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RUPSCONFIDENTIALITY POLICY
RUPS has undertaken the principle of providing confidentiality of the personal information you have shared with us. For these purposes, this Confidentiality Policy was formed to inform you in the process of operation of the website www.rups.com.tr (“Website”) operated by Cleo Turizim Marina Yat İşi. Ve İnş. San. Tic. A.Ş. (“RUPS ”), with regard to the information shared by the Website Users / Visitors (“Data Holder”) or the data produced by RUPS while the Data Holder is using the site, in addition to giving the terms and conditions. The service to be provided by RUPS will be referred to as “Service”.
WHAT IS PERSONAL DATA AND DATA PROCESSING
Under the “Confidentiality Policy”, the information on your identity (name, surname, TR ID Number etc.), address, phone data, profession, IP address, bank account numbers or such other information which could be associated with you (“Personal Data”) while the Private Data being a special type thereof is your race, ethnical origins, political thought, philosophical belief, religion, sect or other beliefs, wear, association, foundation or syndicate membership, medial, sex life, criminal convictions and security measures related data as well as biometric or genetic data (“Private Data”).
Processing the Personal Data means acquiring, recording, storing, saving, altering, rearranging, explaining, transmission, taking over, converting them to in an acquirable form, classifying, or preventing its use or similar procedures that are carried out on the Personal Data either entirely or partially or on the condition to be part of any data recording system through entirely or partially automatic, or on the condition to be a part of any data system, non- automatically.
SCOPE OF THE CONFIDENTIALITY POLICY
As a part of the offered service, We, CLEO Furthermore, cookies are used in the Site in order to improve user experience, provide efficient operation of the website and follow up the statistical data. Some of the personal data referred to above can be acquired using some cookies and the users will be deemed to have accepted use of such cookies by using the Website. Please see our RUPS Cookie Policy to obtain information on the function of the cookies, as to which cookies are used, purpose of use and alter your cookie preferences [GM1]
The data which become irrevocably anonymous will not be assumed as personal data under KVKK and the processing in relation with such data will take place notwithstanding the Confidentiality Policy.
FOR WHICH PURPOSES ARE YOUR PERSONAL DATA PROCESSED
Your personal data can be processed to provide best services by RUPS, to realize your demands or expectations using the products and services offered, to offer our clients with a required service level, hospitability and personal experience, performance of necessary planning, evaluation or works by our business units in the process of our client’s using our products or services, correspondence, notifications or reservations related to our accommodation services, offering products or services after customizing according to wishes, usage habits and requirement of third parties, following up demands, recommendations or complaints from third parties, customer satisfaction management, and planning, statistics and satisfaction studies, determination and application of commercial, legal or business strategies, for the purposes of provision legal, technical, commercial or business security provision of the related parties who are in business relation with RUPS.
Your personal data can also be processed in order to give a better and more reliable service, provide sustainability, carry out quality evaluation and improving works, to provide third parties for their performance as service provider in technical, logistical or purposes hereof, in order to carry out such services.
RUPS may share your personal data with outsource service providers, legal offices, authorized bodies or corporations, research companies, storage, archiving, IT support service providers, consulting companies or such other third parties in order to improve Data Owner experience (including improvement and customization), to provide Data Owner’s security, to determine illegal or unauthorized uses, to perform operational evaluations, to remedy the failures related to site services or to realize any purpose listed hereunder, including the providers who send SMS, email or other transmissions.
Furthermore, part of the personal data referred to hereunder and acquired by RUPS may be shared with advertisers in order to adapt the ads to target mass, only along with the information of other users. In this scope, no personal data is provided, they are used only to carry out some analyses on the user tendencies in a group, carrying out statistical studies with anonymized data and for the purposes of segmentation.
RUPS may disclose your Personal Data due to any one of the following reasons: (i) legal requirements; (ii) to comply administrative or judicial proceedings, or justice office requests; (iii) to carry our Service Requirements; (iv) to preserve its operations; (v) to protect rights, confidentiality, security or properties of third parties to take reasonable measures or to limit any losses which could be encountered.
No third party other than RUPS is able to access or alter these information without your approval.
When you carry out your transactions in the Website, you accept provision of the data to Explanation Text”, [GM2] you can submit your demands to Data Officer along with your application satisfying the Communiqué on Application Procedure and terms to our [email protected] e-mail address through e-signed statement or to our address Mustafa Kemal Bulvarı Babataşı Mahallesi No:113 Fethiye/Faralya with original signature or through a notary public.
Your demands will be handled and concluded as soon as possible, latest within 30 days.
RUPS may either accept the demands or refuse them stating the grounds, and we may submit such reply to the demanding person in writing or electronic media. In case the demand is accepted, we, RUPS are obliged to perform accordingly. In case your demands are refused by RUPS or you are not satisfied from the response, or are not replied at all, or reply has not been served to you within 30 days from your being informed, you may place complaint with the Board of Personal Data Protection within 30 days from expiry of such 30 days period,
In addition to this, if you do not want to receive any commercial e-mails regarding the service provided by RUPS, you can use your relevant refusal right freely through the statement to be sent to [email protected]
HOW LONG YOUR PERSONAL DATA ARE STORED?
RUPS will keep your Personal Data as long as required for processing under this “Confidentiality Policy”, unless a longer keeping period is required or such data keeping is not allowed.
Additionally, RUPS may preserve the personal data through the time lapse period as specified in relevant legislation in case of a dispute between him and the Data Owner, limited with the RUPS, as the service provided may collect, maintain and/or transmit your data under the “Confidentiality Policy”. Such Personal Data processing will be carried out in line with the Personal Data Protection Code (“KVKK”) 6698.
This “Confidentiality Policy” does not reflect the confidentiality practices of third parties to whom data is transmitted and RUPS will assume no obligation for their confidentiality policies and/or personal data processing. This “Confidentiality Policy” does not cover the practices beyond control of RUPS, the information collected by third party websites and/or platform, the information collected by third parties through the links on RUPS website or the titles, campaigns or other ads or introductions on the third party websites sponsored and/or participated by RUPS. RUPS will not be responsible for the transactions related to the personal data collected or used by third parties through their own websites, and in the case you give your personal information on those sites, use or visit them, their confidentiality policy and service terms will apply.
WHICH PERSONAL DATA IS PROCESSED?
Under this heading, some of your personal data are processed under the Services provided by CLEO. Such personal data could contain the following: Your ID information, communication information, user / client transaction data (the data directly related to your reservations, the information on your accommodation at the Hotel and your visit, your Product or service purchase information etc.), payment data, the information on the people accommodating along with you, marketing and communication preference records, IP address, the pages you monitored in our website, your mobile device ID data, if you have used your mobile device, and any information which you provided to us and approved or we can acquire from third parties after your explicit approval can be collected, processed and recorded by us similar functions on our behalf.
Furthermore, your personal data can be used, subject to your explicit consent, for other marketing communication for promotion, campaign, offer, bulletin, activity or similar information aimed at our products and services.
We are processing your personal data collected in line with the foregoing purposes based on one or several legal reasons counted below:
We preserve your entire personal data processed by us as per KVKK and other legislation and in any case, as long as the foregoing legitimate purposes survive, by taking entire administrative or technical measures.
WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
RUPS may transfer the personal data of the Data Owner to third parties either in or outside of Turkey, who provide services to RUPS for the necessary third parties (banks, credit card companies etc.). The information to be shared are all financial data including credit card number, date of expiry and CVV2. Such information are not processed or stored by RUPS. The current summarized transaction data related to such transaction however might be processed by RUPS without covering credit card and/or bank account data.
WHAT ARE YOUR RIGHTS AS DATA OWNER
In relation with your data processed within RUPS, you have the below counted rights:
For the applications related to your foregoing demands, you can check “RUPS Personal Data Protection purpose of defense required under such dispute.
DATA SECURITY
RUPS hereby represents and warrants that it will keep the personal data confidential, to consider such obligation as necessary and provide their reasonable preservation, to do its best and to take necessary measures in an effort to protect necessary and reasonable integrity of such data, to take necessary measures to prevent publishing or unauthorized use or disclosure to third parties of the said personal data either partially or entirely so that they are not subjected to any lost, abuse or illegal performance.
In case there are links to other applications on the website, RUPS does not assume any responsibility with regard to the confidentiality policies and their contents.
You can forward your questions, concerns or complaints on interpretation and application of this Policy to the below given contact address:
Contact:
Cleo Turizim Marina Yat İşi. Ve İnş. San. Tic. A.Ş.
Company Registration Number (Mersis No): 0211127637600001
Telephone: +90 252 614 0091
E-mail: [email protected]
Address: Mustafa Kemal Bulvarı Babataşı Mahallesi No:113 Fethiye / Muğla