Personal Data Protection Notice (KVKK)
1. Data Controller
Under Turkish Personal Data Protection Law No. 6698 (“KVKK”), Neptün Turizm ve Ticareti A.Ş is the data controller for the processing activities described below and carried out through the Neptün Hotels corporate website.
Address: Sığacık Mah. Akkum Cad. No: 175 Seferihisar, İzmir – Türkiye
Telephone: +90 232 398 14 70
Fax: +90 232 745 70 38
Email: info@neptunclubhotels.com
2. Scope of This Notice
This notice explains personal data processing activities relating to visits to the corporate website and information, requests and questions submitted to our company.
Other processing activities carried out during accommodation, reservations, payments or job applications are explained separately through the channel where the relevant service is provided. You can review the notice concerning job applications on the page accessed through the Careers link.
3. Data Processed, Purposes and Legal Bases
Depending on the nature of your enquiry, the following data may be processed in connection with the information and requests you submit to our company:
| Data category | Processing purpose | Legal basis |
|---|---|---|
| The first name, surname, telephone number, email address and message content you provide | Assessing and responding to pre-contractual information requests | Article 5(2)(c) of KVKK, where processing is directly related to the conclusion or performance of a contract and is necessary |
| Identity details, contact information and message content in general enquiries and correspondence | Assessing and responding to requests and managing correspondence | Article 5(2)(f) of KVKK, based on the legitimate interest necessary for managing requests, provided that your fundamental rights and freedoms are not harmed |
| Correspondence and transaction records relating to disputes | Exercising and protecting legal rights | Article 5(2)(e) of KVKK |
| Records that must be retained or provided under applicable legislation | Fulfilling the company’s legal obligations | Article 5(2)(a) or 5(2)(ç) of KVKK, depending on the relevant obligation |
[This table must be adapted after verifying the company’s actual processes. If data is collected through server logs, website forms or other tools, the data categories, specific purposes and legal bases must be added separately.]
Data processing activities carried out through cookies are explained on a cookie-by-cookie basis in the Cookie Policy.
Where a processing activity requires explicit consent, separate information is provided about that activity and explicit consent is obtained separately.
4. Methods of Collecting Personal Data
Your personal data may be obtained through emails you send to our company and information you share during telephone conversations. Depending on the channel, data may be collected by automated means or by non-automated means forming part of a data filing system.
[Website forms, technical logging systems and other data collection channels must be added here in accordance with actual practices.]
5. Transfers of Personal Data
Transfers of your personal data are limited to the data necessary for the relevant purpose and the transfer conditions set out in KVKK.
[Specify the company’s actual recipient groups and transfer purposes here. For example, where email and hosting providers are actually used, explain which data is transferred to them and for what purposes, and under which obligations information is provided to legally authorised public authorities.]
Where personal data is transferred abroad, the services used, relevant recipient groups, transfer purposes and the transfer mechanism under Article 9 of KVKK are explained separately.
[After checking the service providers, state here whether international transfers take place and, if so, the basis for those transfers.]
6. Retention and Disposal
Your personal data is retained for a period limited to the relevant processing purpose and the retention obligations set out in applicable legislation.
When all conditions permitting processing cease to apply, your data is deleted, destroyed or anonymised in accordance with applicable legislation.
7. Your Rights Under KVKK
By submitting a request to our company, you may:
- Learn whether your personal data is processed and, if so, obtain details about that processing;
- Enquire about the purpose of processing and whether your data is used in accordance with that purpose;
- Request information about third parties to whom your data is transferred within Türkiye or abroad;
- Request correction of incomplete or inaccurate information;
- Request deletion or destruction of your data when the statutory conditions are met;
- Request that corrections and deletion or destruction operations be notified to third parties to whom your data has been transferred;
- Object to a result arising against your interests solely through automated analysis;
- Request compensation for damage suffered due to unlawful processing of your personal data.
8. How to Submit a Request
You may submit requests concerning your rights in writing to the company address stated above, in accordance with the requirements of the Turkish Communiqué on the Procedures and Principles for Applications to the Data Controller.
You may also submit a request to info@neptunclubhotels.com using an email address that you previously provided to our company and that is registered in our system. Other valid application methods specified in the Communiqué remain available.
Your request must include information enabling us to identify you, a contact address for the response, the subject of your request and any supporting documents, where applicable. Only information necessary to verify your identity and assess your request is requested.
Requests are resolved as soon as possible, depending on their nature, and within thirty days at the latest. If processing the request entails additional costs, a fee may be charged in accordance with the tariff determined by the Turkish Personal Data Protection Board.
9. Information and Explicit Consent
This notice is provided for informational purposes and is not a declaration of explicit consent. Reading this notice, visiting the website or submitting a request to our company does not, by itself, constitute explicit consent.
