KVKK Policy

SUMMARY TEXT

SCOPE AND PURPOSE

This Policy aims to make regulations regarding the processing of personal data arising from legal, commercial or financial relations entered into by (DREAM WORLD) OPTİMAL TURİZM SANAYİ TİCARET ANONİM ŞİRKETİ with its customers, personnel and real or legal persons with whom it communicates and interacts, or obtained directly, within the scope of the Law on Protection of Personal Data No. 6698 and the KVKK Policy Book, to determine the conditions to be complied with, and to declare and announce them.

Disclosure Obligation

Within the scope of the KVKK (Law on Protection of Personal Data) No. 6698, which entered into force on 07.04.2016, personal data processed during the relations of DREAM World with its customers, employees, as well as real or legal persons with whom they communicate and interact, must be bound to a legal order due to the obligations and requirements brought by the legislation.

DREAM WORLD pays high attention and care to the personal data security and privacy principles of customers, personnel and related persons with whom it communicates and interacts. Priority is given to the personal data security of the relevant persons during the performance of services.

In accordance with the provisions of the aforementioned law, all kinds of personal data (including special categories of personal data) that can be associated with a real person are considered personal data within the scope of the KVK Law. These personal data are processed by DREAM WORLD as Data Controller within the framework of the limits ordered by the legislation and with the methods explained in detail below.

"Processing of Personal Data" refers to any operation performed on data such as obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying or preventing the use of these data by fully or partially automatic means or by non-automatic means provided that they are part of any data recording system.

Purpose of Processing Personal Data and Legal Basis

Personal data may be collected by DREAM WORLD in electronic or physical environment by automatic or non-automatic methods as required by legislation, for example, through registration to the platform, telephone, fax, e-mail, sms and other social media channels, mobile applications, including audio and video recording, in written or verbal form.

Within the framework of Article 5 of the KVKK No. 6698:

• Explicit consent of the data owner,

• Explicitly provided for in the laws,

• It is mandatory for the protection of the life or physical integrity of the person who is unable to disclose his consent due to actual impossibility or whose consent is not legally valid, or of another person,

• Provided that it is directly related to the establishment or performance of the contract concluded with DREAM WORLD as a result of approval and/or signature, it is necessary to process the personal data of the parties to the contract,

• It is mandatory for DREAM World to fulfill its legal obligation,

• It has been made public by the person concerned himself,

• Data processing is mandatory for the establishment, exercise or protection of a right,

• Data processing is mandatory for the legitimate interests of DREAM World, provided that it does not harm the fundamental rights and freedoms of the person concerned.

And again within the scope of Article 6:

• Explicit consent of the data owner,

• In other cases stipulated in the laws

processed within the specified personal data processing conditions and purposes.

Sharing and Transfer of Personal Data

Personal data belonging to the relevant person; may be shared with domestic / foreign solution partners, project partners, program and cooperation partners, supplier companies, institutions and organizations, independent audit institutions, banks and financial institutions, other companies, persons and organizations from which help and support are received, consultancy firms such as lawyers, financial advisors, law, informatics, quality and finance consultants, with whom DREAM World has commercial, legal and economic relations as a requirement of its activities and responsibilities, upon request by official institutions and organizations in cases where the legislation deems it mandatory, by taking necessary electronic and physical security measures by DREAM WORLD. Can be transferred. These sharing and transfer transactions are also valid for abroad.

DREAM WORLD may transfer, process and store personal data belonging to the relevant person to storage, archiving, servers from which information technology support is received, hosting companies, programs, cloud computing and other electronic environments located in Turkey or in other countries, especially EU countries, USA, UK, abroad, provided that necessary security measures are taken.

Method of Collecting Personal Data

Personal data belonging to the relevant person; data obtained in verbal, written, visual, audio recording or electronic environments through methods such as all contracts/information forms and other documents signed with approval and/or acceptance, approvals, acceptances and notifications made with electronic approval and/or signature, DREAM World's administrative center, physical environments, call centers, websites, mobile applications, internet transactions, social media and other public areas, user interviews, scanning of judicial records, market research, Identity Sharing System, SMS, digital applications made to websites, mobile applications, written/digital applications made to sales teams, call centers, are collected as fully or partially automatic or as part of any data recording system and stored taking into account the statute of limitations in accordance with the relevant legislation.

Personal data collected by DREAM WORLD for the legal reasons stated above may be processed or transferred in line with the previously explained purposes of this policy, taking into account the personal data processing conditions specified in Articles 5 and 6 of the Law on Protection of Personal Data No. 6698.

User Rights (Pursuant to Article 11 of the KVK Law No. 6698)

Relevant persons, regarding their personal data, via the following e-mail address of DREAM World;

• Learning whether it is processed or not,

• Requesting information if processed,

• Learning the purpose of processing and whether it is used in accordance with its purpose,

• Knowing the 3rd parties to whom it is transferred domestically or abroad,

• Requesting correction if it is incomplete / incorrectly processed,

• Requesting the deletion, destruction or anonymization of personal data in case the reasons requiring the processing of personal data disappear,

• Requesting notification of the transactions made pursuant to paragraphs (5) and (6) listed above to the 3rd parties to whom it is transferred,

• Objecting to the emergence of a result against you due to analysis exclusively by automated systems,

• Requesting compensation for the damage in case of damage due to unlawful processing

and has other rights written in the legislation.

Data Controller to Whom Application Can Be Made Within the Scope of the Law

DREAM WORLD Data Controller is the person registered in the VERBIS system at www.kvkk.gov.tr.

The relevant person may send his/her requests, complaints and suggestions within the scope of the rights stated above to the address of DREAM WORLD stated below by applying in person or through a notary public or by specifying the electronic mail address notified by the user during account opening and registered on the website to the electronic mail address stated below.

In applications, name, surname, T.R. identity number, residence or workplace address for notification, Mobile Phone number, e-mail address and the subject of the request must be present, and information and documents related to the request must be added to the application.

The official language in correspondence with DREAM WORLD is Turkish. Therefore, it is essential that all kinds of applications, correspondence, problems, complaints and suggestions be written and sent in Turkish.

If the application is sent in written and physical form, the signature must be wet signed.

Answers to requests, problems, suggestions and complaints are generally not subject to a fee. However, if there is a cost, fee or other cost related to the answer to be given, DREAM WORLD reserves the right to request the fees in the tariff determined within the scope of KVKK Regulations or by other authorities.

For more detailed information or for your problems, requests, suggestions and complaints regarding the KVK Policy, you are kindly requested to apply to kvkk@dreamworldhotels.com.tr.

It is also possible to obtain the KVK Policy book from DREAM World.

This policy has been prepared within the scope of the Law on Protection of Personal Data No. 6698.