SECURITY STATEMENT AND POLICY

Protection of Personal Data and Privacy Policy Web Site Confidentiality Agreement How to use and protect the information we obtain about you and the services you request while visiting this website and benefiting from the services we provide through this site is subject to the conditions set forth in this "Privacy Policy".

By visiting this website and requesting to benefit from the services we offer through this website, you accept the terms set forth in this "Privacy Policy".

I. Purpose of the policy of protection and processing of personal data As Villa Sun Flower Hotel, the data received from our customers or prospective customers have been kept confidential and never shared with third parties, in accordance with the sensitivity of the work we have been dealing with as Villa Sun Flower Hotel. Protection of personal data is the basic policy of our company. Even before there was any legal regulation, our companies and affiliates attached great importance to the privacy of personal data and adopted this as a working principle and gave their employees working instructions in line with this principle. As Villa Sun Flower Hotel, we undertake to comply with all responsibilities brought by the Law on the Protection of Personal Data. Our company's principles regarding the protection of personal data also cover our subsidiaries.

II. The scope and change of the personal data protection and processing policy This Policy, prepared by our company, has been prepared in accordance with the Personal Data Protection Law No. 6698 (“KVKK”). The law has entered into force with all its provisions as of today. The data obtained from you with your consent or in accordance with other laws listed in the Law will be used to improve the quality of the services we provide, to improve the services offered to you and our quality policy. Again, some of the data we have is depersonalized and anonymized. These data are used for statistical purposes and are not subject to Law enforcement and our Policy. Villa Sun Flower Hotel's Personal Data Protection and Processing Policy aims to protect the automatically obtained data of our customers, prospective customers, employees, customers and employees of companies working in solution partnership with us, or other persons, and includes regulations regarding these. Our company has the right to change our policy and our Regulations, provided that they comply with the law and that personal data is better protected.

III. Basic rules regarding the processing of personal data

a) Compliance with the law and the rules of honesty: Villa Sun Flower Hotel questions the source of the data it collects or receives from other companies and attaches importance to obtaining them in accordance with the law and within the framework of honesty rules. In this context, it makes necessary warnings and notifications to third parties (agencies and other intermediary institutions) that sell the services offered by Villa Sun Flower Hotel in order to protect personal data.

b) Being accurate and up-to-date when necessary: ​​Villa Sun Flower Hotel attaches importance to the fact that all data within the institution are correct, not contain false information, and finally, if there is a change in personal data, they are updated if they are communicated to it.

c) Processing for specific, clear and legitimate purposes: Villa Sun Flower Hotel processes the data only for the purposes it offers and for which it receives the consent of the people during the service. It does not process, use and make use of data other than for business purposes. d) Being connected, limited and measured for the purpose for which they are processed: Villa Sun Flower Hotel uses the data only for the purpose for which they are processed and to the extent required by the service. e) Retention for the period stipulated in the relevant legislation or required for the purpose for which they are processed: Villa Sun Flower Hotel retains the contractual data as long as the conflict periods of the Law, the requirements of the commercial and tax law. However, when these purposes disappear, it deletes or anonymizes the data. It should be emphasized that, whether Villa Sun Flower Hotel has collected or processed the data with consent or in accordance with the law, these principles listed above still apply. According to article 11 of the Personal Data Protection Law, you have the following rights. In order to facilitate these rights, an application form has also been prepared by Villa Sun Flower Hotel for you. Persons whose personal data are processed, by applying to our contact announced on our website by Villa Sun Flower Hotel, regarding their own data; a) Learning whether your personal data has been processed, b) Requesting information about this if your personal data has been processed,

ç) To learn the purpose of processing personal data and whether they are used in accordance with its purpose, ç) To know the third parties to whom personal data is transferred in the country or abroad,

d) Requesting correction of personal data in case of incomplete or incorrect processing,

e) Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in the law,

f) Requesting notification of the transactions made pursuant to subparagraphs (d) and (e) to third parties to whom personal data has been transferred,

g) Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,

ğ) In case of loss due to unlawful processing of personal data, it has the right to demand the compensation of the damage. As Villa Sun Flower Hotel, we respect these rights. Maximum Savings Policy/Stinginess Policy According to this policy, which is called the maximum savings policy or the stinginess policy, the data reaching Villa Sun Flower Hotel is processed into the system only as needed. Therefore, which data we collect is determined by the purpose. Unnecessary data is not collected. Other data transmitted to our company are transferred to company information systems in the same way. Redundant information is not recorded in the system, deleted or anonymized. These data can be used for statistical purposes. Health data, which is one of the special quality data, is taken only in order to provide better service to customers and protect their health and is kept in the system with care. Deletion of personal data Personal data is deleted, destroyed or anonymized by our company, automatically or upon the request of the person concerned, when the periods required by law to be kept, the completion of judicial processes or other requirements are removed. Accuracy and up-to-dateness The data within Villa Sun Flower Hotel are processed as declared by the relevant persons as a rule. Villa Sun Flower Hotel does not have to investigate the accuracy of the data declared by customers or people who contact Villa Sun Flower Hotel, and this is not done legally and due to our working principles. The declared data is considered correct. The principle of accuracy and timeliness of personal data has also been adopted by Villa Sun Flower Hotel. It updates the personal data that our company has processed from the official documents it receives or upon the request of the person concerned. It takes the necessary measures for this. Privacy and data security Personal data is confidential and Villa Sun Flower Hotel respects this confidentiality. Only authorized persons can access personal data within the company. All necessary technical and administrative measures are taken to protect the personal data collected by Villa Sun Flower Hotel and to prevent it from falling into the hands of unauthorized persons and to prevent our customers and prospective customers from being victims. In this framework, it is ensured that the software complies with the standards, that the third parties are carefully selected and that the data protection policy is complied with within the company.

IV. Data processing purposes Villa Sun Flower Hotel's personal data collection and processing will be carried out for the purposes specified in the clarification text. Data is collected and processed for the purpose of establishing the contract and providing better service to customers.

V. Customer, prospective customer and business and solution partners data Collection and processing of data for the contractual relationship If a contractual relationship is established with our customers and prospective customers, the collected personal data can be used without the customer's consent. However, this use takes place in line with the purpose of the contract. The data is used to the extent of better execution of the contract and the requirements of the service and updated when necessary by contacting the customers. On the other hand, the data left to us by our prospective customers (prospective customers) are processed in order to provide them with an easier and higher quality service afterwards. If this data has not turned into a contractual relationship upon request, it will be deleted. Business and Solution Partners Data Villa Sun Flower Hotel adopts the principle of acting in accordance with the law when sharing data with both business and solution partners. Data is shared with business and solution partners with the commitment of data confidentiality and only as much as the service requires, and these parties are compelled to take measures to ensure data security.

DATA SUPPORTER AND DATA PROCESSOR

Data Controller is OTEL Kahyam Turizm İşletmecilik ve Tic.Ltd.Şti.) and data processor is ETS Ersoy Turistik Servisleri A.Ş. www. etstur.com and https://www.etstur.com/Privacy-Policy

1- The HOTEL accepts, declares and undertakes that the necessary permissions for the transfer and processing of the personal data it has obtained and to be shared within the scope of the Agreement and the personal data to be obtained by ETSTUR on behalf of itself have been obtained from the data owners in accordance with the Law No. 6698. HOTEL accepts, declares and undertakes that it will fully fulfill all kinds of obligations stipulated within the scope of Law No. 6698 in its capacity as Data Controller.

2- Provided that ETSTUR has the title of "Data Processor" during the performance of the services included in the contract, ETSTUR accepts to fulfill all responsibilities and obligations under the definition of Data Processor in the Law No. 6698. In any case, ETSTUR cannot be held responsible for the transactions that are under the responsibility of the Data Controller and in the Law No. 6698, and under no circumstances does it hold the title of Data Controller in terms of the personal data transferred to it by the HOTEL and the personal data to be obtained by ETSTUR on its behalf.

3-ETSTUR is not the subject of any direct or indirect damage, except in cases where personal data is used outside of its purpose due to its own fault, as defined in the Law No. 6698, or if it is illegally disclosed to third parties due to its fault.

4-ETSTUR is obliged to take all necessary technical and security measures to ensure the appropriate level of security in order to prevent the unlawful processing of personal data, to prevent unlawful access to personal data and to ensure the preservation of personal data.

5-Parties are authorized to terminate the Agreement immediately, without prejudice to all claims for compensation, as a result of notification from any official institution within this scope.

USAGE AREAS OF YOUR PERSONAL DATA

Your personal data collected and processed within the scope of the service you purchased, only for the purpose of carrying out the work and when necessary, accompanied by confidentiality agreements;

Making your hotel reservations,

Providing your transportation, if any,

Preparation of hotel check-in procedures,

Maintaining hotel service standards,

Ensuring institutional and administrative management,

It is transferred to the solution partners of OTEL and companies in the position of performance assistants or to the affiliates of other OTEL.