PRIVACY STATEMENT

Data Controller: Şimşekler Teşebbüsleri Ltd. Şti.               
Şehit Osman Yusuf Sok. No.1  Yenişehir / Lefkoşe / KIBRIS

We, as Sunter Turizm A.Ş. (“Limak Cyprus’’), prepared this privacy statement to inform our visitors, our guests, our workers, our applicants and our business contacts regarding processing, storing and transferring the personal data with regard to our hotel management and tourism activities and within the scope of The Law on the Protection of Personal Data no. 6698 (“The Law”) and related legislation.

Which category of personal data do we collect? What is the purpose of processing your personal data?

We collect the below mentioned data categories within the scope of our hotel management, tourism and accommodation services purposes:

1 - Identity Data
2 - Communication Data
3 - Familial Data
4 - Financial Data
5 - Employment Data
6 - Other Data

Identity Data

Explanation : Data which are related to authentication of data subject.

From whom data are collected : We collect identity data from our guests, our visitors, our members, our workers, our applicants and third parties which we cooperate with.

Content : The data such as name, surname, identification number, passport number, license plate information, photograph, identity card photocopy.

Purpose of Data Collection : We collect identity data from either our guests or our visitors due to legislation that we are subject to and the purpose of providing security for all our guest.
We are obliged to record identity data of our workers due to labor and social security legislation.
We collect identity data from our applicants for the purpose of job application evaluation; also from our supplier, subcontractor and other parties that we established similar business contact to fulfill our commercial requisites and obligations   arising concluded contracts.

Legal Grounds for Data Collection : The basic legal grounds for collection of relevant data are legal obligations that arising out of related legislation.
Nevertheless, we collect identity data due to contractual relation between data subjects and us.
We sometimes collect visitor’s (from each same-day visitor) identity data due to our legitimate interests and the adopted corporate principles for purposes of providing security and more peaceful accomodation environment for our guests etc. 

Data Collection Method : We collect data by printed forms and sometimes directly by forms situated in electronic.

 

Communication Data

Explanation : Personal data which provide communication with data subject.

From whom data are collected : We collect communication data from our guests, our visitors, our members, our workers, our applicants and third parties which we cooperate with.

Content : The data such as home and work address, mobile phone number, home telephone number, room number, postal address, e-mail address and IP address.

Purpose of Data Collection : We collect communication data from either our guests or our visitors due to legislation that we are subject to and for the purposes such as providing security for all our guests; informing our visitors and guests regarding our advertisements, campaigns and promotions; performing loyalty card programs, employment relationship and hotel management activities.
We are obliged to record communication data of our workers due to labor and social security legislation.
We collect communication data from our applicants for the purpose of notification for result of application evaluation; also from our supplier, subcontractor and other parties that we established similar business contact to fulfill our commercial requisites and obligations arising concluded contracts.

Legal Grounds for Data Collection : The basic legal grounds for collection of relevant data are legal obligations arising out of related legislation.
Nevertheless, we collect communication data due to contractual relation between data subjects and us.
We sometimes collect relevant data due to our legitimate interests and the adopted corporate principles for the purposes of providing fulfillment of customer satisfaction survey or security.

Data Collection Method : We collect data by printed forms and sometimes directly by forms situated in electronic. 

 

Familial Data 

Explanation : Data that belong to family members of data subject.

From whom data are collected : We collect familial data from our guests, our members, our workers and our applicants.

Content : The data such as name, surname, identification number, photograph, marital status, home and work addresses, mobile phone number, fax number, home telephone number, mail and e-mail addresses of family members. 

Purpose of Data Collection : We collect familial data of our guests due to legislation that we are subject to and for the purpose of providing security for all our guests.
We are obliged to collect familial data of our workers and our applicants due to labor and social security legislation.

Legal Grounds for Data Collection : The basic legal grounds for collection of relevant data are legal obligations arising out of related legislation.
Nevertheless, we collect familial data due to contractual relation between data subjects and us.
We sometimes collect relevant data due to our legitimate interests and the adopted corporate principles for the purposes of communicating in emergency situations or supporting education of workers’ relatives by providing scholarships.

Data Collection Method : We collect data by printed forms and sometimes directly by forms situated in electronic.

 

Financial Data

Explanation : Data such as bank accounts, credit cards, invoice information.

From whom data are collected : We collect financial data from our guests, our members, our workers and third parties which we cooperate with.

Content : The data such as fee, authorized signatures list, salary, bank account, credit card, invoice information and tax number.

Purpose of Data Collection : We collect financial data from either our guests or our members due to legislation that we are subject to and for providing flawless and excellent service.
We are obliged to collect financial data of our workers due to labor and social security legislation.
We collect financial data from our supplier, subcontractor and other parties that we established similar business contact to fulfill our commercial requisites and obligations arising concluded contracts.

Legal Grounds for Data Collection : The basic legal grounds for collection of relevant data are legal obligations arising out of related legislation.
Nevertheless, we collect financial data due to contractual relation between data subjects and us.
We sometimes collect financial data due to our legitimate interests and the adopted corporate principles for the purposes of providing facility of payment for our steady guests and including our workers to campaigns or promotions that are provided by partner banks or other financial institutions.

Data Collection Method : We collect data by printed forms and sometimes directly by forms situated in electronic. 

 

Employment Data

Explanation : Data which provide maintenance of a flawless employment relation.

From whom data are collected : We collect employment data from our workers and our applicants.

Content : The data  related to i.e. identity, communication and financial data, gender, height and weight, social security number, blood group, document which represents personal status, place of residence, IP records, bank account, residence document, reference/ service /working paper from previous employer, criminal record document, CV (curriculum vitae), military service, disability status, data within the scope of tax immunity with respect to disability status, insurance, housing and renting information, foreign language, state of education, professional knowledge and previous address and signature.

Purpose of Data Collection : We collect relevant data to fulfill our obligations which are arisen out of law.

Legal Grounds for Data Collection : The basic legal grounds for collection of relevant data are legal obligations that arising out of related legislation.
Nevertheless, we collect employment data due to labor contract between data subjects and us.
We sometimes collect employment data due to our legitimate interests and the adopted corporate principles for the purposes of attendance for company orientation programs, insurance, communicating with relatives in emergency situations and placing applicants in appropriate positions.

Data Collection Method : We collect data by printed forms and sometimes directly by forms that are in electronic. 

 

Other Data

Explanation : Data which are collected within the scope of our comercial activities.

From whom data are collected : We collect these data from our guests, our members, our workers, our visitors, and third parties which we cooperate with.

Content : These are identity, communication and financial data, CCTV (closed-circuit television) records, voice records, facial recognition systems’ records, magnetic card and turnstile records; identity, communication and financial data which belong to our business connections; data which are collected within the scope of an organised event or organisation, data related to accommodation, data that are collected at complaints and in process of contact with the firm.

Purpose of Data Collection : We collect relevant data from either our guests or our members due to legislation that we are subject to and for providing a flawless and excellent service for all our guests, to provide security; conducting our tourism and hotel management activities; using them in advertisements, marketing, and promotions; organising events and organisations.
We collect relevant data from our supplier, subcontractor and other parties that we established similar business contact to fulfill our commercial requisites and obligations arising concluded contracts.

Legal Grounds for Data Collection : The basic legal grounds for collection of relevant data are legal obligations that are arisen out of related legislation.
Nevertheless, we collect relevant data due to our legitimate interests and the adopted corporate principles for the purposes of providing facility of payment for our steady guests; including our workers to campaigns or promotions that are provided by partner banks or other financial institutions; providing security and more peaceful accommodation environment for our guests; organising events with respect to number of participants and their  special case or demand; presenting special price and accommodation choices for our steady guests, to communicate with them in case of lost property, evaluating the satisfaction of guests and workers and answering the complaints.

Data Collection Method : We collect data by printed forms and sometimes directly by forms situated in electronic.


Due to legislation in our country, we share above-mentioned identity, communication and other several data with authorities that are precisely authorized by legislation periodically or upon their request.


Do we transfer your personal data to domestic third parties?
Competent Authorities:

Besides, your personal data are shared with authorized entity or institution on grounds of   a verdict or upon the request of an administrative agency which is precisely authorized by legislation.

Limak Tourism Group Facilities:

Apart from that, your personal data are shared with below mentioned tourism facilities which shall join onwards limited purposes of providing more privileged services for you.

Limak Arcadia Hotel & Resorts
Limak Limra Hotel & Resorts
Limak Atlantis Deluxe Hotel
Limak Lara Deluxe Hotel
Limak Ambassadore Hotel
Limak Eurasia Luxury Hotel

Limak Thermal Hotel
Limak Cyprus Deluxe Hotel

Third Parties:

Your personal data are also shared with another group of third parties which we cooperate with.  Among these primarily natural or legal persons such as travelling agencies, online hotel reservation services.

Your personal data are shared for the purposes of satisfying your demands for our services such as reception, transfer etc. or returning your lost & founds s, transferring your bills to the extent to fulfill relevant services with natural or legal persons who are authorized to fulfill these services on behalf of us. 

Do we transfer your personal data to abroad?

Your personal data may be transferred to abroad solely in cases where:

- your explicit consent or
- stipulated situations by The Law take place and where there is an adequate protection in transferred country or
- stipulated situations by The Law take place and by the consent of Turkish Data Protection Board in cases where   no adequate protection in transferred country

For example:  In cases where you get service by a foreign agency, online reservation service etc. or you pay us by a foreign financial services, we may transfer your personal data to abroad for the limited purpose of processing without obtaining your consent for providing service for you, namely to performing our service contract.

For how long your personal data are stored?

Retention periods for your personal data are determined with respect to below mentioned criteria:

- If there is a period which is specified by law or related legislation, relevant data has to be stored at least during that period. In regard to possibilities where requests by courts or administrative agencies which is precisely authorized by law reach us late or a dispute takes place in which we may be part of, the retention period to store personal data is specified by adding 6 months or 1 year to periods that are stipulated by legislation and at the expiration relevant data is deleted.

- If there is no stipulated retention period for processing data in legislation in respect to business relation between us, your personal data shall be stored during the period which is specified in the contract. At the end of this business relation or when the period specified in contract ended, your personal data is deleted without any need for your request.

What are your rights as a data subject?

As a personal data owner you may;

- Obtain information regarding whether your personal data are being processed,
- Request information in case your personal data have been processed,
- Find out the reason for processing of your personal data and whether or not the data have been used properly for this purpose,
- Obtain information regarding the domestic and foreign third parties who received your personal data,
- Request for correction of your personal data if they are missing or wrong,
- Request for deletion or removal of your personal data within the framework of the prescribed provisions referred The Law,
- Request for notification of the third parties your personal data have been transferred regarding the correction of missing or wrong data or deletion or removal of your personal data,
- Object to a result against you due to the analyzing of the processed data by automated decision making systems exclusively, and
- Demand a compensation in case where there is a loss due to your personal data being processed contrary to The Law.

How can you exercise your rights as a data subject?

Without prejudice to other methods specified by Turkish Data Protection Board, you may forward your requests related to your personal data along with documents evidencing your identification (copy of your ID card) to …..  our registered electronic mail address or to Şehit Osman Yusuf Sok. No.1 Yenişehir / Lefkoşe / CYPRUSby post.

We reserve the right to object your application in cases where the information and documents that you sent are wrong or your application is unauthorized.

How long does it take to answer your requests?

Your requests are evaluated and answered within 30 (thirty) days at the latest from date of delivery. In case of negative evaluation, reasoned refusal will be sent to the address in your application by electronic mail or post.