Privacy and Cookie Policies

At truebluehotel.com.tr (True Blue Hotel), we attach the utmost importance to the security of your personal data. Your personal data is processed and stored in accordance with the Personal Data Protection Law No. 6698 (“KVKK”).

How Your Personal Data May Be Processed

Pursuant to KVKK No. 6698, the personal data you share with truebluehotel.com.tr may be processed by us in whole or in part, automatically or through non-automatic means provided that it forms part of a data recording system, by being obtained, recorded, stored, altered, reorganised — in short, by being subject to any and all operations performed on data. Under the KVKK, any operation performed on data is considered “processing of personal data.”

Purposes and Legal Grounds for Processing Your Personal Data

The personal data you share will be processed in accordance with KVKK No. 6698 and related secondary regulations for the following purposes:

• To fulfil the requirements of the services we provide to our customers, in a manner consistent with the requirements of our agreements and technology, and to improve the products and services we offer;
• To provide information to public prosecutors, courts and relevant public officials, upon request and as required by legislation, in matters relating to public security and in legal disputes;
• To offer our members a wide range of opportunities, or to share such opportunities with individuals or organisations able to provide them, within the legal framework;
• To analyse advertising preferences.

Information on Third Parties or Organisations to Whom Your Personal Data May Be Transferred

For the purposes stated above, the persons and organisations to whom the personal data you share with truebluehotel.com.tr may be transferred include: our principal shareholders, shareholders, advertisers, our direct or indirect domestic/international affiliates; member companies using the truebluehotel.com.tr infrastructure and, without limitation, individuals and organisations related to the services provided; as well as domestic/international organisations and other third parties from whom we receive services or with whom we collaborate in the capacity of Data Processor in order to carry out our operations.

Our policy regarding cookies used for advertising purposes is the “truebluehotel.com.tr Cookie Policy,” which forms part of the “Privacy and Personal Data Protection Policy” you are currently reading. Please click here for information about our Cookie Policy. (You can access the relevant cookie policy example via the link at the bottom of this document.)

How Your Personal Data Is Collected

Your personal data may be processed and collected in the following ways:

• Through forms on the truebluehotel.com.tr website and mobile applications, including information such as name, surname, address, telephone number, business or personal email address;
• Through data including preferences on pages accessed via username and password, IP records of transactions performed, cookie data collected by the browser, and data relating to browsing duration and details, as well as location data;
• From individuals who share their personal data for purposes such as establishing a commercial relationship with truebluehotel.com.tr, submitting a job application, or providing a quote — via business cards, CVs, quotations and other means — whether in a physical or virtual environment, face-to-face or remotely, verbally, in writing, or electronically;
• From data obtained indirectly through various channels, including (micro) websites and social media used for purposes such as websites, blogs, competitions, surveys, games, campaigns and similar activities; email newsletter reading or click behaviour; data provided by publicly available databases; and open profile and data shared on social media platforms such as Facebook, Twitter, Google, Instagram and Snapchat.

Personal Data Obtained Prior to the Entry into Force of the KVKK

As truebluehotel.com.tr did not begin operating before 7 April 2016, the date the KVKK came into force, we hold no personal data stored prior to that date. (If your website was collecting data before this date, the manner in which that data was processed and stored must be clearly stated.)

Transfer of Your Personal Data

Your personal data, collected by any of the methods listed above whether processed in Turkey or processed and stored outside Turkey, may — within the scope of the KVKK and in accordance with the purposes of the agreement — be transferred to service providers located abroad (in countries accredited by the Personal Data Protection Board as providing adequate protection for personal data).

Your personal data may be transferred, where deemed necessary, to:

• Business partners with whom we collaborate and/or from whom we receive services for the provision and promotion of products and services;
• Competent authorities that will determine your location in the event of an emergency call;
• Regulatory and supervisory bodies and other official institutions such as courts and enforcement offices, as well as other public institutions or organisations authorised to request your personal data;
• Legal entities that are in a commercial relationship with truebluehotel.com.tr and hold your telephone number.

Storage and Protection of Personal Data

Pursuant to Article 12 of the KVKK, truebluehotel.com.tr is obliged to take software measures such as hashing, encryption, transaction logging and access management, as well as physical security measures, in order to prevent the unlawful processing of personal data, to block unauthorised access, and to ensure the safeguarding of personal data held in its systems and databases. In the event that personal data is learned to have been obtained unlawfully by third parties, the matter will be reported immediately and in writing to the Personal Data Protection Board, in accordance with the relevant legislation.

Keeping Personal Data Up to Date and Accurate

Pursuant to Article 4 of the KVKK, truebluehotel.com.tr is obliged to keep your personal data accurate and up to date. In this context, members are required to share accurate and current data, or to update it via the website or mobile application, in order to enable truebluehotel.com.tr to fulfil its obligations arising from applicable legislation.

Rights of the Personal Data Owner Under KVKK No. 6698

Article 11 of KVKK No. 6698 entered into force on 7 October 2016. Pursuant to the relevant article, the rights of the Personal Data Owner as of that date are as follows:

The Personal Data Owner may apply to truebluehotel.com.tr (data controller) to:

• Learn whether their personal data is being processed;
• Request information if their personal data has been processed;
• Learn the purpose of processing their personal data and whether it is being used in accordance with that purpose;
• Know the third parties to whom personal data is transferred, domestically or abroad;
• Request the correction of personal data that has been processed incompletely or inaccurately;
• Request the deletion or destruction of personal data within the framework of the conditions set out in Article 7 of the KVKK;
• Request that third parties to whom personal data has been transferred are notified of any correction, deletion or destruction of personal data;
• Object to the emergence of a result against the individual through the exclusive analysis of processed data by automated systems;
• Claim compensation for damages suffered due to the unlawful processing of personal data.

Contact and Application Method

The Data Controller Representative to be appointed by truebluehotel.com.tr will be announced in the Data Controllers Registry and at the internet address where this document is published, once the legal infrastructure is in place.

Personal Data Owners may direct their questions, views or requests to [email protected].

truebluehotel.com.tr may respond positively or negatively to submitted requests in writing or digitally, provided that a reasoned response is given within 30 days. In principle, the necessary procedures relating to requests are free of charge. However, where procedures incur a cost, truebluehotel.com.tr reserves the right to charge a fee. Such fees are determined in accordance with the tariff established by the Personal Data Protection Board pursuant to Article 13 of the Personal Data Protection Law.

By sharing your personal data on our website, applications and other channels, you declare that you have accepted, with explicit consent as defined under the KVKK — being consent that is specific to a particular subject, based on information, and expressed freely — the following: our Personal Data Policy and the terms therein regarding processing, methods of processing, transfer, sale and other related matters; the use of data shared with truebluehotel.com.tr on the website, in applications and on social media channels, for notifications and recommendations, and its sharing with third parties on a commercial basis where this is in the interests of members; and that you will apply to truebluehotel.com.tr before exercising your legal rights.

This agreement was last updated on 12/08/2021.