PDPL Privacy Notice
PRIVACY NOTICE REGARDING THE PROTECTION OF PERSONAL DATA
1. Purpose and Scope of the Notice
Under Law No. 6698 on the Protection of Personal Data ("PDPL"), personal data means any information relating to an identified or identifiable natural person. Under the PDPL, the natural or legal person who determines the purposes and means of processing personal data and who is responsible for establishing and managing the data recording system is qualified as the data controller. Within this scope, your personal data relating to the transactions you carry out through the website www.lalepension.com ("Website") will be processed by Lale Pansiyon ("Lale Pansiyon") as data controller, within the scope, purposes, and legal grounds explained below. In this Privacy Notice, the Website will be referred to as the "Medium."
This Privacy Notice has been prepared in order to inform, in accordance with Article 10 of the PDPL and the Communiqué on the Procedures and Principles to Be Followed in Fulfilling the Obligation to Inform, the natural persons whose personal data is processed by Lale Pansiyon as data controller. Being transparent and accountable is important to Lale Pansiyon. In this respect, the Privacy Notice includes information on the identity of the data controller and its representative, if any; the purposes for which personal data will be processed; to whom and for what purposes personal data may be transferred; the method and legal basis of collecting personal data; and the other rights of the data subject listed in Article 11 of the PDPL.
Lale Pansiyon may update the Privacy Notice in the event of changes in the applicable legislation, decisions of the Personal Data Protection Board, court decisions, changes in the methods, purposes, or reasons for processing and/or transferring personal data, or similar developments. In the event the Privacy Notice is updated, the current text will be published on the Medium. Within the scope of its activities regarding the processing and/or transfer of personal data, Lale Pansiyon may publish additional privacy notices, rules, terms, or other explanations via the Medium. Should you have any questions regarding the matters covered in this Privacy Notice, please contact us at info@lalepension.com.
2. Methods of Collecting Personal Data and Legal Grounds
Ensuring the security of personal data is one of our priorities. Lale Pansiyon processes your personal data in accordance with the provisions of the Constitution of the Republic of Turkey, the PDPL, Law No. 6563 on the Regulation of Electronic Commerce, Law No. 5237 (Turkish Penal Code), and other relevant legislation.
Lale Pansiyon processes personal data collected through the Medium, authorized agencies, service providers, intermediary service providers, social media accounts, cookies, the call center, messaging applications on the Medium, notifications from administrative and judicial authorities, and other communication channels, whether visual, auditory, physical, electronic, verbal, or written, for the purposes of establishing a commercial relationship, receiving job applications, making offers, establishing contractual relationships, and fulfilling obligations arising from law, and/or within the scope of its legitimate interests, in accordance with the personal data processing conditions set out in the PDPL and in line with the legal grounds specified in this Privacy Notice.
When you interact with Lale Pansiyon through its social media channels — Facebook, Twitter, Instagram, and YouTube — the personal data you provide to those social media platforms may also be processed by Lale Pansiyon. However, please note that the use of social media platforms, and the content and features provided therein, are subject to the respective platform's own privacy and usage policies.
We use "cookies" to help personalize your online experience and to enable you to log in to our services. Through cookies on the Medium, Lale Pansiyon collects personal data for various purposes. Cookies are text files placed on visitors' computers by the websites they visit. They are widely used across nearly all websites to enable websites to function effectively and according to visitors' preferences, and to provide information to website administrators. Cookies are used to determine our visitors' preferences, identify requests for a specific page, improve the Medium experience, keep our services secure, and conduct online behavioral advertising activities for our users.
Our Website uses Google Analytics, an analytics service provided by Google Inc. ("Google"). Google Analytics uses "cookies," i.e., text files saved on your computer, to enable analysis of your use of the website. The information generated by cookies regarding your use of the website is transmitted to and stored on a Google server in the United States. Under instructions from the operator of this website, Google uses this information to evaluate your usage and to prepare reports enabling the provision of related services. The IP address transmitted by your browser as part of Google Analytics is not merged with other Google data. If you do not want these cookies to be stored, you may adjust the relevant setting in your browser.
Furthermore, statistical AdWords and double-click cookies are also used on our Website. We use third-party cookies and our own cookies to display personalized advertisements to you on websites. This is called "retargeting" and is intended to take into account the pages you browse on our Website, the products you view, and your clicks on advertising banners shown to you. We also use cookies as part of our online marketing campaigns to see how users, including on third-party websites, interact with our Medium after being shown online advertisements. You can delete these cookies from your browser at any time.
Many internet browsers are set by default to automatically accept cookies. If you do not want these tools to be used, you can disable them through your browser settings. However, please note that in this case you may not be able to use all functions of the Medium to their full extent.
3. Personal Data Processed
The personal data we process may vary depending on the nature of the legal relationship you have established with Lale Pansiyon. Generally, however, the personal data we process are as follows:
Identity Information Your first name, surname, identification information, date of birth, driver's license information, passport number, nationality, etc., which you provide when making a reservation at the pension through the Medium and similar services, during conversations conducted through live support or the call center, and in connection with any application you submit.
Contact Information Your e-mail address, phone number, mobile phone number, social media contact details, address, etc., which you provide when making a reservation at the pension through the Medium and similar services, during conversations conducted through live support or the call center, and in connection with any application you submit.
Customer (Including Guest, etc.) Information First name, surname, nationality, date of birth, Turkish national ID number, passport number, driver's license, gender, reservation information, purchase information, billing information, delivery information, travel information, travel dates, accommodation information, location information, reservation information, customer transaction information, the type and number of travel documents, their validity start and end dates, and the issuing country; call center records, credit card statements, teller account documents, customer instructions and related recordings kept in connection with such channels, information and records collected under requests and complaints and their outcomes, as well as the website passwords and login credentials you create while using our services in virtual environments.
Financial Information Credit/debit card information, bank account information, IBAN information, balance information, receivable balance, and other financial information.
Sensitive Data Special category personal data such as necessary information regarding your health status that may affect the service you receive, disability information, and HES code (a health/travel code system), where explicitly required by legislation and necessary for our operations, and processed based on your explicit consent.
Marketing Information Records reflecting a person's preferences for marketing purposes, targeting information, cookie records, information derived through data enrichment activities, and information and evaluations obtained through surveys, campaigns, and direct marketing activities.
Transaction Security Information IP address information, password and login credential information, cookie information.
Other Information Family members and close contacts information (identity and contact information of the data subject's children and spouse), physical premises security information (entry/exit records, visit information, photographs, camera and audio recordings), and legal proceedings and compliance information (information requests received from judicial and administrative authorities, etc.).
4. Purposes of Processing Personal Data
Under the PDPL, personal data may not, as a rule, be processed without the explicit consent of the data subject. Lale Pansiyon processes your personal data to the extent and in the cases permitted by legislation.
In this context, the purposes for processing your personal data are as follows:
- To verify the identity information of the person making a reservation at the pension through the Medium and of the person on whose behalf the reservation is made,
- To record address and other necessary information for communication purposes,
- To carry out processes related to the establishment and performance of contracts,
- To communicate with our customers regarding the terms, current status, and updates of contracts concluded under the relevant articles of the Distance Sales Contract and the Law on the Protection of Consumers, to provide necessary information, and to fulfill obligations undertaken under the contracts we conclude,
- To prepare all records and documents in electronic or paper form that serve as the basis for such processing,
- To provide information to public officials upon request and as required by legislation regarding matters related to public security,
- To provide better service to our customers, to inform our customers about our products that may be of interest to them taking into account their interests, and to communicate campaigns,
- To provide information to our customers by e-mail or SMS within the framework of the Law on the Regulation of Electronic Commerce and related legislation,
- To increase customer satisfaction, to get to know our customers through the Medium and use this in customer profile analysis, to use this information in various marketing and advertising activities, and, within this scope, to conduct surveys in electronic and/or physical environments through partner organizations,
- To enable our partner institutions and business partners to offer suggestions to our customers and to inform our customers about our services,
- To evaluate customer complaints and suggestions relating to our services,
- To carry out goods and service production, operation and sales processes, financial and accounting activities, and archiving activities,
- To ensure information security,
- To fulfill our legal obligations and exercise our rights arising from applicable legislation.
In addition, the personal data of our employees may be processed, to the extent necessary for the employment relationship, without obtaining their consent. The terms and conditions set out in the Policy on the Protection and Processing of Employees' Personal Data apply to the processing of our employees' personal data.
5. Our Company's Rights and Obligations Arising from the Law
In accordance with Article 20 of the Constitution and Article 4 of the PDPL, personal data is processed and transferred by our Company:
- In compliance with the law and the rule of good faith,
- Accurately and, where necessary, kept up to date,
- For specified, explicit, and legitimate purposes,
- In a manner connected to, limited to, and proportionate with the purposes for which they are processed,
- Retained for the period stipulated by the relevant legislation or required for the purpose of processing,
based on the conditions set out in Articles 5 and 6 of the PDPL.
Personal data shared with Lale Pansiyon is under the oversight and control of Lale Pansiyon. In accordance with applicable legislation, Lale Pansiyon, in its capacity as data controller, has undertaken responsibility for establishing the necessary arrangements and adopting and adapting technical measures to protect the confidentiality and integrity of information. Being aware of our obligations in this regard, we would like to state that we have taken the following administrative and technical security measures. In this context, we would like to inform you that we regularly update our data processing policies.
Lale Pansiyon retains the personal data it processes for the periods determined by legislation; where no specific period is stipulated by legislation, personal data is retained for the period required by Lale Pansiyon's practices and commercial customs in connection with the services provided when processing the relevant personal data, and thereafter, solely for the period deemed necessary in practice to serve as evidence in potential legal disputes. Upon expiry of the specified periods, the relevant personal data is deleted, destroyed, or anonymized.
6. Transfer of Personal Data
The sharing of personal data with third parties takes place within the framework of applicable legislation and/or the explicit consent given by the data subjects. However, due to our legal obligations, and limited thereto, personal data is shared with courts and other public authorities.
In addition, in order to provide the services we have undertaken and to audit the quality of the services provided, personal data is transferred to third parties within the framework of a contractual relationship. Necessary technical and administrative measures are taken to prevent data breaches during the transfer of personal data to third parties; for example, SSL and transport layer security are used during data transfer.
Your personal data may be shared with the partner institutions and organizations we cooperate with to carry out our activities; with third parties acting as service providers and/or intermediary service providers; with our business partners providing special integrator services; with independent auditors; with domestic persons and institutions from which we receive cloud storage services for data; with domestic organizations with which we have agreements for sending commercial electronic messages to our customers; with our financial advisors; with the Interbank Card Center; with banks we have agreements with; with payment service providers; and, within the scope of various marketing activities aimed at providing you with better service and ensuring customer satisfaction, with various domestic agencies, advertising companies, and survey companies, other domestic third parties and related business partners, our shareholders and affiliates, as well as third parties from whom we receive services within the scope of a contractual relationship, our lawyers, our consultants, and legally authorized public institutions and private legal entities.
7. Rights of the Data Subject
Under Article 11 of the PDPL, the data subject has the right to:
a. Learn whether their personal data is being processed; b. Request information regarding such processing if their personal data has been processed; c. Learn the purpose of processing personal data and whether the data is used in accordance with its purpose; ç. Know the third parties, domestic or foreign, to whom personal data is transferred; d. Request correction of personal data if it has been processed incompletely or incorrectly; e. Request the deletion or destruction of personal data if the reasons requiring its processing no longer exist, despite the data having been processed in accordance with the PDPL and other relevant laws; f. Request that the actions taken pursuant to correction, deletion, and destruction requests be notified to third parties to whom the personal data has been transferred; g. Object to a result that is against the data subject arising from the analysis of processed data exclusively through automated systems; ğ. Request compensation for damages in the event of loss due to unlawful processing of personal data.
To exercise these rights, you may submit your request in accordance with Article 13 of the PDPL and the Communiqué on the Procedures and Principles of Application to the Data Controller, in writing, to Lale Pansiyon's address at "Kale Mah. Cami Yanı Sok. No: 9 Eğirdir/ISPARTA," including your first and last name, your signature, your Turkish national ID number (if you are a citizen of the Republic of Turkey) or your nationality, passport number, or identification number (if you are not a citizen of the Republic of Turkey), your residential or business address for service of notice, your e-mail address and phone number for notification purposes, the subject of your request, and any other information and documents necessary to verify your identity — either by using the Application Form or by submitting your request via the e-mail address confirmed as your membership e-mail (or, if you are not a member, by e-mail for general information regarding the PDPL).
Your application will be evaluated by Lale Pansiyon and concluded free of charge within thirty days. However, if the transaction requires an additional cost, a fee may be charged according to the tariff determined by the Personal Data Protection Board.
Data Controller: Lale Pansiyon
Tax Office / Tax ID No.: Eğirdir Tax Office 28459879732
Address: Kale Mah. 6 Nolu Sok. No: 2 Eğirdir / ISPARTA
Registered Electronic Mail (KEP) Address: lalepension@hs01.kep.tr
Contact Phone: +90 542 241 72 13
Business License: 27/12/2021 – 2021-32-0051
Tradesmen's Registry No.: EĞİRDİR - 32/4928
Sustainability Certificate: —
MERSİS: —
E-mail Address: info@lalepension.com