Privacy Notice on the Processing of Personal Data

Your personal data is processed by ELA HOSPİTALİTY TURİZM VE OTELCİLİK ANONİM ŞİRKETİ("Hotel") as the data controller within the scope of the Personal Data Protection Law ("Law"). This privacy notice aims to inform you about how your personal data are processed by the Hotel.

The General Data Protection Regulation (hereafter referred to as the “GDPR”) applies to the data controllers who offer their services to people in the EU. If you are an individual using our Application within the EU, please see our GDPR-compliant privacy notice by clicking on the link here to find out about how your personal data are processed by the Hotel.

The Hotel has designed the Ela Excellence application ("Application") as a digital service channel available to everyone. With this Application, you can benefit from the services offered by the Hotel.

The Purposes and Legal Basis for Processing of Your Personal Data

Articles 5 and 6 of the Personal Data Protection Law regulates the legal basis for the processing of personal data. The purposes for which we process your personal data and the legal basis for such purposes are specified below:

For the following purposes, based on the legal requirement to process personal data in order to execute or perform an agreement:

• To create your user account in the Application, to enable you to log into the Application with your account and update your user information,
• To ensure that you benefit from the services offered by the Hotel, in this context, to receive and finalize your reservation requests regarding the services.

For the following purposes, based on the legal requirement to process data in order to grant, exercise or protect a right:

• To detect and prevent problems and errors with suspicious/illegal transactions within the scope of access and use of the Application,
• To protect and exercise our rights and execute legal processes in the event of a potential legal dispute.

For the following purposes, based on the legal basis of fulfilling our legal obligations:

• To fulfill our legal obligations when we are requested to do so by authorized institutions or institutions, or when we are required to notify such institutions (e.g., sharing your information when requested by a public institution regarding a suspected illegal transaction).

For the following purposes, based on the legal requirement to process data for our legitimate interests provided that this processing shall not violate the fundamental rights and freedoms of the data subject:

• To receive and finalize your questions, suggestions, requests, and complaints through the Application,
• To contact you about our services and the operation of our Application (for example, sending you notifications about innovations, and changes in the Application, or about your requests),
• To collect your evaluations regarding our Application within the scope of improving our Application and ensuring customer satisfaction.

For the following purposes in case you grant your explicit consent:

• To conduct campaigns, promotions, and events specific to Application users, to inform you within this scope, and to provide you with products, services, and opportunities that we think may be of interest to you (such studies allow us to increase your loyalty and satisfaction with our products/services).

Your explicit consent will be asked separately (not as a part of this privacy notice) and even if you choose to grant your consent, you will have the right to withdraw it any time.

Your Personal Data We Process

Within the scope of the purposes and legal basis specified in this Privacy Notice, your identity, contact, customer transaction, and financial information, your suggestions, questions, and requests, and legal transaction, and transaction security information are processed.

The Methods We Use for Collecting Your Personal Data And The Legal Basis Associated With Such Methods

We collect your personal data using automated and partially automated methods through our Application. We collect your personal data subject to the legal basis defined in article 5 of the Law when the processing of such personal data is required for executing or performing an agreement when the processing of data is required for granting, exercising or protecting a right, to fulfil our legal obligations, and when the processing of data is necessary for our legitimate interests. If there is no legal basis specified in the Law, your explicit consent is asked.

Exercising the Rights of the Data Subject

Article 11 of Personal Data Protection Law regulates the rights of data subjects. You have the following rights pursuant to this article:

• Learn whether your personal data has been processed,
• Request relevant information if your personal data has been processed,
• Learn the purpose of personal data processing and whether it has been used for the intended purpose,
• Learn the domestic and overseas third parties to which personal data was transferred,
• Request correction in case of missing or incorrect personal data and request notification of such transaction to third parties to which your personal data was transferred,
• Request deletion or destruction of your personal data in case the reasons behind data processing no longer apply, even if it was processed in compliance with the Law and other relevant legal provisions, and if your personal data was processed incompletely or incorrectly, request notification of such transaction to third parties to which your personal data was transferred,
• Object to any unfavorable result occurring on your end due to analysis of your processed data exclusively by automated systems,
• Request indemnification of loss due to unlawful processing of your personal data.

You can send an e-mail to ege.ozen@ozakglobal.com with your e-mail address registered in our systems to convey your requests regarding your rights to our Hotel. You may also send your requests using other methods specified in the Communique on the Procedures and Principles of Application to the Data Controller.