Personal Data Processing Disclosure Text
A. Personal Data Protection and Processing Policy
As SAPAZ OTELCİLİK TURİZM İNŞ. SAN.TİC. A.Ş. (“Port Bosphorus Hotel”), we attach the utmost importance to the security of your personal data. With this awareness, as a Company, we highly value the processing and preservation of all kinds of personal data belonging to all individuals associated with the Company, including those benefiting from our products and services, in compliance with Law No. 6698 on the Protection of Personal Data (“KVKK”). Fully acknowledging this responsibility, we process your personal data as the “Data Controller”, as defined in the KVKK, in the manner described below and within the limits prescribed by the legislation.
The protection of personal data is among our Company’s fundamental policies. Throughout our existence, we have prioritized the confidentiality of personal data, adopted it as a working principle, and provided our employees with working instructions in line with this principle. Our Company accepts and undertakes to comply with all responsibilities imposed by the KVKK. With full awareness of this responsibility and as the Data Controller, we process, record, transfer, share, and store your personal data as explained below and within the limits set by the legislation.
For questions regarding our Company’s “Personal Data Processing Disclosure Text”, you may contact us using the following details:
Application Address: Kılıçali Paşa Mahallesi Meclis-i Mebusan Cd. No:13 Karaköy / Beyoğlu / İSTANBUL
Application Email: kvkk@portbosphorushotel.com
Our Company reserves the right to update this “Personal Data Protection Disclosure Text” at any time in line with changes in the applicable legislation.
B. Collection, Processing, and Processing Purposes of Personal Data:
Our Company’s Personal Data Protection and Privacy Policy has been prepared in accordance with the KVKK. Accordingly, your personal data may be collected through automatic or non-automatic methods, verbally, in writing, or electronically, via offices, branches, dealers, call centers, websites, social media channels, mobile applications, and similar tools, depending on the services, products, or commercial activities provided by our Company. Your personal data will be processed, created, and updated as long as you benefit from our Company’s products and services.
Additionally, your personal data may be processed when you:
a. Use our call center or website,
b. Visit our Company, facilities, or units,
c. Browse our website or social media channels,
d. Participate in training, seminars, or events organized by our Company.
Your personal data, obtained with your consent or based on legal grounds under Turkish law, will be processed for the following purposes:
a. Conducting necessary work by our business units to provide you with our products and services,
b. Customizing and recommending our products and services based on your preferences, habits, and needs,
c. Improving the quality of our services and enhancing our quality policies,
d. Informing you about general and special campaigns, promotions, discounts, and similar benefits,
e. Processing your personal data, preferences, transactions, and browsing duration when you log in to our platforms with your username and password to provide requested information and services,
f. Notifying you about membership-related matters (renewal, expiration, etc.) regarding any cards (e.g., Wyndham Rewards Card) issued by our Company or affiliated entities, as well as website memberships,
g. Ensuring the legal and commercial security of our Company and related parties (administrative operations, physical security of locations, business partner/customer/supplier evaluations, legal compliance, financial affairs, etc.),
h. Managing security operations, accidents, or similar medical/insurance-related incidents,
i. Conducting market research and R&D (research and development) to improve our product range, services, stores, IT systems, and security systems,
j. Using CCTV footage to ensure the safety of individuals in our facilities and assist in preventing, detecting, and prosecuting criminal offenses, as well as protecting our legal rights,
k. Providing information about requested services, events, and inquiries,
l. Determining and implementing our Company’s commercial and business strategies,
m. Executing our Company’s human resources policies,
n. Fulfilling legal obligations explicitly required by law.
Your personal data may be processed by our Company, affiliated entities, and third parties listed in Section (E) below, in compliance with Articles 5 and 6 of the KVKK.
C. Method and Legal Basis for Personal Data Collection:
Your personal data is collected through verbal, written, or electronic means for the purposes stated above to ensure the lawful provision of our products and services and to fulfill our contractual and legal obligations.
Collected personal data is processed, recorded, transferred, shared, and stored in line with Articles 5 and 6 of the KVKK and for the purposes outlined in Section (B).
Key Principles:
Lawfulness & Fairness: We process personal data in compliance with legal principles and good faith.
Accuracy & Up-to-Date Data: We ensure data accuracy and update it as needed.
Purpose Limitation: Data is processed only for specified, legitimate purposes.
Data Minimization: Only necessary data is processed.
Retention Period: Data is retained only as long as required by law or for its purpose.
Privacy Policy:
By using our website, you consent to the collection and use of your personal data as described. We are committed to protecting your privacy. This policy applies only to our website and not to third-party sites. If you do not agree, please refrain from sharing personal data.
Data Usage Purposes:
Sending newsletters or notifications via email,
Delivering printed materials or other correspondence,
Processing reservations and managing your account,
Calculating transaction statistics,
Generating commercial analytics on website usage.
Cookies:
We use cookies to enhance your experience, remember preferences, and improve site functionality. You may disable cookies, but this may limit website features.
D. Processing of Special Categories of Personal Data:
Under Article 6 of the KVKK, certain data (e.g., race, health, sexual life, biometric/genetic data) is classified as “special category”. We process such data only:
a. With explicit consent, or
b. Without consent, if permitted by law (e.g., for public health, medical services, or legal obligations).
E. Recipients and Purposes of Personal Data Transfer:
Your data may be shared with shareholders, business partners, suppliers, authorized public/private entities, and third parties listed in Section (E), per Articles 8 and 9 of the KVKK.
F. International Data Transfers:
We may transfer data abroad if permitted by the KVKK and the Personal Data Protection Board, subject to your explicit consent.
G. Rights of Data Subjects Under KVKK Article 11:
You have the right to:
a. Learn whether your data is processed,
b. Request information if processed,
c. Know the purpose and compliance of processing,
d. Identify third-party recipients (domestic/foreign),
e. Request correction of inaccurate/incomplete data,
f. Demand deletion/destruction/anonymization of data per Article 7,
g. Object to automated decision-making,
h. Claim compensation for damages due to unlawful processing.
Application Procedure:
Submit your request:
In person (with ID) to: Kılıçali Paşa Mahallesi Meclis-i Mebusan Cd. No:13, Karaköy / İstanbul,
Via notary,
Electronically via secure e-signature to www.portbosphorushotel.com,
Via registered email (previously notified to the Company).
We will respond within 30 days. Requests without ID verification or for third-party data will not be processed.
H. Data Retention Periods:
Your data will be deleted, destroyed, or anonymized when the processing purpose ceases or legal retention periods expire.
I. Cases Where Data May Be Processed Without Explicit Consent:
Per KVKK Article 5, we may process data without consent if:
Required by law,
Necessary to protect life/body integrity,
Related to contract performance,
Necessary for legal obligations,
Data is publicized by you,
Necessary to establish/exercise/defend legal rights,
Necessary for legitimate interests (without harming your rights).
Note: Even if data is deleted, we may share it with authorities if legally required.
Contact: kvkk@portbosphorushotel.com