PRIVACY AND PERSONAL DATA PROTECTION POLICY

As yourhotelmassage.com, we take utmost care regarding the security of your personal data. Your personal data is processed and stored in accordance with the Law No. 6698 on the Protection of Personal Data (“KVKK”).

1. How Your Personal Data May Be Processed

According to the KVKK No. 6698, the personal data you share with yourhotelmassage.com may be obtained, recorded, stored, modified, reorganized, and processed in any manner by us as part of any data recording system, whether fully or partially, automatically or non-automatically. Any transaction performed on data under KVKK is considered as "processing of personal data."

2. Purposes and Legal Reasons for Processing Your Personal Data

The personal data you share will be processed for:

• Meeting the requirements of the services we provide to our customers in accordance with the contract and technology, and improving our products and services;
• Providing information to prosecutors, courts, and relevant public officials in matters related to public safety, in case of requests and as required by legislation;
• Offering our members a wide range of opportunities or sharing them with individuals or institutions that can provide these opportunities within a legal framework;
• Analyzing advertising preferences,

in accordance with the KVKK No. 6698 and relevant secondary regulations.

3. Information About Third Parties or Organizations to Whom Your Personal Data May Be Transferred

For the purposes mentioned above, the personal data you share with yourhotelmassage.com may be transferred to; our main shareholders, shareholders, advertisers, our domestic/international affiliates directly or indirectly, member companies using the infrastructure of masajlazim.com, and those related persons and organizations for the services provided, as well as other third parties and organizations with whom we collaborate and receive services in the capacity of Data Processor.

The arrangements regarding cookies to be used for advertising purposes are included in the "yourhotelmassage.com Cookie Policy," which forms a part of this "Privacy and Personal Data Protection Policy" you are currently reading. To learn more about our Cookie Policy, please click here.

4. How Your Personal Data is Collected

Your personal data is collected through:

• Forms on the yourhotelmassage.com website and mobile applications, including information such as name, surname, address, phone number, business or personal email address; preferences on pages accessed using a username and password; IP records of transactions carried out; data collected by the browser including cookie data; and browsing duration and details, as well as location data;
• Individuals sharing personal data through business cards, resumes (CVs), and other means for purposes such as establishing a commercial relationship with yourhotelmassage.com, applying for jobs, or making offers, whether in physical or virtual environments, face-to-face or remotely, verbally or in writing or electronically;
• Data obtained indirectly from various channels, such as websites, blogs, competitions, surveys, games, campaigns, and other purpose-built (micro) websites, and social media; data related to reading or clicking on newsletters; data provided by public databases; profiles and data shared from social media platforms (Facebook, Twitter, Google, Instagram, Snapchat, etc.) can also be processed and collected.

5. Personal Data Collected Before the KVKK Came into Effect

yourhotelmassage.com did not start its publication life before the effective date of KVKK, which is April 7, 2016, and therefore does not have any personal data stored before this date. (If your website collected data before this date, the methods of processing and storing that data must be specified.)

6. Transfer of Your Personal Data

Personal data collected through any of the methods mentioned above, processed in Turkey or to be stored outside Turkey, may be transferred to service intermediaries located abroad (to countries accredited by the Personal Data Board with sufficient protection in the area of personal data protection), provided that it remains within the scope of KVKK and is in accordance with the contractual purposes.

Your personal data may be transferred to:

• Business partners with whom cooperation is made for the presentation and promotion of products and services;
• Authorized authorities that will determine your location in case of an emergency call;
• Regulatory and supervisory institutions, courts, enforcement offices, and other public institutions or organizations authorized to request your personal data;
• Legal entities in a commercial relationship with yourhotelmassage.com that have your phone number;

It may be transferred when deemed necessary.

7. Storage and Protection of Personal Data

yourhotelmassage.com is responsible for taking software measures such as hashing, encryption, processing records, and access management, as well as physical security measures to prevent the unlawful processing of personal data, to block unauthorized access, and to ensure the storage of systems and databases containing your personal data, as required by Article 12 of the KVKK. In case of learning that personal data has been obtained unlawfully by others, the situation will be reported immediately, in accordance with legal regulations, and in writing to the Personal Data Protection Board.

8. Keeping Personal Data Updated and Accurate

According to Article 4 of KVKK, yourhotelmassage.com is obligated to keep your personal data accurate and up to date. In this context, for yourhotelmassage.com to fulfill its obligations arising from current legislation, our members are required to share accurate and up-to-date information or update it through the website/mobile application.

9. Rights of Personal Data Owners Under Law No. 6698

The 11th article of Law No. 6698 on the Protection of Personal Data came into effect on October 7, 2016, and according to this article, the rights of the Personal Data Owner after this date are as follows:

• The Personal Data Owner may apply to yourhotelmassage.com (the data controller) to:
• Learn whether personal data is being processed;
• Request information regarding their personal data if it has been processed;
• Learn the purpose of processing personal data and whether they are used in accordance with their purpose;
• Know the third parties to whom personal data is transferred, domestically or internationally;
• Request correction of personal data if it is incomplete or incorrectly processed;
• Request deletion or destruction of personal data under the conditions stipulated in Article 7 of KVKK;
• Request that the transactions of correction, deletion, or destruction of personal data be notified to third parties to whom personal data has been transferred;
• Object to the emergence of a result against the person, which is concluded exclusively through automated systems;
• Request compensation for damages incurred due to the unlawful processing of personal data.

10. Contact and Application Method

The Data Controller Representative to be appointed by yourhotelmassage.com will be announced in the Data Controllers Registry and on the internet address where this document is located once the legal infrastructure is provided.

Personal Data Owners can direct their questions, opinions, or requests to the email address [email protected].

yourhotelmassage.com may respond to requests received in writing or digitally, provided that they are justified and responded to within 30 days, either positively or negatively. The necessary processes regarding requests are generally free of charge. However, if the processes require a cost, yourhotelmassage.com reserves the right to charge a fee. These fees will be determined according to the tariff set by the Personal Data Protection Board in accordance with Article 13 of the Personal Data Protection Law.

By sharing your personal data on our website, applications, and other channels, you acknowledge that you have read our Personal Data Policy, which includes the conditions regarding the processing, methods of processing, transfer, sale of data, and other related matters. You agree that the data shared with yourhotelmassage.com, a social media application, may be used on the website, applications, and social media channels, and you may receive notifications and suggestions. You also accept that it may be shared with third parties for commercial purposes as long as it benefits the members and that you will apply to yourhotelmassage.com before exercising your legal rights. You declare that you have given your consent, defined as explicit consent, based on informed understanding and freely expressed will, which holds great importance under KVKK.