As HtoTurizmİnşaatveDış Tic. Ltd. Sti we have prepared this disclosure in order to inform our online visitors, customers, potential customers, supplier employees and supplier authorities regarding the processing, storage and transfer of your personal data within the framework of the Turkish Law on Protection of Personal Datano 6698 (“KVKK”) and its activities arising from relevant legislation and legal regulations.

1) What are the Personal Data Categories We Process and For What Purposes Do We Process Them?

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Personal information of our business partners can be processed byHtoTurizmİnşaatveDış Tic. Ltd. Stiaccording toarticle 4.2 of KVKK in accordance with the principles of 

(i)Being in conformity with the law and good faith

(ii)Being accurate and if necessary, up to date

(iii)Being processed for specified, explicit, and legitimate purposes,

(iv)Being relevant, limited and proportionate to the purposes for which data are processed,

(v)Being stored only for the time designated by relevant legislation or necessitated by the purpose for which data are collected

within the scope of our ongoing business relations with our business partners, it can be processed for the following purposes.(It is possible for one person to fall into multiple categories)

A. Our Online Visitor

Transaction security information(e.g. your IP address information) of our online visitors using our website and (if you provide us with them), identification information, contact information (eg your e-mail address) will be processed for the following purposes.

a) conducting activities in accordance with the legislation

b) conducting information security processes

c) tracking of requests / complaints

d) conducting communication activities

e) giving information to authorized persons, institutions and organizations

f) access to our website via the Internet

B. Customers

Identity information, contact information, customer transaction information(e.g. accommodation information), physical spacesecurity information, financial information, legal transaction information, marketing information(e.g. shopping history information) of the authorities and / or customers of our natural or legal person customers will be processed for the following purposes.

a) carrying out activities in accordance with the legislation, 

b) conducting financial and accounting affairs,

c) conducting / auditing business activities,

d) execution of goods / services after sales support services,

e) conducting sales processes of goods / services,

f) conducting marketing analysis studies,

g) conducting contract processes,

h) giving information to authorized persons, institutions and organizations,

i) ensuring physical space security,

j) elimination of legal disputes

k) carrying out storage and archive activities,

l) conducting risk management processes

m) conducting advertising / campaign / promotion processes

n) execution of loyalty processes to companies / products / services

o) conducting communication activities.

C. Our Potential Customerswww.akkasgroup.com

Identity information,contact information,customer transaction information,physical space security information,marketing information of the employees and / or customers of our natural or legal person customers will be processed for the following purposes.

a) managing the sales processes of goods / services,

b) conducting contract processes,

c) ensuring physical space security,

d) conducting advertising / campaign / promotion processes, 

e) conducting marketing analysis studies

D. Our Supplier Employee

Identification information,contact information,physical space safety information,professional experience information(e.g. in-service training information) of our supplier employees will be processed for the following purposes.

a) conducting communication activities, 

b) execution / audit of business activities,

c) ensuring physical space security,

d) conducting supply chain management processes,

e) conducting logistics activities, 

f) conducting activities in accordance with the legislation,

g) conducting occupational health / safety activities.

E. Our Supplier Representativewww.akkasgroup.com

Identity information,contact information,physical space security,customer transaction information,financial information,marketing information,legal transaction information of our natural person suppliers or legal person supplier representativeswill be processed for the following purposes.

a) conducting / audit of business activities,

b) conducting procurement of goods / services,

c) conducting financial and accounting affairs,

d) conducting contract processes,

e) conducting of investment processes,

f) ensuring physical space security,

g) follow-up and conducting of legal affairs

2) What are the Collection Methods of Your Personal Data?

Your personal data mentioned above in categories are gathered in automatedor non-automated ways through physical means such as order forms, contracts, visitor forms, or information systems and electronic devices (e.g. telecommunications infrastructure, computers and phones), third parties (e.g. KKB and Findeks Report), our website and other documents declared by the person concerned. 

3) What Is the Legal Reason For Collecting Your Personal Data?

Your personal data is processed byHtoTurizmİnşaatveDış Tic. Ltd. Sti. in order to achieve the objectives described above, it is processed based on the following legal reasons stated in Article 5 of KVKK;

(i) Clearly prescribed by law

(ii) Provided that it is directly related to the establishment or execution of a contract, the processing of personal data of the parties necessary to the contract

(iii) Data processing is mandatory for the data controller to fulfiltheir legal obligation

(iv) Data processing is mandatory for the establishment in order to exercise orprotecta right

(v) Data processing is mandatory for the legitimate interests of the data controller, provided it does not harm the fundamental rights and freedoms of the person concerned.

When the data processing activity cannot be based on one of the above legal reasons, your personal data is processed based on your explicit consent.

4) Do We Transfer Your Personal Data to a Third Party?

a)Personal data belonging to our visitorsif required by the relevant legislation can be shared with law enforcement and judicial authorities for the purpose of resolving legal disputes.

b) Personal data of our online visitors if required by the relevant legislation can be shared with judicial authorities and authorized public institutions and organizations for the purpose of resolving legal disputes.

c) Personal data belonging to our customers, can be shared withthe authorized public institutions and organizations in order to carry out the activities in accordance with the legislation, pursue and carry out legal affairs, to inform the authorized persons, institutions and organizations within the scope of the legal regulations; It is transferred to our group companies, suppliers, cargo companies, insurance companies, banks and financial advisors to the extent necessary for the purpose of conducting business operations / auditing, risk management processes and performing our services properly.In addition, the personal data in question may be transferred to the law firm and the judicial authorities, in order to be used as evidence in future legal disputes.

d)The personal data of our potential customers can be transferred to the law firm and judicial authorities in which we receive service in order to be used as evidence in future legal disputes.

e) The personal data belonging to our supplier employee,can be transferredwithin the scope of the legal regulationto the authorized public institutions and organizations in order to carry out the activities in accordance with the legislation, to follow and execute the legal affairs, to inform the authorized persons, institutions and organizations, to carry out / control the business activities; it is transferred to group companies, suppliers, cargo companies, banks and our financial advisor to the extent necessary to perform the service properly. In addition, the personal data in question may be transferred to the law firm and the judicial authorities, in order to be used as evidence in future legal disputes.

f) The personal data belonging to our supplier authority, can be transferredwithin the scope of the legal regulationto the authorized public institutions and organizations in order to carry out the activities in accordance with the legislation, to follow and execute the legal affairs, to inform the authorized persons, institutions and organizations, to carry out / control the business activities; it is transferred to group companies, suppliers, cargo companies, banks and our financial advisor to the extent necessary to perform the service properly. In addition, the personal data in question may be transferred to the law firm and the judicial authorities, in order to be used as evidence in future legal disputes.

5) How Can You Exercise Your Rights Regarding Your Personal Data?

Your requests within the scope of Article 11 of the Law on Protection of Personal Data no 6698, which regulates the rights of the persons concerned, can be conveyed to HtoTurizmİnşaatveDış Tic. Ltd. through the "Application Form to Data Controller" prepared for your convenience in accordance with the "Notification Regarding the Application Procedures and Principles of Application to Data Controller" at the address "https://www.lpphotel.com/".

Data Controller: HtoTurizmİnşaatveDış Tic. Ltd. Sti

Address:HocapaşaMah. İbni Kemal Cad. No: 12 Fatih/İstanbul

Mail:info@lpphotel.com