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2. PROCESSING OF PERSONAL DATA
A. GENERAL PRINCIPLES
swandorhotels.com acts in accordance with the following general principles regulated in Article 4 of the Law in the processing of personal data obtained through the website and mobile application:
Compliance with the law and honesty rules
Being accurate and up to date when necessary
Processing for specific, explicit and legitimate purposes
Being relevant, limited and proportionate to the purpose for which they are processed
Retention for the period stipulated in the relevant legislation or required for the purpose for which they are processed
You can find detailed information on general principles in swandorhotels.com Personal Data Protection and Processing Policy.
B. PURPOSES OF PROCESSING PERSONAL DATA
swandorhotels.com processes User personal data in accordance with the Law and secondary regulations for the following purposes:
Hotel Reservation Transactions: Your personal data is processed for the purpose of completing and managing your hotel reservation. This purpose also includes sending messages to you for reservation confirmation, cancellation or changes and to remind you about the service and to ensure the efficient operation of our website and mobile application.
Customer Services: In order to facilitate the booking process and to meet your requests regarding the services we offer, we provide customer service through the live support panel on our website and our call centre. Your personal data that you share during communication with our customer service employees are processed in order to respond to your request.
Member Account Transactions: As a member of swandorhotels.com, you can easily manage your reservations, newsletter preferences, search preferences. If you create a member account, the personal data you share is processed in order to make the best use of your member account.
Contact: By using the personal data you provide to swandorhotels.com, we may contact you for various purposes. The main ones are completing your reservation, sending reminder and warning messages and responding to your request you have submitted to us.
Legal Obligations: Your personal data may be processed, transferred and stored for the period stipulated in the relevant legislation or for the period required for the purpose, if required by any legislative provision to which swandorhotels.com is subject, especially for the processing of online user data in accordance with the relevant legislation and responding to information requests from administrative / judicial authorities.
Dispute Resolution: swandorhotels.com may process your personal data and share it with the relevant legal authorities in order to prove that it has carried out lawful transactions and fulfilled its legal obligations in disputes that may arise in the future and to ensure the resolution of disputes.
Improvement of Services and Customer Satisfaction: Your personal data is processed for the purposes of conducting analytical studies to improve your website experience, evaluating your requests, complaints and suggestions and taking actions to increase customer satisfaction and service quality. In addition, the publication of your accommodation evaluations and comments on the website may also be carried out within the scope of swandorhotels.com's legitimate interests. The purpose of the reviews, which you can publish anonymously depending on your preference, is to inform other users about the property you stayed at.
Marketing/Advertising: swandorhotels.com may use your information for various advertising and marketing activities if you give your explicit consent. In this context, your personal data may be processed for the purposes of creating potential customer records, informing you about campaigns and opportunities, conducting profiling, targeting and advertising activities, presenting you with the most suitable offers for your past preferences and tastes, and sending e-bulletins in accordance with your preferences registered in our website member profile. Your personal data will not be processed for such purposes in cases where you do not consent to marketing activities or withdraw your consent.
LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL DATA
swandorhotels.com processes personal data in the presence of at least one of the legal grounds set out in the Law. The legal grounds on which the above-mentioned personal data processing purposes are based are as follows:
Hotel reservation transactions, customer services and member account transactions are carried out on the basis of the legal ground of the establishment or performance of a contract specified in Article 5/2(c) of the Law.
The data processing activities we carry out in order to fulfil our legal obligations are based on the legal reason specified in Article 5/2 (ç) of the Law.
The cases where personal data are processed for the resolution of disputes are based on the legal ground for the establishment, exercise or protection of a right specified in Article 5/2(e) of the Law.
Marketing and advertising activities may be carried out based on the legal ground of explicit consent set out in Article 5/1 of the Law.
Activities based on the improvement of services and customer satisfaction and communication purposes are carried out based on the legal ground of legitimate interest regulated in Article 5/2(f) of the Law.
C. METHODS OF COLLECTING PERSONAL DATA
swandorhotels.com may collect personal data electronically through call centre and e-mail channels, reservation forms on the website and mobile application, membership registration forms or website live support panel, web analysis tools and cookies within the scope of the services offered to the User and the data processing purposes stated above. In addition, it also collects personal data in cases where the User discloses it by contacting swandorhotels.com through other methods.
D. TRANSFER OF PERSONAL DATA
Showing high sensitivity to the security of personal data and compliance with the provisions of the relevant legislation, swandorhotels.com shares personal data in accordance with the law only to the extent necessary; otherwise, it does not transfer it for any commercial purpose or sell it to third parties.
swandorhotels.com shares the personal data of the User who makes the reservation with the relevant accommodation facility in Turkey or abroad in order to complete and manage the reservations made through the swandorhotels.com website and mobile application.
In addition, the personal data of the User may be shared with swandorhotels.com's business partners and external service suppliers within the framework of the conditions specified in Articles 8 and 9 of the Law. If the User has consented to the processing of personal data for the purpose of carrying out marketing, profiling and advertising activities, it is also possible to transfer data to solution partners who carry out such activities on behalf of swandorhotels.com.
Sharing Personal Data with Public Authorities
swandorhotels.com may share personal data and traffic information, such as browsing information, relating to visits to or membership of the website and mobile application with public institutions and organisations legally authorised to request such information in order to fulfil swandorhotels.com's obligations arising from the legislation to which swandorhotels.com is subject (in cases where swandorhotels.com is legally or administratively obliged to notify or provide information, including but not limited to the fight against crime, threats to state and public security, etc.).
E. DELETION, DESTRUCTION AND ANONYMISATION OF PERSONAL DATA
swandorhotels.com stores personal data processed through its website and mobile application for the periods stipulated in the relevant legislation and/or for the period required by the purpose of processing. In case this period expires, personal data are destroyed in accordance with the Law and the Regulation on Deletion, Destruction or Anonymisation of Personal Data.
3. MEASURES TAKEN TO ENSURE DATA SECURITY
swandorhotels.com takes all appropriate technical and administrative measures to ensure that personal data is processed in accordance with the law and to mitigate risks such as malicious use, unauthorised access, sharing, destruction or alteration of personal data.
You can find detailed information about the technical and administrative measures taken to ensure data security in swandorhotels.com Personal Data Protection and Processing Policy.
5. WEB MONITORING
The swandorhotels.com website and mobile application collects and stores data for analysis, marketing and optimisation purposes using Google Analytics, a web analytics service provided by Google, Inc. ("Google"), Hotjar Ltd. ("Hotjar"), Nextroll, Inc. web tracking technology. You can refuse tracking by Google Analytics with effect for the future by clicking here for your current web browser. You can click here to prevent tracking by Hotjar.
6. PERSONAL DATA OF CHILDREN
The website and mobile application of swandorhotels.com are intended for use by adults and the services offered are not intended for children. Minors under 18 years of age must have the consent of their parents or guardian to use the services offered by swandorhotels.com. If information is received from a child under 18 years of age, swandorhotels.com has the right to delete this information. However, in limited circumstances, such as the execution of reservation procedures and the purchase of other travel-related services, or in other exceptional circumstances (such as when the features relate to families), swandorhotels.com may process personal data of children only with the consent of the parent or guardian.
7. SOCIAL MEDIA PLUGINS
Various social media plugins are integrated into the swandorhotels.com website and mobile application. By clicking on one of the integrated social media buttons, some of the User's information is shared with social media providers. If the User is logged in to the social media account at the same time or if social media cookies are stored in the User's browser, the social media provider may recognise the visit on our website or mobile application and show these activities in the User's social media profile.
It is possible for social media providers to record information such as the URL or IP address of a visited website, even if the user does not have an account on a social network (e.g. Facebook), is not logged in to the provider of the plug-in or has not clicked on the plug-in.
To prevent social networks from associating your visit to the swandorhotels.com website with your user accounts, you must log out of your user account before visiting our website.
RIGHTS OF THE USER
By contacting swandorhotels.com as the data subject;
To learn whether their personal data is being processed or not,
Request information if personal data has been processed,
To learn the purpose of processing their personal data and whether they are used in accordance with their purpose,
To know the third parties to whom personal data are transferred domestically or abroad,
To request correction of personal data in case of incomplete or incorrect processing and to request notification of the transactions made within this scope to third parties to whom personal data are transferred,
Although it has been processed in accordance with the provisions of the Law and other relevant laws, to request the deletion or destruction of personal data in the event that the reasons requiring its processing disappear and to request notification of the transactions made within this scope to third parties to whom personal data is transferred,
To object to the emergence of a result against you by analysing the processed data exclusively through automated systems,
In case of damage due to the processing of personal data in violation of the Law, it has the right to demand the compensation of the damage.
If the User submits his/her requests regarding the above-mentioned rights to swandorhotels.com in accordance with the application procedures stipulated in the Communiqué on the Procedures and Principles of Application to the Data Controller, swandorhotels.com will finalise the request free of charge as soon as possible and within 30 (thirty) days at the latest. However, if the transaction requires an additional cost, swandorhotels.com may charge the fee in the tariff determined by the Personal Data Protection Board.
For more detailed information on the processing of personal data by swandorhotels.com and ensuring data security, please refer to swandorhotels.com Personal Data Protection and Processing Policy.
8. CHANGES TO BE MADE IN THE CONFIDENTIALITY POLICY