CLARIFICATION TEXT ON PERSONAL DATA PROCESSING

As Hacınurioğlu Turizm Ticaret A.Ş. ("Company"), we show maximum sensitivity to the security of your personal data. With this awareness, you, our esteemed visitors and our customers attach great importance to the processing, storage and deletion of personal data in accordance with the Personal Data Protection Law No. 6698 ("LPPD" or "Law"), the secondary regulations (regulation, communiqué, circular) that have been enacted and will be enacted in accordance with the Law and the decisions to be taken by the binding Personal Data Protection Board.

The protection of personal data is among the basic policies of our Company and has given priority to the confidentiality of personal data, adopted it as a working principle and instructed its employees to work in line with this principle. Our company accepts and undertakes to comply with all responsibilities brought by the LPDP. This information text has been prepared in order to inform you about the processing of your personal data, the purposes of processing, the legal reasons, the method of collection, to whom it can be transferred and your rights under the LPPD within the scope of Article 10 of the LPPD No. 6698 as the "data controller" of Hacıurioğlu Turizm Ticaret A.Ş.

1. INFORMATION ON DATA CONTROLLER

Information about our Company as the data controller is as follows.

Data controller's;

1. PURPOSE OF PROCESSING PERSONAL DATA

Your personal data may also be transferred limited to the personal data processing conditions specified in Articles 5 and 6 of the Law No. 6698 and the notification of your identity information numbered 1774 to the official authorities for the purpose of establishing the security of our Hotel and benefiting from our services and internet access offered by our Hotel to our visitors and guests, the use of our Hotel's social facilities (Spa-Wellness, Fitness and other sports and activities), the management of access records, the fulfillment of our obligations arising from the law and legislation.

In this context, your personal data may vary depending on the services, products or commercial activities provided by our Hotel; it may be collected verbally, in writing or electronically by automatic or non-automatic methods, offices, branches, dealers, call center, website, social media channels, mobile applications and similar tools. As long as you benefit from our company's products and services, your personal data can be processed by creating and updating.

• In addition, in order to benefit from the products and services of our Hotel when you use ourcall
   center or website,
• When you visit our hotel, facilities, units and businesses located in our facilities,
• When you visit our website or social media channels/spaces,
• Your personal data may be processed when you participate in trainings, seminars or organizations organized by our company.

Your personal data obtained from you with your consent or due to the legal compliance reasons stated in the laws of the Republic of Turkey;

• Our business units can carry out the necessary works to benefit you from the products and services offered by our hotel,
• Suggesting and presenting the products and services offered by our hotel to you by customizing them according to your tastes, usage habits and needs,
• Improving the quality of the services offered by our hotel and developing our quality policy,
• Being informed about and benefiting from the general and special campaigns, promotions, promotions, discounts and similar advantages offered by our hotel,
• To be able to process your personal data, preferences, transactions and the data obtained together with your browsing time in the relevant channels when you log in with your username and password in order to receive services from the channels offered by our hotel,
• To make notifications (renewal, expiration, etc.) about the website memberships of our Hotel with all kinds of loyalty cards issued and/or to be issued by our Hotel, to inform you about all kinds of communication with you, new services and products to be offered, changes, innovations and similar issues that may occur in personal data policies and membership conditions,
• Ensuring the legal and commercial security of our Hotel and the persons who have business relations with our Hotel (administrative operations for communication carried out by our Hotel, ensuring the physical security and supervision of the locations of our Hotel, evaluation processes of the business partner/customer/supplier (authorized or employees), legal compliance process, financial affairs, etc.),
• Managing security operations, accidents or other similar events for medical-insurance purposes,
• Conducting Market Research and R&D (research and development) studies, as well as developing and improving our product range, services, stores, information technology systems and security systems,
• To inform you about the information, activities and services you will request from our hotel,
• Determination and implementation of commercial and business strategies of our hotel
• Ensuring the execution of our hotel's human resources policies and
• If it is clearly stated in the legislation or if necessary, fulfillment of a legal obligation determined by the legislation
• Due to force majeure, including infectious epidemics such as COVID-19,
   it may be processed by our Hotel within the personal data processing conditions andpurposes specified in Articles 5 and 6 of the Personal Data Protection Law.

1. METHOD AND LEGAL REASON FOR PERSONAL DATA COLLECTION

Your personal data are collected in all kinds of verbal, written or electronic media, in printed/electronic forms, contracts/commitments, e-mail, reports, business cards, events, Wi-Fi, Security Cameras, your license plate, business partners and face-to-face interviews depending on the method, in order to provide our products and services within the legal framework determined as the Company in line with the purposes specified in the above articles and to fulfill the responsibilities of our Companies arising from the contract and the law completely and accurately. Your personal data collected for this legal reason areprocessed, recorded, transferred, shared and stored for the purposes specified in this Clarification Text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of thePersonal Data Protection Law.

1. DELETION, DESTRUCTION AND ANONYMIZATION OF PERSONAL DATA

In accordance with the LPPD, when the purpose requiring processing in accordance with Article 7/1 of the LPPD disappears and/or when the statute of limitations, which we are obliged to process your data in accordance with the legislation, expires, your personal data will be deleted, destroyed or anonymized by us.

1. TO WHOM AND FOR WHAT PURPOSE PERSONAL DATA MAY BE TRANSFERRED

1. OTHER RIGHTS OF PERSONAL DATA OWNERS LISTED IN ARTICLE 11 OF THE LPPD

We inform you that you have the following rights in accordance with Article 11 of the Personal Data Protection Law;

• You have the right to learn whether personal data has been processed or not,
• na te gaan of de persoonsgegevens al dan niet zijn verwerkt,
• Requesting information regarding the personal data if they are processed,
• Learning the purpose of processing the personal data and whether they are used for the purpose or not,
• Being informed about the third parties to whom personal data are transferred domestically or abroad,
• Requesting correction of the personal data in case they are short or wrong processed and the transaction performed under this scope to be informed to the third parties to whom the personal data are transferred,,
• Although it has been processed in accordance with the provisions of the law and other relevant laws, to request the deletion or destruction of your personal data in the event that the reasons requiring its processing disappear, and within this scope and in case of incomplete or incorrect processing of your personal data, to request notification of the transactions made to third parties to whom your personal data has been transferred,
• Objecting to any application response against himself/herself, resulting from the analysis of processed data exclusively by the automatic systems
• Claiming the compensation of the loss in case of suffering loss due to illegal process of the personal data.

1. APPLICATION METHOD TO THE DATA CONTROLLER

You can forward your applications for your rights listed above to our Company with a petition to be sent to info@bluemarlindeluxe.com or a petition to be physically submitted to human resources or other methods specified in the LPPD. Depending on the nature of your request, your applications will be concluded free of charge as soon as possible and within thirty days at the latest; however, if the transaction requires an additional cost, you may be requested with a charge according to the tariff to be determined by the Personal Data Protection Board.

1. AMENDMENTS AND UPDATES

This information text has been prepared within the scope of the Law No. 6698 and the Regulations and Communiqués published within the scope of the said Law and the personal data processing purposes and policies of our Company. Necessary changes can be made to the information text in line with the relevant legal legislation and/or changes in the personal data processing purposes and policies of our Company.