Personal Data Protection Law

LA LUCCI FETHIYE PERSONAL DATA PROTECTION AND PRIVACY POLICY

Website Confidentiality Agreement

How to use and protect the information we obtain about you and the services you request while you visit this website and benefit from the services we provide through this site are subject to the conditions set forth in this “Privacy Policy”. By visiting this website and requesting to benefit from the services we offer through this website, you accept the terms set forth in this “Privacy Policy”.

PURPOSE OF PERSONAL DATA PROTECTION AND PROCESSING POLICY

Due to the sensitivity of the work we have been dealing with as La Lucci Fethiye, the data received from our customers or prospective customers have been kept confidential and have never been shared with third parties. Protection of personal data is the basic policy of our company. Even before there was any legal regulation, our companies and affiliates attached great importance to the privacy of personal data and adopted this as a working principle and gave their employees working instructions in line with this principle. As “La Lucci Fethiye”, we undertake to comply with all the responsibilities brought by the Law on the Protection of Personal Data. The principles of our companies regarding the protection of personal data also cover our subsidiaries.

SCOPE AND CHANGE OF PERSONAL DATA PROTECTION AND PROCESSING POLICY

This Policy, prepared by our company, has been prepared in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”). The law has entered into force with all its provisions as of today. The data obtained from you with your consent or in accordance with other laws listed in the Law will be used to improve the quality of the services we provide, to improve the services offered to you and our quality policy. Again, some of the data we have is depersonalized and anonymized. These data are data used for statistical purposes and are not subject to Law enforcement and our Policy. “La Lucci Fethiye” Personal Data Protection and Processing Policy” aims to protect the automatically obtained data of our customers, prospective customers, employees, customers and employees of companies working in solution partnership with us, or other persons, and includes regulations regarding these. Our company has the right to change our policy and our Regulation, provided that it is in compliance with the law and that personal data is better protected.

BASIC RULES ON THE PROCESSING OF PERSONAL DATA

1. Compliance with the law and the rules of honesty: “La Lucci Fethiye” questions the source of the data it collects or receives from other companies and attaches importance to obtaining them in accordance with the law and within the framework of honesty rules. In this context, it makes necessary warnings and notifications to third parties (agencies and other intermediary institutions) that sell the services offered by “La Lucci Fethiye” in order to protect personal data.
2. Being accurate and up-to-date when necessary: “La Lucci Fethiye” attaches importance to the fact that all data within the institution are correct, not contain false information, and finally, if there is a change in personal data, they are updated if they are communicated to it.
3. Processing for specific, clear and legitimate purposes: “La Lucci Fethiye” processes data only for the purposes it offers and for which it receives consent from individuals during the service. It does not process, use and make use of data other than for business purposes.
4. Being connected, limited and measured for the purpose for which they are processed: “La Lucci Fethiye” uses the data only for the purpose for which it is processed and to the extent required by the service.
5. Retention for the period stipulated in the relevant legislation or required for the purpose for which they are processed: “La Lucci Fethiye” preserves the data originating from the contracts as long as the conflict periods of the Law and the requirements of commercial and tax law. However, when these purposes disappear, it deletes or anonymizes the data.

It should be emphasized that, whether “La Lucci Fethiye” has collected or processed the data with consent or in accordance with the law, these principles listed above still apply.

Maximum Savings Policy/Stinginess Policy

According to this principle, which is called the principle of maximum savings or the principle of stinginess, the data reaching “La Lucci Fethiye” is only processed into the system as much as necessary. Therefore, which data we collect is determined by the purpose. Unnecessary data is not collected. Other data transmitted to our company are transferred to company information systems in the same way. Redundant information is not recorded in the system, deleted or anonymized. These data can be used for statistical purposes. Health data, which is one of the special quality data, is taken only in order to provide better service to customers and protect their health and is kept in the system with care.

Deletion of personal data

Personal data is deleted, destroyed or anonymized by our company, automatically or upon the request of the person concerned, when the periods required to be kept by law, the completion of the judicial processes or other requirements are eliminated.

Accuracy and data timeliness

As a rule, the data within the body of “La Lucci Fethiye” are processed as declared by the relevant persons. “La Lucci Fethiye” is not obliged to investigate the accuracy of the data declared by customers or people who contacted “La Lucci Fethiye”, and this is not done legally and due to our working principles. The declared data is considered correct. The principle of accuracy and timeliness of personal data has also been adopted by “La Lucci Fethiye”. It updates the personal data that our company has processed from the official documents it receives or upon the request of the person concerned. It takes the necessary measures for this.

Privacy and data security

Personal data is confidential and “La Lucci Fethiye” also respects this confidentiality. Only authorized persons can access personal data within the company. All necessary technical and administrative measures are taken to protect the personal data collected by “La Lucci Fethiye” and to prevent it from falling into the hands of unauthorized persons and to prevent our customers and prospective customers from becoming victims. In this framework, it is ensured that the software complies with the standards, that the third parties are carefully selected and that the data protection policy is complied with within the company.

DATA PROCESSING PURPOSE

The collection and processing of personal data by “La Lucci Fethiye” will be carried out in line with the purposes specified in the clarification text. Data is collected and processed for the purpose of establishing the contract and providing better service to customers.

CUSTOMER, POSSIBLE CUSTOMER AND BUSINESS AND SOLUTION PARTNERS DATA

As “La Lucci Fethiye”, we process your personal data as a data controller within the scope of the Personal Data Protection Law No. 6698 and other relevant legislation.

The categories and explanations of personal data to be processed in this context are as follows:

– Identity Information: Name-surname, name-surname of accompanying guest/guests, nationality, place and date of birth; TR ID, driver’s license and passport numbers (including the date and place of issue).

– Contact Information: Address, phone number, e-mail address.

– Financial Information: Mobile billing information, bank account information, payment card number and other payment information,

– Loyalty Program memberships, information on purchased products or services.

– Customer comments, feedback and complaints data: specific preferences in accommodation, marketing and communication; reviews, opinions or complaints about brands and facilities.

– Other: Information on reservations, travel history; Participation in contests, lotteries or marketing programs, information about the vehicles used to reach the facility; booked hotel, airline and rental car packages; Groups with which it is affiliated to stay at the facilities, frequent flyer or Travel Partnership Program memberships and member numbers, information given in membership and account applications.

Collection and processing of data for contractual relationship

If a contractual relationship is established with our customers and prospective customers, the collected personal data can be used without the customer’s consent. However, this use takes place in line with the purpose of the contract. The data is used to the extent of better execution of the contract and the requirements of the service and updated when necessary by contacting the customers. On the other hand, the data left to us by our prospective customers (prospective customers) are processed in order to provide them with an easier and higher quality service afterwards. If this data has not turned into a contractual relationship upon request, it will be deleted.

Business and Business Partners Data

“La Lucci Fethiye” adopts the principle of acting in accordance with the law when sharing data with both business and solution partners. Data is shared with business and solution partners with the commitment of data confidentiality and only as much as the service requires, and these parties are compelled to take measures to ensure data security.

Data processing to manage, analyze and improve the services offered at the facilities

• Conducting surveys with the aim of measuring the services provided,
•  To communicate with guests for marketing purposes in line with the communication permissions granted within the framework of other laws,
• Making internal correspondence about guests who behave outside the facility and general etiquette during their stay at the hotel and preparing a list in line with this information,
• Guests’ social media, blog, comment portals, etc. recording the comments in the fields in the system in order to analyze the return of the service provided,
• To carry out Sales and Marketing activities in order to provide a personalized holiday experience by processing the data of the services offered to the guests.

Managing our relations with guests before, during and after their stay

• Making phone calls before entering the facility,
• Customer Loyalty Program management,
• Answering guests’ questions about the Loyalty Program, card scales, transition to the next card and similar issues,
• Segmentation by processing data related to reservation history, travel preferences and services received in order to manage marketing activities correctly,
• Managing claims/complaints about our facilities and services received on comment portals, complaint pages, social media channels,
• Keeping guests’ personal information data up-to-date and combining it with data from third-party sources for analytical purposes

e-invoice

Within the scope of the e-invoice program; The customer is automatically registered in the e-invoice program and an invoice is sent via e-mail sent to the facility. It is the customer’s responsibility to ensure that the e-mail address given at the entrance to the facility or updated by applying afterwards is correct and is the preferred e-mail address for this communication. If a reservation is made for another family member or persons using this e-mail address, the e-invoice of the relevant invoice will be sent to the e-mail owner’s address.

Advertising data processing

About Regulation of E-Commerce. About Commercial Communication and Commercial Electronic Messages by Law. In accordance with the regulation, e-mails for advertising purposes can only be sent to people with prior approval. The explicit consent of the person to whom the advertisement is sent is required. Again, “La Lucci Fethiye” complies with the details of the “approval” determined in accordance with the same legislation. The approval to be obtained should cover all commercial electronic messages sent to the electronic communication addresses of the recipients in order to promote your company’s goods and services, market it, promote its business or increase its recognition with content such as congratulations and wishes. This approval can be obtained in writing, in the physical environment or by any electronic means of communication. The important thing is that the buyer has a positive declaration of will that he accepts the sending of commercial electronic messages, his name and surname and his electronic communication address.

Data transactions made due to the legal obligation of the company or expressly stipulated 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 legally permitted data processing and must comply with relevant legal provisions.

Company data processing

Personal data may be processed in line with the service offered by the company and its legitimate purposes. However, the data cannot be used for illegal services in any way.

Processing of special data

According to the Law, data regarding the race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and dress, membership to associations, foundations or unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data is personal data of special nature. “La Lucci Fethiye” also takes adequate measures determined by the Board in the processing of special categories of personal data. “La Lucci Fethiye” can only process special data for the purpose for which they were collected, with the consent of the individuals, in order to provide better services.

Data processed by automated systems

“La Lucci Fethiye” acts in accordance with the Law regarding the data processed through automatic systems. The information obtained from these data cannot be used against the person without the explicit consent of the people. However, “La Lucci Fethiye” can take decisions regarding the people it will deal with using the data in its own system.

User information and internet

In case of collection, processing and use of personal data on websites and other systems or applications of La Lucci Fethiye, the relevant persons are informed about the privacy statement and, if necessary, about cookies. People are informed about our practices on web pages. Personal data will be processed in accordance with the law.

When you visit our website, we present the following information to your attention regarding the cookies we use/will use on our page.

Purpose of Use of Cookies
Cookie Type
Google (analytics, doubleclick)
Measurement Advertising On-site optimization
Functional and analytical cookies Commercial cookies
Facebook
Advertisement
Commercial cookies
insider
Measurement Advertising On-site optimization
Functional and analytical cookies Commercial cookies
hotjar
Measurement On-site improvement
Functional and analytical cookies Commercial cookies
3rd party companies (criteo, rtbhouse)
Advertisement
Functional and analytical cookies Commercial cookies

Functional and Analytical Cookies contain data about remembering your preferences, using the website effectively, optimizing the site to respond to user requests, and how visitors use the site. Due to their nature, these types of cookies do not contain usernames, etc. may contain your personal information.

Third Party Cookies

La Lucci Fethiye websites/mobile applications/mobile websites work with third-party reliable, well-known advertising providers. Third party service providers place their own cookies in order to serve you specific advertisements. Cookies placed by third parties collect and process the browsing information of visitors on websites and analyze how they are used.

Commercial cookies

In line with your interests and choices, it serves to increase your usage experience by presenting the products/content that you have targeted and offering a more advanced, personalized advertising portfolio. The above-mentioned session, permanent, functional and analytical and commercial cookies are kept in the background for approximately 2 (two) months, and the necessary adjustments can be made in the personal internet browser settings. The removal process from these settings may vary based on the internet browser.

If your transaction is incomplete due to errors or interruptions in the system while you are at the reservation stage, our call center representative will reach you.

How can I delete cookies?

Many internet browsers are set to automatically accept and use cookies from the time they are first installed on your computer. By using the help or settings menus of your internet browser, you can prevent cookies or give a warning when cookies are sent to your device. You can use your browser’s instruction or help options screen to learn about the different ways to manage cookies and to get detailed information on how to adjust the settings of the browser you are using.

Purposes of Collection and Processing of Security Data in Facilities

Your security camera footage obtained due to your visit to La Lucci Fethiye, which is the data controller within the scope of the law numbered 6698, is collected in order to ensure the safety of both our company and you, and our company to provide you with safe service.

Your personal data is not used for purposes other than those listed; The legitimate interest of the data controller regulated in Article 5/2 (f) of the KVKK is processed based on the legal reason.

As a rule, your collected personal data is not shared with any third party or institution. However, it may be shared in order to meet the demands of legally authorized public institutions and organizations in order to fulfill the legal obligations set forth in article 5/2(ç) of the law. After the purpose of collection is over, your data is destroyed.

DATA OF OUR EMPLOYEES

Processing of data for business relationship

Personal data of our employees can be processed without consent as far as necessary in terms of business relations and health insurance. However, “La Lucci Fethiye” ensures the confidentiality and protection of the data of its employees.

Data is obtained from the Kariyer.net system for job applications and candidate recruitment, as well as for the management of human resources, and the data is recorded in the system within the scope of the candidate evaluation process.

Processing by Legal Obligations

“La Lucci Fethiye” may process the personal data of its employees without obtaining separate approval in order to clearly state the processing in the relevant legislation or to fulfill a legal obligation determined by the legislation. This issue is limited to the obligations arising from the law.

Processing for the Benefit of Employees

“La Lucci Fethiye” may process personal data without obtaining approval for transactions that benefit company employees, such as private health insurances. “La Lucci Fethiye” may also process employee data for disputes arising from business relations.

Processing of special data

According to the Law, data regarding the race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and dress, membership to associations, foundations or unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data is personal data of special nature. “La Lucci Fethiye” also takes adequate measures determined by the Board, in addition to the approval of the data subject, in the processing of personal data of special nature. Special categories of personal data can be processed without the consent of the person, but only in relation to the cases permitted by the Law and in a limited manner. In order for our employees to benefit from insurance and health services, the qualified data obtained from them is used only for the purpose.

Data processed by automated systems

Data processed by automated systems regarding employees can be used in internal promotions and performance evaluations. Our employees have the right to object to the result against them, and they do so by following internal procedures. The objections of the employees are also evaluated within the company.

Telecommunications and internet

Computers, telephones, e-mails and other applications allocated to the employees within the company are allocated to the employee only for business purposes. The employee cannot use any of these means allocated to him by the company for his private purposes and communication. The company can control and audit all data on these vehicles. The employee undertakes that he/she will not keep any other data or information other than work on the computers, phones or other tools allocated to him from the moment he/she starts the job.

TRANSFER OF PERSONAL DATA IN DOMESTIC AND INTERNATIONAL

Personal data may be shared with business and solution partners and affiliates in order for “La Lucci Fethiye” to see the service.

“La Lucci Fethiye” will be able to transfer personal data to the following individuals and institutions for certain purposes;

• Limited to the business partners of “La Lucci Fethiye” in order to ensure the fulfillment of the purposes of the establishment of the business partnership,
• To the suppliers of “La Lucci Fethiye”, limited to the purpose of providing the necessary services to our Company to carry out the commercial activities of our Company, which our company outsourced from the supplier,
• Solution partners of “La Lucci Fethiye” limited to ensuring the execution of commercial activities of our company that require the participation of affiliates,
• To the affiliates of “La Lucci Fethiye”.

“La Lucci Fethiye” has the authority to transfer personal data within the scope of the conditions determined by the Board in the law, in accordance with the other conditions in the Law and subject to the consent of the person, within the country and abroad.

RIGHTS OF THE RELATED PERSON

“La Lucci Fethiye” accepts that within the scope of the Law, the data subject has the right to obtain consent before the data is processed, and that it has the right to determine the fate of the data after the data is processed.

Regarding personal data, by applying to our related person announced on our website by “La Lucci Fethiye”;

• Learning whether personal data is processed or not,
• If personal data has been processed, requesting information about it,
• Learning the purpose of processing personal data and whether they are used in accordance with the purpose,
• Knowing the third parties to whom personal data is transferred at home or abroad,
• Requesting correction of personal data in case of incomplete or incorrect processing,
• Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7,
• Requesting notification of the transactions made pursuant to subparagraphs (d) and (e) to third parties to whom personal data has been transferred,
• Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,
• He has the right to demand the compensation of the damage in case of loss due to the unlawful processing of personal data. However, individuals do not have a right to anonymized data within the Company. “La Lucci Fethiye” may share personal data with relevant institutions and organizations in order to exercise the legal powers of a judicial duty or state authority in accordance with the business and contractual relationship.

Personal data owners can submit their requests regarding the above-mentioned rights by filling in the application form on the official website of the Company, www.laluccifethiye.com/, and signing it with a wet signature, to the contact address specified below, by registered letter with return receipt and photocopies of identity card (only the front side copy for the identity card). ) will be able to transmit by sending. Your applications will be answered as soon as possible depending on the content of your application or within 30 days at the latest after it reaches our company. You must submit your applications by registered letter with return receipt requested. In addition, only the part of your application about you will be answered, and an application about your spouse, relative or friend will not be accepted. “La Lucci Fethiye” may request other relevant information and documents from the applicants.

PRIVACY POLICY

The data of employees or other persons in “La Lucci Fethiye” is confidential. No one can use, copy, reproduce, transfer to others, use this data for any other purpose without compliance with the contract or the law.

PROCESS SECURITY

All necessary technical and administrative measures are taken to protect the personal data collected by “La Lucci Fethiye” and to prevent it from falling into the hands of unauthorized persons and to prevent our customers and prospective customers from becoming victims. In this framework, it is ensured that the software complies with the standards, that the third parties are carefully selected and that the data protection policy is complied with within the company. Safety measures are constantly being renewed and improved.

AUDIT

“La Lucci Fethiye” carries out the necessary internal and external audits for the protection of personal data.

NOTIFICATION OF VIOLATIONS

When “La Lucci Fethiye” is notified of any violation of personal data, it immediately takes action to remedy the violation. It minimizes the harm of the person concerned and compensates the damage. When personal data is obtained by unauthorized persons, it immediately notifies the Personal Data Protection Board.

Applications can also be made according to the procedures specified at www.laluccifethiye.com/en/kvkk regarding the notification of violations.

Regarding requests made in accordance with the Law on Protection of Personal Data

As announced on www.laluccifethiye.com/en/kvkk pages, all applications will be processed if the form on the page is filled in and a copy of the ID is attached to it, and sent to the address on the form by registered letter with return receipt requested.

Rights regarding personal data can only be exercised about personal data. Requests regarding the data of people other than the person who filled out the form and whose ID photocopy is attached will not be considered. Forms without an ID photocopy will not be considered. Even when data deletion requests are fulfilled, we inform you that we are obliged to share the data with the official authorities if requested by the official authorities.

CHANGES THAT CAN BE MADE IN THE PROTECTION OF PERSONAL DATA AND PRIVACY POLICY:

“La Lucci Fethiye” reserves the right to make changes on the statements here. If a significant change is made to the statement, a link to the current statement is added to the home page of the website. Guests who register for any of our products or services can be informed about this issue through the communication channel given to the facilities. The last time the declaration was updated and the update number are indicated at the end of this text. Every change made in the statement becomes effective with the publication of the amended statement on the site. Using the site, any of our products and services following such changes indicates your acceptance of the then-current amended statement.

Policy Update: 20.09.2019.KVKK Statement-1

CONTACT

For questions about the confidentiality agreement, you can contact us using the contact information below.

LA LUCCI FETHİYE

Karaağaç, Alınca mevki, 48300 Fethiye/Muğla
+90 (252) 530 00 62
info@laluccifethiye.com