVKK article 5/2 to the foreign countries announced to have sufficient protection (“Foreign Country Possessing Sufficient Protection”) by the Personal Data Protection Board (“KVK Board”), or in case of lack of sufficient protection, to the foreign countries for which the controller in Turkey and in the related foreign country guarantee a sufficient protection in writing and KVK Board has authorized such transfer (“Foreign Country with the Data Controller that Guarantees Sufficient Protection”).

Protection, Retention, and Destruction of Personal Data

• 5.1 Protection. LETOONIA is obliged to take all kinds of physical, technical, and administrative measures to provide sufficient level of security in order to prevent illegal processing of and illegal access to your personal data, and to ensure the protection of your personal data and it takes maximum measures.

Your personal data recorded in the accommodation documents will be kept physically locked and stored electronically.

• 5.2 Retention and Destruction. In accordance with the relevant legislation, accommodation documents will be kept for one year starting from the calendar year following the year they were issued, identification information and accommodation registrations books containing the dates of check-in and check-out will be kept for a period of five (5) years starting from the date of registration.

Your contact information, preferences and field of interests, personal data related to your complaints and comments during your stay, your visual and audio recordings and photographs for marketing and promotional purposes will be kept for two (2) years following your last stay at LETOONIA. At the end of two (2) years, LETOONIA will remove and destruct your images and photographs on its website and social media accounts.

Your IP address and financial information will be kept for a period of five (5) years. Your health data and intervention records that you shared with LETOONIA doctor in cases of necessities will be kept for two (2) years. In case of legal dispute, the relevant records, correspondence, and all kinds of relevant information and documents will be kept for ten (10) years from the date of violation and when the perpetrator was found out. In cases of final judgment is not made during this retention period, they will be kept until the end of five (5) years following the receiving of the final judgment and at the end of this period, they will be destructed at the first destruction period.

Your personal data will be deleted, destroyed, or anonymized during the first destruction period following this retention periods.

Camera recordings are kept for thirty (30) days from the date of recording and are destroyed at the end of this period.

Your Rights

In accordance with the legislation in force, as the data subject you have the right to (a) learn whether your personal data are processed and request information on how your personal data are processed (article 11/(a), (b)), (b) learn the purpose of your data processing and whether this data is used for intended purposes (article 11/c), (c) know the third parties to whom your personal data is transferred (article 11/ç), (d) request rectification of your personal data (article 11/d), (e) request erasure of your personal data in case the reasons for the personal data that needed to be processed disappear (article 7, article 11/e), (f) request notification of the operations carried out to third parties to whom your personal data has been transferred in case of rectification and erasure (article 11/f), (g) object to the obtained results in case your personal data is analyzed (article 11/g), (h) request restriction of the processing of your personal data (article 7), (i) request compensation for the damage arising from the unlawful processing of your personal data (article 11/ğ).

Aforementioned rights are limited by law and will probably only be provided by us under certain conditions. (Please especially pay attention to the 10th and 13th articles of KVKK).

In accordance with the first paragraph of the 13th article of KVKK, applications to be made to our Company, as the data controller, regarding these rights can be forwarded written and signed via sending mail and/or electronic mail to the addresses given below. A written or an electronic answer will be sent to you within 30 days at latest after your request is delivered to LETOONIA.

Data Controller: TUTİS TURİZM TİCARET SEYAHAT ANONİM ŞİRKETİ

Mersis (Central Registration System) Number: 0872003504000021.
Address: Karagözler Mah. Fevzi Çakmak Cad. No: 82 Fethiye/MUGLA
Telephone: +90 252 614 49 66
E-Mail: bilgilendirme@letoonia.com

Upon your request, LETOONIA can always update your personal data and as well as the informing text. Up-to-date informing text can always be found at the address [https://www.tutis.com.tr].

In order to exercise your right to complain to the Board: (KVKK article 13, 14, 15)

Board: Personal Data Protection Board

Address: Nasuh Akar Mah. Ziyabey Cad. 1407. Sok. No: 4 06520 Balgat-Çankaya/ Ankara,

Telephone: +90 312 216 5000

Website: Please contact at the address: http://www.kvkk.gov.tr/